Response 174771590

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Kishor Dabasia

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WA Admin: Department of Mines Industry Regulation and Safety - Building and Energy Division

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NCC 2019 Amendment 1

Please provide your recommended change below.

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Radio button: Ticked Process for developing Performance Solutions
Radio button: Unticked Early childhood centres
Radio button: Unticked Spec C1.1 Class 2 and 3 concessions
Radio button: Unticked Definition: Building complexity
Radio button: Unticked Marking specification for ACPs
Recommended change to draft:
Delete first mention of “PBDB” in clause A2.2(4) and replace with “Performance-based design brief (PBDB)”
Comment/reason for change:
To improve readability and be consistent with the way the term has been called up in Schedule 7 of NCC 2019.

NCC 2019 Amendment 1

Please provide your recommended change below.

Your comment relates to:
Please select one item
Radio button: Unticked Process for developing Performance Solutions
Radio button: Ticked Early childhood centres
Radio button: Unticked Spec C1.1 Class 2 and 3 concessions
Radio button: Unticked Definition: Building complexity
Radio button: Unticked Marking specification for ACPs
Recommended change to draft:
Identify the specific clause that D1.11(a)(ii) relates to e.g. D1.2(e) rather than a generic reference to the whole of Part D1.
Comment/reason for change:
To remove any unnecessary ambiguity and clarify the intent of clause D1.11(a)(ii).

The intent appears to be that a minimum of one exit must be provided from each fire compartment but a horizontal exit cannot be used to satisfy that requirement. The current reading of the draft changes does not communicate the specific intent, instead it reads that horizontal exits in an early child hood centre or a school cannot be counted as required exits.

A reference to the whole of Part D1 is too general in nature and creates unnecessary ambiguity. Even within this very Clause, without identifying the specific Clause that D1.11(a)(ii) relates to, subclause (a)(ii) contradicts subclause (c)(i).

(a)(ii) promotes that you can’t count horizontal exits as required exits and then (c)(i) says that horizontal exits cannot comprise more than 2/3 of the required exits.

(c)(i) would suggest that they can be counted as a required exit