NCC 2019 Amendment 1 Public Comment Draft

The inclusion of a precise Performance Solution methodology within the BCA is supported in principle but is noted to have significant productivity impacts that should be considered in detail. A regulatory impact statement should be prepared analysing impact/benefit on a range of Performance Solutions including minor departures. In addition, A2.2 should be coupled with a simpler process for BCA verification methods or Codemark type solutions.

A2.2(4) doesn’t however distinguish between complex and minor Performance Solutions. Example of minor Performance Solutions include:
- Codemark certificates such as termite barriers
- BCA conflicts such as primary school lower handrail at landings vs barrier climbability

The PBDB requirements will double the handling time on all Performance Solutions including minor departures.

The definition is being proposed without any detail on its intended implementation. Any public consultation is premature. Future public consultation should be encouraged when the public have enough information about how the definition will be used to comment in an informed way.

Unable to provided comment without details of the definitions intended application.

The child care fire safety updates are much needed but a better way to address in the short-term could be through a national technical advisory note leaning on E2.3 and the Guide. This would ensure a fire safety engineer is engaged when a child care centre is above ground. Any changes should be supported by a regulatory impact statement.

C2.5 and D1.11 appear clunky and may result in confusion. The horizontal exit requirements of C2.5 and D1.11 should be combined/streamlined if possible to better convey the intent of the clauses.

Suggest any changes to E1.5 be part of the broader ABCB Holistic Fire Safety Project.

Spec E1.5 Clause 2(c) is 85 words in one sentence. Suggest this be revisited for readability.

Regarding horizontal exits:
- C2.5 requires at least 2 horizontal exits
- D1.11(a) Doesn’t allow horizontal exits to be counted as required exits
- D1.11(c) Allows horizontal exits to be not more than 2/3 the required exits

The above requirements are confusing and may be a conflict.