Part 1: Building Warrant Fees
1.1. Do you agree building warrant fees should be increased to strengthen the building standards system in Scotland?
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Strongly agree
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Agree
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Neither agree nor disagree
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Disagree
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Strongly disagree
Please provide your reasoning for your answer
Strongly agree, but on the proviso that the money does lead to a strengthened system. Currently it is difficult to equate the fee level to the service provided by some Building Control departments.
Provided correctly allocated, increased fees would assist with increasing resource and skillset but also consistency and understanding of Building Standards throughout Scotland. However an understanding of the proposed fee levels would need to be provided and agreed prior to introduction and what will be offered for this additional cost.
Provided correctly allocated, increased fees would assist with increasing resource and skillset but also consistency and understanding of Building Standards throughout Scotland. However an understanding of the proposed fee levels would need to be provided and agreed prior to introduction and what will be offered for this additional cost.
1.2. Do you agree that a proportion of the building warrant fee should be used to support a central Building Standards Hub?
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Strongly agree
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Agree
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Neither agree nor disagree
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Disagree
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Strongly disagree
Please provide your reasoning for your answer
The current situation where interpretation of the Building Standards can vary widely between local authorities is ridiculous and it is inappropriate for LABSS to be on only a voluntary basis. It is vital to have a centralised body to provide a basis for a consistent approach. It would seem logical for this to be linked to the Building Standards Division who write the standards in the first place and are surely best placed to offer guidance on their interpretation.
However we would query the estimated £1 million per annum initial costs. If the Hub was created as a sub-division of the Building Standards Division, could it be more economically run?
However we would query the estimated £1 million per annum initial costs. If the Hub was created as a sub-division of the Building Standards Division, could it be more economically run?
1.3. Do you support the introduction of enhanced verification and certification auditing, monitoring and reporting of fee investment to support the implementation of the strengthened building standards system over the next 3 years?
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Yes
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Not sure
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No
Please provide your reasoning for your answer
This would assist with transparency of the additional fee expenditure is being targeted providing the industry with an understanding of where these additional fees are being spent.
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Yes
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Not sure
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No
Please provide your reasoning for your answer
It would be good to see this being opened to public scrutiny with developers given an opportunity to feedback and comment on performance and success or failure, and also identify where areas are not working as they should be and what could be done to improve.
Part 2: High Risk Buildings (HRBs)
2.1. Do you support the introduction of an enhanced fee for High Risk Building warrant applications?
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Strongly support
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Support
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Neither
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Do not support
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Strongly do not support
Please provide your reasoning for your answer
Yes, it makes sense to relate fees to the project complexity rather than just on construction value - appreciate that this would be hard to define so this makes sense as a step in the right direction. Perhaps consideration could also be given to a fee reduction for simple projects, ie larger scale developments with a lot of repeated house types?
Part 3: Building Standards Enforcement
3.1. Should a portion of building warrant fees be used to fund the local authority compliance enforcement role but only as it relates to the building warrant process?
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Yes
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No
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Unsure
Please provide your reasoning for your answer
This would be on the assumption that the ‘compliance enforcement roles’ intention was to work in co-ordination and support of developers/contractors rather than work against them. The Building Standards are becoming increasingly complex and difficult to follow and more assistance is required within the industry, particularly in relation to sustainability, fire etc.
However, we have issues where Building Control site inspectors take a different opinion/interpretation to the Building Control Officer who granted the warrant leading to accusations of non-compliance even when we are building to the approved warrant information. We would not want to see our fees going to more of this!
However, we have issues where Building Control site inspectors take a different opinion/interpretation to the Building Control Officer who granted the warrant leading to accusations of non-compliance even when we are building to the approved warrant information. We would not want to see our fees going to more of this!
3.2. Should a portion of building warrant fees be used to fund the local authority building standards wider statutory role covering both building warrant compliance enforcement and dangerous and defective buildings?
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Yes
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No
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Unsure
Please provide your reasoning for your answer
We do not think it is appropriate for enforcement on dangerous and defective buildings to be funded from Building Warrant fees. This should be funded separately by the Scottish Government.
Part 4: Devolved Building Warrant Fees
4.1. Should building warrant fees be set at national or local level?
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National level
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Local level
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Unsure
Please provide your reasoning for your answer.
We strongly believe that fees should be set at a national level. The whole process needs to be controlled more at a national level to ensure a more consistent approach and service. There is no reason for a warrant to cost more in one local authority than another, it is only fair and reasonable for this to be consistent across the country.
Part 5: Impact Assessments
5.1. Are there any proposals in this consultation which you consider impact or have implications on people with protected characteristics?
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Yes
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No
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Unsure
5.2. Do you think that any of the proposals in this consultation have any financial, regulatory or resource implications for you and/or your business (if applicable)?
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Yes
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No
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Unsure
Please provide any comments in the box below. If selecting yes, please specify which of the proposals you refer to and why you believe financial, regulatory or resource implications will be impacted.
Increased fees will have a direct financial impact on our business in costing us more, but this would be more than offset if we will receive a more consistent and efficient service as a result. We waste a lot of resource having to navigate between the different interpretations currently taken by different authorities.
5.3. Do you think that any of the proposals in this consultation have any impact or implications on island communities?
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Yes
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No
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Unsure
Please provide any comments in the box below. If selecting yes, please specify which of the proposals you refer to and why.
The potential for fees to be set at a local level could impact on island communities.
5.4. Do you think that any of the proposals in this consultation have any impact on the inequalities of outcome caused by socio-economic disadvantage?
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Yes
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No
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Unsure
About you
Are you responding as an individual or an organisation?
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Individual
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Organisation
What is your organisation?
Organisation
Cruden Homes