[Received by email 14/9/04]

10 September 2004

Comment on the Productivity Commission Draft Research Report

To. building@pc.gov.au

I wish to comment as an individual who has varied skills and experiences in the Building Industry.

I am a developer, builder, building supervisor, company director, Building Surveyor, private certifier, consumer and building surveying and planning consultant to several Local Government Authorities.

The reason for listing these skills and knowledge is to highlight the fact that my views are based on a collaboration of personal experiences, primarily within but not limited to South Australia.

Rather than go into pages of comments on this issue I thought it better to list a range of dot points, which hopefully are more relevant;

•	Generally the document is well balanced,
•	Strongly support the concept of national uniform legislation for building control,
•	Support consolidated building related (not planning) legislation for the Building Code of Australia, licensing, etc,
•	As a past BSAP Board member and Chairman of their Ethics Committee I am aware of petty and vexatious complaints lodged by Councils against certifiers. Although I was mainly dealing with complaints in NSW I am fully aware of a “them and us” mentality,
•	I am also aware of the problems with unqualified Building Surveying practitioners throughout Australia. Most of the issues within the Report appear relevant to NSW. It should be noted that these practitioners, with the same qualifications are practising in Private and Local Government,
•	The ABCB National accreditation framework has been in a final draft format for 3-4 years and supposedly supported by the various States. Numerous reasons have been given why it has not been adopted, such as auditing etc, however I would imagine the longer it can be delayed the less likely grandfathered practitioners weaknesses will be identified,
•	For example SA has, within the past two months, amended its legislation to ensure private certifiers with old qualifications (none of which are in Building Surveying) are not bound to the framework requirements,
•	Consistent interpretation from the various states Fire Authorities would be desirable but improbable,
•	I commend you on identifying the problems with planning and would suggest similar efforts in the planning area would have a much greater benefit than trying to change the way the ABCB operates,
•	The suggestion that the ABCB has had its attention focused on other issues such as disabled and energy is correct and I believe they are the appropriate body to do so. With over 30 years in the building industry the one thing I am sure of is that more topics will require investigation rather than less. The ABCB is perfectly placed to address these issues.
•	There is no requirement in SA for licensed builders or registered works supervisors to maintain their skills and knowledge. This is probably one of the biggest concerns, especially when subcontractors may only need to undertake around 10 hours training per year to have some concept of the changes,
•	If the ABCB accreditation framework was adopted when agreement was met, training of Building Surveyors would now be in place and many of these issues would not exist. Due to individuals associated with the decision making process, having a personal interest in deferring the adoption of these new rules I would not be so negative with this aspect of the report,
•	If qualifications, skills and knowledge of builders, fire authority officers and Building Surveyors were enforced, issues such as quality of building work, performance based assessment etc would be to a satisfactory standard,
•	As a builder, developer I believe the inconsistencies with interpretation by Council planning staff in Councils, let alone the varying criteria of planning rules from one Council to another, is a much greater problem.

Yours faithfully

Grant Riches

[Received by email 16/9/04]

…Just a quick note regarding the NSW building surveyor qualification comments I made.
The past qualification requirements in NSW were less than the norm in Australia however many of them probably have better on-site/inspection practices compared to many higher qualified practitioners, especially the newer breed without on site experience.
There is a need for experts in both elements of building surveying.
Not everything on site goes strictly by the book.

Thanks

Grant Riches