BC(A)R SI.9 Submission Series No 8: Stakeholders ACEI, SCSI & RIAI


by BRegs Blog

The following submissions were made by key industry stakeholders Engineers Ireland (EI), Society of Chartered Surveyors in Ireland (SCSI) and the Royal Institute of the Architects of Ireland (RIAI) as part of the current annual review of BC(A)R SI.9 being conducted by Ministers Coffey, Kelly and the Department of the Environment.

These three organisations, along with the Construction Industry Federation (CIF) were involved with the Department of the Environment in the formation of BC(A)R SI.9.

In brief, all three are against the immediate inclusion of other professions, notably Architectural Technologists, all are opposed to the Minister’s policy to reduce fees and all strongly reject any exemption from provisions of SI.9 for once-off housing. These are just three of the 170 submissions made to the DECLG consultation but they send a strong message to the Minister and his department that they do not support his proposed changes.

The issue of cost seems to the the biggest bone of contention:  below is the fee calculation included by the RIAI for a typical house (€7,997 including VAT) as  opposed to the Department of the Environment (DECLG) calculated cost of €3,800. The RIAI acknowledges that hourly charge rates used are unrealistically low, and suggests a “living wage” rate would push this fee up to more than double that suggested by the Department officials. The RIAI rebuttal reinforces recent calls by Engineers Ireland to engineers to ‘hold firm’ on current fee levels for Building Control services. It may be a step too far for a Minister faced with a housing crisis to accept this house inspection regime that will cost over €80 million p.a. in extra professional fees.

The Chartered Institute of Architectural Technologists (CIAT), unlike the three main stakeholders, were the only professional group to take issue with the charge out rate suggested by the DECLG. A €65/hour charge out rates equates to an annual salary in the region of €52,000 which is comparable to the pay of a clerk of works in the public sector (assuming charge-out rate TX2 with no profit for a firm).

All three bodies are recommending that the Department introduce Latent Defects Insurance for purchasers of residential properties,  to give immediate redress to consumers for defective buildings. However LDI policies with subrogation clauses, will not reduce the liability of professionals as the LDI claims will pass directly to their Professional Indemnity Insurer. Professional certifiers can be pursued directly by Latent Defects Insurance companies for the full claim under this scenario.

EI submission: EI Submission to DECLG 2015

SCSI submission: SCSI Submission to DECLG 2015

RIAI submissions: RIAI SUBMISSION 1 With Appendix 15 MAY 2015

RIAI Submission Regard Information Paper 2, Option B 15.05.15

RIAI Fee scale (typical house):

RIAI Fee calculation draft [Converted]

Other posts in this series:

BC(A)R SI.9 Submission Series No 1: ‘Self-Build issues’ | IAOSB

BC(A)R SI.9 Submission Series No 2: ‘12 Point Plan to fix S.I.9’ | UCD

BC(A)R SI.9 Submission Series No 3: The Legal Environment and Consumer Protection | Deirdre Ní Fhloinn

BC(A)R SI.9 Submission Series No 4: Proposal for a Better System

BC(A)R SI.9 Submission Series No 5 | Architectural Technologists: CIAT

BC(A)R SI.9 Submission Series No 6 | Practically Trained Architects: AAOI & GIAI

BC(A)R SI.9 Submission Series No 7 | Architect’s issues: Eoin O Cofaigh FRIAI

Other posts of interest:


Minister Kelly warns Engineers to expect further changes | EI Conference

DEADLINE TODAY | make your submission to the review of Building Control

ALERT: Ministers Kelly & Coffey Commence Review of Building Control Regulations | BRegsForum

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