A state Senate bill introduced 1/21/11 proposes to expedite permit processing by allowing an Architect's certification to substitute for state and city agency review.2011 Legislature, Senate Bill 114.
A cursory review of the proposed Bill in its present form, suggests that
- the actual scope of this legislation would affect mostly larger projects since the current language states, "An applicant for two or more state permits may apply...."
- a joint agreement may be created between gov't agencies (fed/state/city) for the purpose of "specifying the regulatory and review responsibilities of each government agency" ie. are all agencies going to allow an Architect to substitute for their approvals?
- there is no mandate for any gov't agency: fed, state or city to participate.
What is the intent of this legislation? If the permit regulatory system is too cumbersome, perhaps it would be better to streamline or revise the regulatory system directly, rather than create another set of rules to regulate how to circumvent it.
The safety of the general public is one of the key reasons why we have a regulatory system. How is the public interest served by allowing a single design professional to take the place of certain (and potentially ALL) government agencies involved in the permitting process? If an Architect can stand-in as proxy for agency review for large projects, then why not want extend his authority to smaller projects as well? This would seem to have a larger impact on improving overall efficiency. Is the bill suggesting that certain gov't agencies are no longer needed. If a single design professional in the private sector is able to substitute for the services they provide, perhaps the bill suggests that it is not as critical to maintain certain agencies' fiscal budgets and staffing?
Also, as it currently reads, the bill may pave the way for greater abuses if only a limited number of large projects qualify for this exemption and the terms under which a project may be approved is not clear. Furthermore, would a single Architectural entity have the financial resources to financially withstand the rigors of a legal challenge(s) and potential monetary penalties that may be levied against his work?
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