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RE: South Australia practices

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In South Australia development approval comprises of two parts:

1) Provisional Development Plan consent
2) Provisional building Rules consent

Only the local councils (AHJ) can grant development approval, and only once
the two consents have been granted. The assessment of building rules is
usually by building surveyors, a few are architects and a few are engineers,
most are not.

As I understand it, in the past people could simply go to local council and
ask what was required and they would be told what to do. Not sure how far
back that was, but the current development act was introduced in 1993, and I
believe the prior act required submission of structural calculations. When
it was introduced private certifiers were also introduced, and many councils
now send applications out to private certifiers for assessment: building
departments have shrunk in size. Private certifiers are registered building
surveyors, and I believe they have to also be either architects or
engineers. Private certifiers can only grant approval for building rules,
and building permit is not issued until get full development approval.

The building surveyor is not permitted to recommend design-solutions, they
have to remain independent. I believe at some point in the past a few
councils were sued because of faulty footings on reactive clay soils:
council is always there, other parties aren't.

What it means is if something is undersized the building surveyor cannot say
what size will be approved: they can only reiterate the requirements of the
building rules.

Also the development regulations require that the structural provisions of
the building code of Australia (BCA) are assessed by an independent
technical expert. At present however the definition of such is simply a
person with a 4 year B.Eng in Civil Engineering and a few years of
experience: it doesn't require registration on the national professional
engineers register (NPER). If the building surveyor is an engineer then they
can assess the structural provisions. Most building surveyors are not
engineers so most councils send development applications out to private
consulting engineers for structural assessment. These consultants usually
request the submission of engineering calculations. That is not really the
intent of the act.

A building surveyor is permitted to accept in good faith a certificate from
an independent technical expert, and is also required to seek such
certificates if aspects of a development proposal are beyond their scope of

So sometimes instead of asking for engineering calculations they will simply
ask for a certificate of an independent technical expert. If an engineer
specialises in a particular area of practice then they can simply look at
something and say it is similar to a 100 other projects, and certify it. But
if the proposal is deficient they cannot advise or specify the requirements
to make it acceptable. 

In which case they remove the reference to independent technical expert and
issue a certificate of structural adequacy with conditions. If it is simple
the engineer representing the AHJ will accept that without calculations, if
not simple then may request the calculations or other evidence to support.
{On the other hand the AHJ's request for a certificate makes it sound like a
simple exercise to the owner of the building.}

The building code of Australia (BCA) requires evidence-of-suitability, but
indicates that a certificate from a suitably qualified person is adequate
evidence. (NPER is called up as one option of suitably qualified, but not

To me it seems that in practice there are double standards. The building
surveyors do a lot of the assessment themselves without calculations or
other documentary evidence: access/egress requirements, fire rated
construction, timber framing and more. Not all of this is simple
prescriptive comparative checks, it requires some effort and justification.
They do not ask designers to submit calculations for such things: the
building surveyor does what ever is required.

But structural even if building surveyor is an engineer and able to make the
assessment, they still want some calculations submitted.

The issue I have with that is: in many cases it is a waste of time and
paper, and waste of space to store the paper, especially for those
situations where the calculations are just tedious repetition to satisfy a
paper trail. Further more the requirement is technical check: does the
proposal comply with the code. According to some reports, often only an
arithmetical check is carried out: relevance and deficiencies in the
calculations not understood or recognised.

If the technical experts were selected correctly, then they would have
appropriate tools to review the proposals in the shortest time frame
possible. Given such tools it is a waste of time to decipher hand written
scribble, when can check the specification directly.

The intent of the 1993 development act was to speed up approval. My view is
that the designer only needs to submit their calculations, when the checker
considers there is a non-compliance, and the designer wants to argue the
point. Further the councils and other AHJ should select independent
technical experts appropriate to the project, rather than have an on going
contract with a local consultant.

The development court has apparently ruled in various cases: expertise to
the extent necessary to make an assessment, it doesn't require
specialisation. That may be fine on the AHJ's side, but the industry is
always complaining about how long it takes to get approval.

My view is that it is the industries own fault. The builders and building
designers could simply choose a private certifier with the appropriate
specialisation, there is no need to go through council for building rules,
when seeking development approval they simply advise council who the private
certifier is. Once appointed they cannot change the certifier.

More importantly they could get engineering done before seeking development
approval, that way they would avoid the delay when a request for engineering
is issued. If the work is of a simple nature then the engineer can act as
independent technical expert and simply certify the structure. If the work
is of a more complex nature, then the engineer acts as designer. To save
time the design engineer can then seek another engineer to act as
independent technical expert. There then should be two sets of calculations,
but only the independent technical expert's certificate needs to be
submitted for approval: the AHJ accepts that on good faith. The benefit is
that the two independent engineers can be selected on basis of experience
and specialisation. Calculations for the project can be minimised whilst a
wealth of calculations are produced for an industry.

The requirement for independence doesn't allow a senior engineer in the same
company to act as technical expert; they have to find an external
consultant. But there are exceptions for very specialised areas, but even
then may still impose external assessment to the extent possible.

Older engineers close to retirement can benefit. For example permissible
stress codes are now obsolete, we only have limit state design. Building
surveyors will reject calculations in permissible stress format, but the
design engineer can get an independent technical expert to certify the
design after checking to the limit states codes. If non-compliant the
design-engineer can go away find design-solution using permissible stress,
then get it checked for compliance with limit state.

Whilst people complain about slowness of getting approval, it is the way
most people operate within the system which is inefficient not entirely the
system itself.

Though licensing/registration of the engineers acting as independent
technical experts would seem a beneficial addition: to improve consistency
in what gets approved. 

Well that's not exactly brief. Hope it helps anyway.

Some useful links:

Planning Department:

The advisory notices:

The development Act:

The development Regulations:

Roof Truss Issues:

Faulty Trusses:

Simplified Wind Speed Maps:

National Professional Engineers Register (NPER):

Conrad Harrison
B.Tech (mfg & mech), MIIE, gradTIEAust
South Australia

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