Personal information
What is your name?
Name
Raymond Romanos
On whose behalf are you making this submission?
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I am making this submission on my own behalf
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I am making this submission on behalf of a business
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I am making this submission on behalf of an industry body
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I am making this submission on behalf of a government agency
What is your organisation (if relevant)?
Organisation
Romanos Consulting
Which best describes your industry sector?
Which best describes your industry sector?
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Building Commercial
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Building Residential
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Building Commercial and Residential
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Building and plumbing products
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Building Certification/ Surveying
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Architecture and design
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Engineering
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Plumbing
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Compliance, testing and accreditation
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Legal and Finance
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Specialist - disability access
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Specialist - energy efficiency
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Specialist - fire safety
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Specialist - health
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Specialist - hydraulic/ plumbing
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Student/ apprentices
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Trades and other construction services
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Education
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Community and Non-Government organisations
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Government
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General Public
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Other
Please select your State or Territory
State or Territory
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ACT
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NSW
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NT
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Qld
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SA
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Tas
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Vic
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WA
Discussion paper terms and definitions
1. Do you agree that the terms listed above should have nationally consistent definitions?
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Yes
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No
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Why?
Consistency is simpler and will be more condusive for achieving the aims of the definitions.
2. Do you agree with the draft definitions for the terms?
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Yes
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No
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If you do not agree, please provide details of why and how the definitions can be improved.
Essential Services is not intuitive and can be inconsistent with other definitions utilising the word essential. e.g safety and essential services are commonly misused or inter-changed incorrectly. A possible improvement I believe would be dts, CC or NCC services as it seems the list is capturing all the minimum items required for a CC in accordance with the NCC.
Draft building manual dataset
3. Do you agree that the draft dataset could give building owners the information they need to maintain and operate their buildings safely?
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Yes
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No
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Why?
It provides a reference or baseline as what was required to be constructed/provided as part of the CC.
4. What changes can you suggest to improve the dataset (e.g. removing items that would not be helpful to building owners and other potential users of building manuals)?
4. What changes can you suggest to improve the dataset (e.g. removing items that would not be helpful to building owners and other potential users of building manuals)?
None. The more relevant information the better.
Building manual processes - creating manuals
5. Do you believe building surveyors should have a role in verifying the content of building manuals?
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Yes
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No
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Unsure
Why?
They are providing the CC and OC for a development and are the delegated authority for compliance of the development.
If you don’t believe building surveyors should verify the content of building manuals, who should perform this role instead (e.g. a developer, site manager or a contracted third party)?
They would need to rely on input from the relevant disciplines to verify the contents of a building manual which would spread the accountability while still maintaining a single point of authority.
6. Should people who create or verify the content of building manuals be subject to requirements, such as holding certain qualifications or having completed certain training?
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Yes
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No
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Why?
It should be the designer for each relevant discipline.
What requirements would you suggest?
The same requirements for the certification by the designer because it is clear that this could not be completed by the trade that completes the install as they most often do not complete or complete poorly.
7. If you work in the building industry, what guidance, training and/or assistance is needed to ensure building manuals given to building owners, following construction of new buildings, are accurate and complete?
Guidance for industry
None as long as the requirements are articulated as proposed with the requirements included in the NCC.
8. Do you agree occupation approvals should only be issued if there is an accurate and complete building manual?
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Yes
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No
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If you agree, how would you address issues that may be caused by construction models that permit progressive occupation?
progressive manuals and the proposed bond.
9. It has been suggested that for strata buildings, developers should have to provide a bond of one per cent, which is released once the building manual is accepted by the new owners corporation. Do you agree with this incentive?
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Yes
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No
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Why?
Cashed up developers may forfeit the bond to get out as quickly as possible.
10. Other than withholding occupation approvals and bonds, what other incentives or penalties should be considered to ensure developers and builders fulfil the requirements of a building manual?
What other incentives or penalties should be considered?
Not sure if there is any other pragmatic incentive or penalty that would be effective.
If you agree with incentives or penalties, what conditions, if any, should states and territories consider in implementing them?
None to keep the incentive penalty robust.
What exemptions from incentives or penalties, if any, should be considered?
Exemption provided at the discretion of a government body on a case by case basis funded by the developer in the event there is an issue.
How could the issues around progressive occupation be addressed?
No sure how this is an issue as all systems are required to be fully compliant and functional for occupation even when there is separate stage or progressive occupation.
Perhaps any provisions required for progressive stages are included as a requirement in this situation.
Perhaps any provisions required for progressive stages are included as a requirement in this situation.
Building manual processes - updating manuals
11. This paper proposes that information about a building should continue to be recorded during its life. Do you agree that, provided older versions of the building manual are accessible to building owners and it is clear which version of the building manual a person is accessing, new information should continue to be added to the building manual during the life of a building?
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Yes
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No
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Why?
This would be the same as the AFSS and does not present any problems depending on changes to a building as long as they are recorded.
12. What guidance, training and/or assistance is needed to ensure building owners can understand, use and maintain the information in building manuals?
What assistance is needed to ensure building owners can understand, use and maintain building manuals?
None if the front end is written in easy to understand terms and summary/format. Obviously technical details require a minimum level of background/technical knowledge but that should rarely be required by building owners.
13. If a building owner gives responsibility for maintenance decisions to another person, such as a building manager, should the building manager also have legal responsibility for ensuring the building manual is updated?
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Yes
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No
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Why?
The building manager would be aware of all changes, additions etc so it seems logical that if they are delegated the responsibility, recording of works as required would be included in their role.
14. Should there be incentives and penalties for building owners and building managers to ensure they continue to record information about buildings they own or manage?
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Yes
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No
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Why?
The market should be able to do this as any new owners would be entitled to a complete and accurate building manual so it would be in the best interests of the manager (to keep their job) and owners (to be able to sell).
Building manual processes - storage, format, access and ownership
15. Do you believe the building manual should be stored by government(s), individual building owners, and/or by a service provider?
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Government(s)
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Building owners
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Service provider
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Other
Why?
Cheapest and most effective. Building owner has interest to have and maintain a building manual should they ever want to sell and if they don't they can pay to get it. Government would be to onnerous and costly to achieve the same outcome.
16. Do you believe governments need to play a role in delivering building manuals or should this be left to the market?
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Governments should have a role
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It should be left to the market
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Other
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Why?
Can and does get done currently but no requirement/mandate at the moment to ensure it gets done.
17. Stakeholders have commented that digital storage formats can become obsolete in a shorter time than the life of a building. Do you have any comments about the digital format of building manuals and how this issue can be addressed?
How can digital format issues be addressed?
I do not believe this will be an issue as older formats get phase out there is usually backwards and cross compability.
18. Under existing state and territory disclosure legislation, certain building information must be provided to potential owners prior to a contract of sale. If it is not provided or is provided late and materially impacts the potential owners, they have the right to cancel the contract. Do you agree that legislation for a building manual should contain similar provisions?
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Yes
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No
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Why?
Otherwise it wont happen.
19. Do you have any concerns about building information being available to potential buyers?
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Yes
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No
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Unsure
If yes, what are your concerns?
It should not be provided to potential buyers only the actual buyer as part of the settlement otherwise it could, although unlikely become a potential avenue for IP theft.
20. Some stakeholders have suggested accurate and complete building manuals should be a condition of signing large leases e.g. for office buildings. Do you agree?
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Yes
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No
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Why?
Leasee does not have any permanent jurisdiction over the property. Could be a recommendation/optional only in lieu of mandatory.
21. Apart from privacy, security and intellectual property, what issues do you believe should be carefully considered prior to introducing building manuals?
Apart from privacy, security and intellectual property, what issues do you believe should be carefully considered prior to introducing building manuals?
None.
22. Who should be considered the legal owner of information about a building?
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Government(s)
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Building owner(s)
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Building/facility/strata manager(s)
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Other
Why?
They have permanent jurisdiction over a property until it sells
Types of buildings that require a building manual
23. Do you agree the most appropriate option is all new Class 2 – 9 buildings (Option 3)?
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Yes
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No
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Unsure
Why?
Class 1 and 10 are normally completed by smaller operations that do not have the same resources, technical expertise required for class 2-9. These classes could be optional.
24. Do you agree the same dataset could be used for all new Class 2 – 9 buildings?
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Yes
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No
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Unsure
Why?
They are all based on the performance requirements of the NCC.
General questions
25. Do you agree this discussion paper explains the problems caused by building owners not having access to information about their buildings?
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Yes
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No
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Unsure
26. Do you agree with the benefits of building manuals, as identified in this paper?
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Yes
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No
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Unsure
27. Who do you believe will benefit from building manuals and to what extent?
| Building owners A lot Radio button: Checked A lot | Building owners A little Radio button: Not checked A little | Building owners No change Radio button: Not checked No change |
| Building/facility/strata managers A lot Radio button: Not checked A lot | Building/facility/strata managers A little Radio button: Checked A little | Building/facility/strata managers No change Radio button: Not checked No change |
| Building users including tenants A lot Radio button: Not checked A lot | Building users including tenants A little Radio button: Not checked A little | Building users including tenants No change Radio button: Checked No change |
| Developers A lot Radio button: Not checked A lot | Developers A little Radio button: Checked A little | Developers No change Radio button: Not checked No change |
| Builders A lot Radio button: Checked A lot | Builders A little Radio button: Not checked A little | Builders No change Radio button: Not checked No change |
| Sub-contractors A lot Radio button: Checked A lot | Sub-contractors A little Radio button: Not checked A little | Sub-contractors No change Radio button: Not checked No change |
| Architects and building designers A lot Radio button: Checked A lot | Architects and building designers A little Radio button: Not checked A little | Architects and building designers No change Radio button: Not checked No change |
| Building surveyors A lot Radio button: Checked A lot | Building surveyors A little Radio button: Not checked A little | Building surveyors No change Radio button: Not checked No change |
| Government agencies e.g. fire services A lot Radio button: Checked A lot | Government agencies e.g. fire services A little Radio button: Not checked A little | Government agencies e.g. fire services No change Radio button: Not checked No change |
| General public A lot Radio button: Not checked A lot | General public A little Radio button: Not checked A little | General public No change Radio button: Checked No change |
| Other A lot Radio button: Not checked A lot | Other A little Radio button: Not checked A little | Other No change Radio button: Checked No change |
29. Do you believe there are drawbacks to building manuals?
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Yes
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No
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Unsure
30. Who do you believe will be negatively impacted by building manuals and to what extent?
| Building owners A lot Radio button: Not checked A lot | Building owners A little Radio button: Not checked A little | Building owners No change Radio button: Checked No change |
| Building/facility/strata managers A lot Radio button: Not checked A lot | Building/facility/strata managers A little Radio button: Not checked A little | Building/facility/strata managers No change Radio button: Checked No change |
| Building users including tenants A lot Radio button: Not checked A lot | Building users including tenants A little Radio button: Not checked A little | Building users including tenants No change Radio button: Checked No change |
| Developers A lot Radio button: Not checked A lot | Developers A little Radio button: Checked A little | Developers No change Radio button: Not checked No change |
| Builders A lot Radio button: Not checked A lot | Builders A little Radio button: Checked A little | Builders No change Radio button: Not checked No change |
| Sub-contractors A lot Radio button: Not checked A lot | Sub-contractors A little Radio button: Checked A little | Sub-contractors No change Radio button: Not checked No change |
| Architects and building designers A lot Radio button: Not checked A lot | Architects and building designers A little Radio button: Not checked A little | Architects and building designers No change Radio button: Checked No change |
| Building surveyors A lot Radio button: Not checked A lot | Building surveyors A little Radio button: Checked A little | Building surveyors No change Radio button: Not checked No change |
| Government agencies e.g. fire services A lot Radio button: Not checked A lot | Government agencies e.g. fire services A little Radio button: Not checked A little | Government agencies e.g. fire services No change Radio button: Checked No change |
| General public A lot Radio button: Not checked A lot | General public A little Radio button: Not checked A little | General public No change Radio button: Checked No change |
| Other A lot Radio button: Not checked A lot | Other A little Radio button: Not checked A little | Other No change Radio button: Checked No change |