NT September Advocacy Update

Dear all NT Chapter members,

We’ve had a busy last few months with many advocacy projects undertaken, and of course in the middle we had an election. I wanted to provide a quick outline of some of the key issues that we’ve been addressing. 

National Registration Framework (NRF)

This month we have being lobbying locally and nationally on the National Registration Framework (NRF) for Building Practitioners and the changes the ABCB board are considering. We met with Minister Lawler, who has taken our concerns on board and will assist in advocating our position. Our keys points that we shared with the Minister are the following changes that do not support the intent of the Building Confidence Report.

  • Should be based on an assessment of competence
    • The (proposed) NRF is not based on assessment of competency, which is a well-recognised high-quality benchmark for assessment that results in better building outcomes. Experience does not equal competence. Experience equals merely experience and can relate to someone who has done something for a long time, and not necessarily well. There must be an underpinning robust assessment process of experience levels that translate to competencies. These competencies from different types of practitioners in the levels outlined in the NRF must be comparable. 
  • Education and experience requirements are too low
    • The levels of education and assessment of experience set out in the NRF are inappropriate with regard to the skills required to deliver safe buildings and buildings that comply with the NCC in all of its aspects.
  • Registration levels
    • We would strongly recommend that they be described as follows:
      1. Registered architect – all buildings
      2. Registered building designer level 2 medium rise buildings with medium rise being defined as two storeys rather than three, and with qualifications on it depending on the number of consultants that are required to deliver the building
      3. Registered building designer level 3 low rise buildings
        • This would then prevent the necessity of requiring registered architects (noting they are already registered to practice) to also be registered as building designers. It would also differentiate between skill level of an architect and building designer and provide greater confidence and understanding for the public.
  • Scope of work
    • The NRF views architects as largely equal to building designers and other lesser qualified practitioners who offer building design services. This does not provide clarity regarding the relative capabilities of an architect as opposed to a building designer or drafter, and will not result in improved public confidence, which is the core objective of the Building Confidence Report.
  • The distinction between architects and building designers
    • Architectural science and architectural are not terms supported by various Architectural Registration Acts in Australia. The restriction of the term architect is stipulated so that the public and consumers of architectural services have confidence in the standard of professionalism and expertise that they can reasonably expect from an architect. This benefit is diminished when a system such as the NRF implies that people with lesser qualifications are capable of providing equivalent expertise to a registered architect.
  • Medium rise definition
    • The taxonomy defines permitted work for level 2 as NCC Class 2 to 9 buildings – performance and DTS to a maximum of three storeys above a storey used for parking vehicles
    • The definition should be restricted to a maximum of two storeys rather than three. The three storey definition conflicts with the NSW SEPP 65, which defines apartment buildings 3 storeys or more to be designed by an architect.
    • The NRF should be required to deliver a robust system with the capability to handle the future of construction in Australia, which will be considerably more complex
  • Risks to the future of the architecture profession
    • In its present form, Table 01 NRF Taxonomy Level 1, has the potential to reduce the accreditation requirements of a registered architect by allowing a comparison of a person with a degree in architecture plus NCC training to become a registered architect
    • This document and the support of the ABCB may become an influential document in allowing the establishment of “building designers” to a lesser level than a registered architect but by association suggesting a person with a degree in architecture plus NCC training is equal to a registered architect.
    • Given that the funding of University courses in architecture are tied to the requirements of practice, if the equivalent NRF registration requirements are lowered to undergraduate degree plus honours, the federal funding and HECS for Masters of Architecture may be removed.
  • Building Design (includes architect & draftsperson) – Energy Efficiency
    • There appears to be a misunderstanding of the role of architects and building designers with regard to commercial energy efficiency design work.
    • Some architects do specialise in energy efficiency, however it (and energy rating) does not naturally sit within the architectural discipline. Typically, commercial energy modelling is undertaken by specially trained practitioners who may be architects, but who are more likely to be engineers or scientists. Residential energy modelling requires specific training that is not ordinarily included in architectural education. The training is state based and licensed. Practitioners come from architectural, engineering, science and building certification backgrounds.
  • Building Design (includes architect & draftsperson) – Access Consulting
    • There appears to be a misunderstanding of the role of architects and building designers with regard to access consulting.
    • Some architects specialise in access design; however, it does not always sit within the architectural discipline. Often specialist access designers are required. This work is undertaken by specially trained practitioners who may be architects but could also be practitioners from building certification backgrounds. Architectural education includes access design, however, Certificate IV in disability access consulting is not ordinarily included. The training is state based and licenced. Registered architects may not have the required training or experience to perform this role at the level required by state licencing or Certificate IV in disability access consulting.
    • Clarity is required as to “normal” access design performed by architects, and those cases where licenced access experts should be engaged.
  • Project Management
    • Architects must be included as project managers.
    • Project Managers are responsible for project managing the project. This includes managing the program, the scope, the inclusions of all the consultants, as well as managing the cost of the project and keeping the client well informed throughout the project.
    • We recommend the Project Manager should be AQF9 qualified and minimum 2 years post graduate experience, have a code of conduct and be required to hold PI insurance and be required to do ongoing CPD annually.

For the full submission please click here.

Section J and Energy Efficiency

The NT Chapter has been part of the investigation into the implications of adopting Section J of the National Construction Code (NCC) for non-residential buildings in the NT. In response to the findings, the Department of Infrastructure, Planning and Logistics will prepare a cost benefit analysis of adopting Section J for non-residential buildings in the NT. This work will examine both the Section J requirements of the 2016 NCC and the 2019 NCC. This process will include further consultation.

For the Building Energy Efficiency in new commercial buildings in the Northern Territory submission to the Department of Infrastructure, Planning and Logistics click here

Phase one of the NT Planning reform was held on Tuesday 8 September, with phase two to start soon. This has been a great consultative process all along with industry bodies being able to be a key part of the process. For the full information click here.

Minister Lawler has confirmed that the implementation of the Building Confidence report recommendations to NTG will progress forward. We will keep you up to date as this is progressed.

As you are aware the Government Architect position has been vacant for a significant amount of time. We will be pursuing this as it is an important position for the NT. We believe that the role does not have to be in the same format as the previous appointment and could be a panel based on specialisation. We will keep you up to date with our progress.

Finally with the NT Election over we will keep you up to date of our advocacy issues and report against the positioning paper this as things progress. Click here for the 2020 Election Positioning Paper.

Raquel Nicholls-Skene
Executive Director – Northern Territory