Hunter PCA Pty Ltd, HAMILTON NSW, made the following submission on the project:

Proposed criteria for category A5 port certifiers

1. The Accreditation Criteria appear very restrictive and depart significantly from that required for other levels of accreditation. To require the certifier to hold such specialised engineering qualifications will, in my opinion, result in a very small pool of accredited persons for each of the individual types of port infrastructure nominated.

2. In some cases there may be no accredited persons available to certify port infrastructure that is unclassifiable under the BCA. In such circumstances only the council could consider a CDC or CC for the port infrastructure. The town planner or building surveyor working for the local council who will be called upon to process such applications is very unlikely to hold the specialty engineering qualifications proposed for A5 port certifiers.

3. The SEPP (Three Ports) 2013 already requires engineering certification prior to the issue of a CDC and/or on completion of work for most of the nominated infrastructure. Therefore it appears unnecessary for the certifier to also have specialty engineering qualifications. Rather, the skill set of the existing Accredited Certifier - Building Surveying Grade 1 would, in my opinion, be more appropriate.

4. Existing Accredited certifiers already are able to issue CDCs and CCs for buildings and structures that are classifiable under the BCA. It would, in my opinion, be a simple matter to amend the authorities conferred for the Accredited Certifier - Building Surveying Grade 1 to include the issue of CDCs, CCs, OCs, and to carry out PCA functions and to conduct inspections in relation to port infrastructure which is deemed 'not classifiable under the BCA'. Similar amendment was made to include CDCs for demolition which were not originally included in the authorities conferred for A1 to A3 accredited certifiers.

5. If the BPB consider port certifiers require knowledge and skills over and above that required for the current A1 category of accreditation then this could be addressed via additional training. This could include courses to develop understanding of the SEPP (Three Ports) 2013, SEPP 33, identifying designated development, contaminated land issues, fire safety studies, hazops, etc, that apply to port infrastructure. Perhaps only once the relevant course / courses had been completed would the individual's accreditation statement be amended to include 'Port Infrastructure' with their existing A1 accreditation, or they could receive the additional A5 category of accreditation.

Thank you for the opportunity to comment.