Charles Slack-Smith , of  Sydney NSW, made the following submission on the project:

Proposed criteria for category A5 port certifiers

I do not see why this has to be NPER Engineers only, the complexity of the process is in the CDC process under the EPA Regulation, and SEPP, not the technical details of the structure / element which can be resolved by a requirement for NPER Designers or If there is a concern with the design elements, then make it a requirement of the A5 Accreditation that the certifier be provided with a Part 4A Compliance Certificate for the engineering elements to form part of the CDC

I would envisage that Grade A1 certifiers with appropriate experience would be much better suited to undertake this role, as learning about the CDC process is complex, and not something that a non-practising person can pick up, engineers are good at design and engineering, certifiers are the experts at certification, and this is how it should be undertaken for the issue of CDC and OC's