Des Lynch , of  Greenhills NSW, made the following submission on the project:

Proposed criteria for category A5 port certifiers

I am in agreement with the AIBS submission.
I can not see how introducing the engineers to role of certifier for these structures and building would present a better outcome then the system currently administered and certified by Accredited Certifiers. Structures and facilities of the ports require the expertise on a high level experience certifiers that can use the provision of alternative solution under the BCA to access the performance provision for the safe use of the structures, example being a silo facility for ship or truck loading.
Introducing engineers to be the administers of certification is a role that engineers are not trained or experienced in nor would they want to be involved in State Legislation. Best the Dept of Planning consider the A1 Accredited Certifiers be the certifying authorities for these developments and the engineers who are experienced in port structures certify that the structures are structurally adequate and provide the design certification, construction inspections to determine adequate to design intent, as we as an industry do every day for these structures. Class 10b and Class 8 structures have been approved over the years this ways by certifiers, just legislate the complying development ability and condition that only to be processed and certified by level A1s.