Thank you for the…

Thank you for the opportunity to comment on transforming and modernizing the delivery of Ontario’s building code services. I am an architect in the Province of Ontario. The following comments are based on my experience and personal opinion.

The following comments follow the numbering system in the discussion guide.

1.3 Recruiting Experienced Building Code Professionals
A provisional license framework is a good idea.

1.4 Using Coordinating Professionals

Yes, the use of a Prime Consultant, under certain circumstances, would support a more streamlined building permit application process.

The use of Certified Professionals would be problematic for the architecture profession because it would create a complex two-tiered system in a discipline that already adheres to strict and demanding licensing requirements.

In the words of the OAA, this will entail significant changes to the way architects work, adding red tape, liability and unnecessary duplication to the building approval process.

There are many other ways to achieve a streamlined building permit application process, that could be explored. For example, can faster approval times be granted if building permit applications are complete and 95% or more in compliance? The incentive of receiving approvals sooner could be linked to the quality of the application.

As another example, an organization such as Code for Canada could explore the potential role of artificial intelligence apps to check compliance on routine aspects of code compliance of applications, based on electronic documents submitted to the specifications of the application. There could be an incentive of faster approval if the applicant submits documents that are compatible with this model. The use of automation itself in reviewing certain components of applications could speed approval times. As the construction industry is already broadly using digital tools, it would be reasonable to explore such solutions. Such automated reviews would not completely replace reviews by officials, but may be reasonable for speeding up certain routine components of application reviews.

2.2 Continuing Professional Development

I do not think that continuing professional development would be effective, because it creates more red tape, and it would be difficult for any program to address the variety of scales of construction in municipalities of different sizes and locations, without being overly complex to administer.

For example, training might be provided on one aspect of the code, whereas the need might arise to be knowledgeable on another area of the code that year. Having resources and technical advice available as needed would be more animble and effective.

Building officials may already choose to take part in certification programs. That is enough. Promotion of the voluntary system could be more effective and less costly to administer than required continuing professional development.

2.3 Registration Compliance and Enforcement

1. What types of compliance measures should be put in place to ensure building code professionals are meeting the requirements of their registration?
Instead of self-registering, the registration could be completed by the administrative authority, similar to how drivers do not self-register their drivers' licenses.

5a. Under what circumstances do you think it would be appropriate for financial penalties to be used as a means of encouraging compliance with registration
requirements?
Administrative financial penalties are appropriate as a means to encourage compliance, especially for annual renewals.

3.1 Enhanced Municipal Enforcement
Administrative penalties are an excellent solution. They can be used to enforce compliance on stop work orders and other non-compliance that poses a significant risk to public safety.

Administrative penalties could also be used to enforce higher quality building permit applications, e.g., for successive incomplete applications or other applications that are clearly lacking.

3.3 Unincorporated Areas
Although I do not live in an unincorporated area, I support the suggestion of a risk-based approach with a focus on compliance for large, public assembly buildings.

4.1 Promoting a Consistent Application of Code Requirements
The issuance of technical bulletins and/or code interpretations would be useful, provided they are widely available and searchable.

I don't think a separate class of material or information should be provided to the public, apart from regular communications about code updates of interest.

4.2 Digital Service Transformation
In addition to a digital OBC, I would find wiki pages that crowd source answers to technical questions, if the wiki were moderated by a reputable official, or if it were peer reviewed.

4.3 Building Sector Data and Research
Building sector data should be collected at source (i.e., an app would auto-collect the data and auto-send it ), much like Google is always collecting data from its customers, so that there is no reporting burden for municipalities.

5. The proposed funding model is reasonable.