Response 584257032

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General Questions

Does the proposed NRF deliver an appropriate and proportionate response to BCR Recommendations 1 and 2?

Please select one item
Ticked Yes
No
Unsure

Will the NRF, if implemented, enhance confidence in the building industry by ensuring that key practitioners in the building process are registered?

Please select one item
Ticked Yes
No
Unsure

Do you foresee any risks in implementing this proposal, noting that the states and territories are responsible for implementation of the NRF?

Please select one item
Ticked Yes
No
Unsure
Please explain your reasoning.
It is not clear that simply being a registered architect is sufficient to ensure that adequate knowledge and practice in documenting and reviewing construction detailing in accord with the NCC and Australian Standards will be guaranteed. In my experience it is not uncommon for inexperienced (registered) architects to produce documentation that omits essential information due to lack of experience. particularly with regard to access / egress and FRL requirements. Certification or a demonstration of the minimum level of EXPERIENCE is key, whether a building designer or architect.

Do you think the proposed NRF will improve compliance with the NCC?

Please select one item
Ticked Yes
No
Unsure
Please explain your reasoning.
Yes, If the emphasis is on verifiable sound EXPERIENCE combined with qualifications. It should not matter if I have been a building designer for 10 years or a registered architect for 3 years when it comes to certifying a building under NCC requirements. It is the benchmark of sound EXPERIENCE+ a recognised TAFE or bachelor qualification that ought to be acceptable.

NRF Discipline Specific Comments

Please provide your comments below.

Your comment relates to:
Please select one item
(Required)
Ticked Building design
Energy efficiency design
Disability access design
Geotechnical design
Structural design
Electrical design
Mechanical design
Hydraulic design
Plumbing design
Fire safety design
Fire systems design
Façade design
Building
Fire systems installation
Plumbing
Building surveying
Fire systems inspection
Project management
Registration levels
Suggestions for Registration Levels

Peer Review - All Buildings no restrictions
Level 1 - All buildings - DTS and performance solutions
Level 1R - All Buildings -restricted to DTS
Level 2 - Medium Rise - DTS and performance solutions
Level 2R - Medium Rise - restricted to DTS
Level 3 - Low Rise buildings - DTS and performance

Descriptions/definitions
Building design work is the development of construction design documentation, [ADD including the co-ordination and integration of professional engineering requirements, into documentation that will be used for construction of the building]. Building design work also includes the compilation of specifications relating to the design of a new building or alterations to an existing building where the design is required to meet the requirements of the NCC, but does not include building professional engineering design work, or building technical design work. Building design work includes, documenting, checking, peer review and signing certificates of compliance.
Scope of work
Level 1 - All buildings - DTS AND performance solutions

Level 1R - All Buildings -restricted to DTS

Level 2 - Medium Rise - DTS AND performance solutions - NCC Class 1 and 10 buildings - performance and DTS. NCC Class 2 to 9 buildings - performance and DTS to a maximum of three storeys above a storey used for parking vehicles including Type A construction.

Level 2R - Medium Rise - restricted to DTS - NCC Class 1 and 10 buildings - restricted to DTS. NCC Class 2 to 9 buildings - restricted to DTS to a maximum of three storeys above a storey used for parking vehicles but not including Type A construction other than for NCC Class 2, 3, or 9 buildings.

Level 3 - Low Rise buildings - DTS AND performance - NCC Class 1 and 10 buildings - performance and DTS. NCC Class 2 to 9 buildings - performance and DTS with a gross floor area of not more than 2000m², but not including Type A or Type B construction.
Qualification requirements
Min Requirements

Peer Review work - AQF 9 and above - Approved Australian Masters degree in architecture, architectural science, architectural design that includes NCC training; or Approved Masters degree in architecture, architectural science or architectural design plus approved NCC training, or Registration as a practicing architect.

Level 1 - All Buildings -performance AND DTS - AQF8 - Approved Australian degree in architecture, architectural science, architectural design that includes NCC training; or Approved degree in architecture, architectural science or architectural design plus approved NCC training, or Registration as a practicing architect.

Level 1R - All Buildings -restricted to DTS - AQF 6/7 - Approved Australian degree, associate degree or Advanced Diploma in architecture, architectural science, architectural design or building design that includes NCC training; or Approved degree, associate degree or Advanced Diploma in architecture, architectural science or architectural design plus approved NCC training, or Registration as a practicing architect.

Level 2 - Medium Rise - performance AND DTS - AQF 6/7- Approved Australian degree, associate degree or Advanced Diploma in architecture, architectural science, architectural design or building design that includes NCC training; or Approved degree, associate degree or Advanced Diploma in architecture, architectural science or architectural design plus approved NCC training, or Registration as a practicing architect.

Level 2R - Medium Rise - restricted to DTS - AQF 6/7- Approved Australian degree, associate degree or Advanced Diploma in architecture, architectural science, architectural design or building design that includes NCC training; or Approved degree, associate degree or Advanced Diploma in architecture, architectural science or architectural design plus approved NCC training, or Registration as a practicing architect.

Level 3 - Low Rise buildings - DTS AND performance - AQF 4/5 - Approved certificate IV or Advanced Diploma in building design or architectural drafting that includes NCC training, or Approved certificate IV or diploma in building design or architectural drafting plus approved NCC training.
Experience requirements
Minimum Experience
Peer Review - All Buildings - no restrictions - AQF9 + minimum 10 years
Level 1 - All buildings - DTS and performance solutions - AQF8 + minimum 5 years
Level 1R - All Buildings -restricted to DTS - AQF 6/7+ minimum 5 years
Level 2 - Medium Rise - DTS and performance solutions - AQF 6/7 + minimum 3 years
Level 2R - Medium Rise - restricted to DTS - AQF 4/5 + minimum 5 years
Level 3 - Low Rise buildings - DTS and performance - AQF 4/5 + minimum 3 years
Any other comments for this discipline
3 years of experience is not adequate for Level 1 Building Design discipline. 5 years minimum should be required and it should be experience across all classes of buildings and 2-9 buildings in particular.

Architectural Registration OR AQF 9 should NOT be the minimum qualification for Level 1/Level 2 design (as the AIA is suggesting / likely to suggest). This is anti competitive in nature. It unfairly discriminates against women and people from low socio-economic backgrounds. Crucially it is not possible to demonstrate an exclusive causal relationship between registration and good build-quality outcomes. It is discriminatory to people from experienced backgrounds who may be more qualified to undertake the work as a registered building designer than a registered Australian Architect eg. a construction manager with 10 years experience in a Tier 1 or Tier 2 building company, an international architect with more experience but who's degree was not transferrable without prohibitive costs and time associated with registration. The focus should shift to 'SOUND (local) EXPERIENCE' combined with qualifications encompassing the NCC. This 'sound experience' should be combined with a qualification from a tertiary intuition, at a matriculation level, that is reasonable and not exclusionary.

AQF 9 OR Registration as a practicing architect + 10 years experience should give you the ability to peer review all Levels of Building Design work. In addition it should be mandatory for all Level 1 unrestricted buildings to be peer reviewed by an AQ9 + 10 years experience qualified design specialist. This cost should be borne by the developer and each jurisdiction should have a 'first off the rank' pool of peer reviewers available as a condition of the Construction Certificate being granted. (Local jurisdictions should consider legislating mandatory hold points in a construction program for peer review eg. waterproofing, waste outlets / overflows / slab falls / fire resisting construction before lining / finishing, flashings etc.). I understand this is not within the scope of this report but it should be considered in the context of a holistic approach and supports the my proposal of a separate level for Registered Peer Reviewer in the discipline of Building Design.

Thank you for reading my submission. I love our industry and am in the process of attempting to become a registered architect through the NpRA (alternative pathway scheme) as I have more than 10 years experience in design and delivery of all building types. I work for a registered architect and refer to myself as a designer. I clearly see the importance of registered architects and their contribution to a better built environment (that's why I am pursuing this as my career) but this can be separated from the issue of quality construction documentation and hence, built outcomes. I can also see things from the perspective of dedicated building designer professionals. Over this time it has been my work experience, dedication to continuing professional development and high professional standards that people have come to rely on - not my Bachelor of Arts (USyd) +Diploma in Architectural Design (TAFE). I don't think that will change if I am fortunate enough to become a registered practicing architect.

Would you like to comment on another discipline?

Please select one item
(Required)
Yes
Ticked No

Other Comments

The ABCB is specifically interested in your comments on the registration levels for building surveyors. Do you agree with the criteria used to distinguish between with the two levels of registration for building surveyors and does it adequately accommodate the different levels of risk?

Please select one item
Yes
Ticked No
Unsure
Please provide your reasoning.
There should be more than two levels
Level 1 - all buildings - 5 years
Level 2 - DTS and performance - 3 years NCC Class 1 and 10 buildings of any size, and NCC Class 2 to 9 buildings no greater than 3 storeys in height and 2,000m2 in area
Level 2 - DTS only - 2 years NCC Class 1 and 10 buildings of any size, and NCC Class 2 to 9 buildings no greater than 3 storeys in height and 2,000m2 in area