These changes to increase…

These changes to increase oversight do not support the provincial governments promise of less reporting and less red tape. The charges proposed will increase municipal Building Service Costs by 3.14% (3.62% for Admaston/Bromley) based on 2018 FIRs. And provide the province with $7,716,189 in new revenue. Please see the questions below asked in the discussion paper and our replies for your consideration.

1. How could the current examination design, content and/or delivery be improved? More training opportunities and better resources offered through the OBOA.

2. Are the current training offerings meeting your needs? Yes.

3. Do you see a role for the administrative authority in the delivery of training for building code professionals? No, there is already an Association for this the OBOA which members consist of stakeholders should determine the training needed. An authority is a duplication of what the Association already provides.

4. What factors could contribute to the low take-up of the current internship programs? Lack of knowledge that they exist. We shared a CBO with 2 neighbouring municipalities and one of which took advantage of this program and we also plan to take advantage of it however not all municipalities are aware of this program.

5. What role could an administrative authority play in internship programs? None again this would be duplication as this is provided through the OBOA.

6. Would implementing a provisional licence framework help with municipal recruitment challenges and what should be considered? Not sure. Would need more information to comment on this.

7. Are there other ways to help building code enforcement bodies attract and retain experienced building professionals? Offer free membership to OBOA and mentorship programs through municipalities.

8. Do you think the use of a Prime Consultant, under certain circumstances, would
support a more streamlined building permit application process? No.

9. Do you think the use of Certified Professionals, under certain circumstances, would support a more streamlined building permit application process? Yes the OBOA could have a certification similar to the Association of Municipal Managers Clerks and Treasurers of Ontario AMCTO.

10. If the ministry decides to move forward and allow the use of such professionals,
what do you think needs to be considered in implementing this change? Recognition of the designation and coordinated training through the OBOA

11. If you are a registered building code professional, what are the key issues you face with the current QuARTS system? Once our CBO status was inactive which was incorrect.

12. What registration functionality would you find helpful that is not currently available
in QuARTS? Nothing at this time.

13. As a member of the public, what information would you like to see made publicly
available on the registry to help you make an informed decision on hiring a qualified building code professional? Their designation, current job title, years of experience, list of employers in the last 5 years. The categories and status on their currently are also helpful. List of any infractions on file or penalties received.

14. How many activities or hours of CPD do you feel is reasonable to require of building code professionals? 20 hours per year similar to other designations.

15. What is the right mix of formal and informal CPD activities that building code
professionals should be required to complete (e.g., courses, training, examinations, reading professional/technical journals or documents, volunteering in the sector, attending relevant conferences, etc.)? minimum of 4 hours of courses or training and 20 hours total of all CPD annually.

16. What is a reasonable timeframe for completing CPD requirements to ensure
knowledge is maintained (e.g., annually, at every new Building Code cycle which is usually 5-7 years, other)? 60 hours every 3 years similar to other designations.

17. Are there already mechanisms, materials, or offerings that would give building code professionals options on how they could meet their CPD requirements? Yes OBOA Conference and Training offered annually.

18. What types of compliance measures should be put in place to ensure building
code professionals are meeting the requirements of their registration? Submit a report on all their CPD activities once every 3 years to OBOA for review and recertification.

19. What types of accountability mechanisms do you think might be appropriate if a
body enforcing the building code (i.e., municipality, Conservation Authorities, Boards of Health) is found not to be meeting its responsibilities under the Building Code Act, 1992? Reports to be printed annual like Ombudsman reports and investigations booklet and a copy of the investigation to be filed and review at a public meeting where the infraction was committed.

20. Do you see any challenges with requiring all building code professionals to adhere to a code of conduct? No.

21. What should be considered when increasing the number of available enforcement tools and using an escalating enforcement model? Training and consultation on any new model is crucial.

22. 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? Only for severe infractions that cause significant risk to human life or show blatant disregard or negligence.

23. How could these penalties be set so that they are fair? Further consultation would be needed for this.

24. What types of orders do you think administrative penalties could be used for? Again further consultation would be needed for this.

25. What do you think the province should consider in developing an administrative penalty framework? Further consultation would be required to determine this.

26. Are there enforcement tools that would help principal authorities ensure compliance with technical requirements of the building code? A formal complaint process and notification to the employer organizations.

27. Would it be beneficial for municipalities to have the ability to transfer some or all of their building service delivery to the administrative authority? No. it would cost an additional $7,716,189 in fees according to the 2018 FIRs.

28. If you live in a smaller, rural and/or northern municipality, how would you feel more supported at your municipal building counter? More training opportunities offered by the OBOA.

29. What kind of framework should the province consider for dealing with building code compliance and enforcement in unincorporated areas? Use the OBOA to ensure training is available in these areas and to keep track of any complaints.

30. If you live or work in an unincorporated area, what guidance, resources and/or
support do you need for your building projects? N/A

31. Would you support the issuance of technical bulletins and/or code interpretations? Yes this would be helpful and result in less calls to the Province for Interpretation which is the majority of calls made by our CBO.

32. If additional resources and guides to help with code interpretation were created,
what types of resources (e.g., type of content, format, etc.) would be most useful? Similar to the Municipal Drainage Act Guide or Fence Viewers Act. Both of these guides are very helpful.

33. Would the addition of more visual guidance materials for specific building code
issues be helpful? Yes.

34. As a member of the public, what resources and tools would you need to assist
you with understanding code requirements for your small or personal construction projects (e.g., minor renovations, decks, sheds etc.)? A Guide similar to the ones mentioned above would assist the public in understanding.

35. If you would use an electronic version of the Code, on what type of electronic device would you most frequently view/use it on? (e.g., laptop/desktop, mobile device) Laptop.

36. In addition to digital versions of the Ontario Building Code Compendium, what other digital guides, resources or tools would you find most useful? Any guides, training materials, conference materials, new interpretations or application cases.
37. Does your organization collect building sector data? Yes.

38. Do you have any policies in place for data collection, management, and/or transparency? Yes

39. How could the potential increase in municipal reporting burden be mitigated? If the province encourage the OBOA to take on the training, recertification and complaints then an authority would not be needed and as the Association is already in place the cost would be financially sustainable.

40. Do you think it would be beneficial if the administrative authority conducted research on behalf of the sector? No I think that is the purpose of the OBOA.

41. Is the proposed funding model a reasonable approach to delivering improved
Services to the sector? No. The cost will increase municipal building expenses by 3.14% or $7,716,189 across the province plus administration costs to collect and remit and report on these funds.

42. Are there impacts in implementing such a fee model that the government should
consider? Such see above. This is a service our CBO uses on average once per year. This would result in a cost of $1,000.00 per call for the Township of Admaston/Bromley.