Discussion paper: National Registration Framework for Building Practitioners

There is no point equating 2 entities that are fundamentally different. Architects have greater education and a wider set of skills than Building Designers. To suggest that an architect registered under State legislation should also need to licence as a “Building designer Level 1” shows the authors of the report are not aware of the existing requirements placed upon individuals who wish to register as architects under the nationally consistent registration process.

The proposal currently aims to place a Registered Architect who has completed an AQF 9 course, 3300 hours experience assessed against nationally consistent competencies and pass written and oral exams as being equal to an individual who completes an AQF 8 course followed by 3 years of non-assessed experience. Building designers are not qualified to be architects and architects should not be identified as building designers of any level. The act of downgrading a profession to the level of a para-profession is unlikely to promote confidence with the public and provide the best built environment outcomes for the public.

The proposal will diminish the quality of the built environment by devaluing the architectural profession. The BOAQ can see a circumstance where architectural students will abandon the master degree of their education as the report draws no difference between an individual who completes a 5 year degree followed by competency based experience then passing a nationally consistent written exam and an oral exam and completing a 3 year degree followed by 3 years of non-guided experience. Building Designer has come to mean something very different to the way it is outlined in the document. In Queensland, the architects act prevents a licensed building designer from identifying themselves as an architect. The profession will be diminished if a registered architect is forced to also hold a license that identifies them as a building designer and the public will be short changed if they have their built environment designed and documented by lesser qualified paraprofessionals

While the proposal may increase compliance with the NCC the licencing regime proposed has been in place in Queensland for some time and noncomplying buildings have been constructed under this regime. While licencing tradespeople may provide a way of penalising them if they are found to have not followed the requirements of the NCC what needs to be addressed is the fundamental shortcomings in the procurement of buildings and the shortcuts taken to deliver ever cheaper construction. The NCC incorporates too many Australian Standards to allow practitioners to have a full understanding of all regulations. The Australian standards that are incorporated by direct reference are in many cases poorly drafted or confusing, and there is no verification process that imported materials comply with the standards, through these holes mistakes and incorrect installations are made. Requesting everyone to have a better understanding of the NCC will make little difference to completed buildings until the NCC is a better document.

These comments relate to building design, building procurement and development/feasibility studies, building documentation, contract administration, project management, post constructions services. In summary, these comments relate to the practice of architecture.

The proposal to have registered architects’ licence as building designers of any level is ill considered. To suggest that a professional should need to also licence as a paraprofessional is misguided. Architects should be completely excluded from the requirements of building designer licencing. The proposal brings into question how authorities can promote paraprofessionals with inferior training can be capable of delivering work at the level of real professionals. The proposed level 1 building designer class should be limited in the work they can attempt, and registered architects excluded from the requirements of holding a building design licence. Architects are more extensively trained and tested for registration and better regulated through the acts in each state. The idea to lower the qualifications of those who design, and document projects will not protect the public.

The description of a Level one – open building designer is incorrect as it describes a paraprofessional. The definition is too narrow as architects also administer building contracts and manage projects through all phases of delivery these are skills that building designers do not have.

The scope of work described for a lesser trained paraprofessional is not in the interest of the public. The scope of work outlined in the Class 1 category is beyond the education and experience level outlined for individuals with AFQ 8 education and 3 years’ experience’.

The qualification for an open building designer outlined in the document is too low to allow them to attempt the design of any building. Architects complete a 5-year degree exiting with a masters, 3300 hours experience logged against nationally consistent competencies and then sit a registration exam consisting of written and oral segments, obviously a much higher threshold than outlined in the document. There should be an additional classification above open building designer for architects and the open building class restricted.

Architects are required to log 3300 hours experience against competencies prior to sitting a registration exam. This does not compare to 3 years’ experience in an undefined way after completing a 3-year bachelor degree.

The aim of this proposal is to provide better outcomes in the built environment by placing more emphasis on knowledge of the NCC. In many cases this is not the root of recent problems which have emerged in Australian building stock. The situation is unlikely to be improved by reducing qualification requirements of those that design and document buildings.