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    Why multi-storey apartments should be designed by competent building designers not just architects

    Nathan Johnson

    Update: This article has since been responded to by the Australian Institute of Architects National President, David Karotkin. Click here to read:

    Restrictions on who can design multi-storey residential developments in NSW are detrimentally predicated on an architect qualification rather than relevant design competency. This is the opinion of many building designers in NSW, and a few architects as well.  

    NSW’s State Environment Planning Policy no. 65 (SEPP 65) stipulates that an architect must be responsible for the design of multi-storey residential complex, a clause that has architect Ian Bassett, Policy & Professional Development Director of Building Designers Australia (BDA), uneasy.  

    Bassett would agree with most that the SEPP65 and aligned Residential Flat Design Code have done great things for the quality of NSW apartment design and construction, to the point the state is widely lauded as the nation’s leading such system. However he’d rather see the restrictions based on a competency test rather than a university degree.

    We caught up with Bassett to discuss the SEPP65 policy and asked him to pitch a different model that would focus on a competency test rather than an architect qualification.

    What are the restrictions to building designers on SEPP65 buildings and why do they exist?

    SEPP 65 restricts the design of multi-storey residential developments; specifically, three or more storeys and four or more unit developments, to registered architects.

    This was introduced by Premier Bob Carr in 2002 to combat the proliferation of three storey walk up flat developments – usually with ground level garages facing the street and two levels of units above – which he considered, quite rightly, rather ugly.

    Ironically, the examples he produced to support his argument were mainly designed by architects.

    The main players in the introduction of SEPP 65 were the RAIA and State Planning bureaucrats, top heavy with architects. Non-architect building designers were often referred to as ‘backroomdrafties’ with no qualifications and/or experience.


    In 2000 Premier Bob Carr endorsed the design work of 'The Belmont' development in Sutherland, as an exemplar of desirable SEPP 65 design outcome, despite it having been designed by building designer Cameron Jones. 

    Why only architects?

    It was considered by those in power at the time that only architects, with their university training and undoubted design skills were competent enough to design multi-storey residential buildings that were functional and had architectural merit.

    The fact that many architects, especially those with only a few years’ experience, whom were themselves too inexperienced to design SEPP 65 type buildings, was immaterial to the drive to limit this type of design to architects only.

    Why shouldn’t this be the case?

    The BDA considered this to be a restraint of trade and considering that non-architect building designers prepare 97 per cent of residential designs, including 90 per cent of multi residential designs (Source: RAIA and State Planning), it was only the tip of the iceberg to limit other types of building design to architects only, thus basically putting building designers out of business.
    The above statistics may upset our architect colleagues but they are real world numbers that demonstrate clearly that the marketplace has already decided the type of project that architects will be engaged on and the type of projects that can be managed by building designers.

    We can conclude that in NSW, architects are more likely to be engaged to do the ‘up market’ residential projects and high rise residential developments while building designers do the bulk of built work stock.

    What alternative would the BDA want to see?


    All of the apartments for Sydney's Barangaroo precinct were designed by architects. Photo: Jacky Ghossein

    NSW, unlike Queensland, Victoria and Tasmania, does not have any formal registration for building designers and the BDA has been lobbying successive NSW governments for many years to introduce mandatory registration that includes professional indemnity insurance and Continuing Professional Development for building designers to practice in NSW. 

    The BDA recognises that a formal registration system of building designers in NSW is paramount to providing consumer protection. This would weed out those aforementioned ’backroom drafties’ and also provide a way of ensuring that only competent building designers are allowed to practice in NSW that would include a three tiered level of registration, similar to that in place in Queensland and Tasmania, so only those building designers deemed competent to do SEPP 65 work would be licensed to do so.


    Built in 2003, 'EDO' by Stanisic Architects is considered a great example of SEPP65 design. Image: Patrick Bingham-Hall.

    How can building designers prove their competency in order to build SEPP65 buildings and is it difficult?

    The BDA has been instrumental, in partnership with Construction and Property Services Industry Skills Council (CPSISC)  in developing a suite of new national training courses that have now be taken up by the TAFE colleges and other training organisations that is based on competency standards that are peculiar to the building design profession.

    The BDA has an internal accreditation program that is available to both BDA members and non-members to assess their competence based on a set of standards that are reflective of ‘best practice’ within the industry. The BDA also has a member category of Chartered Member that requires members to be accredited, have PI insurance and maintain CPD over a range of criteria.

    The BDA enjoys a partnership with Sydney TAFE that has recently allowed 100+ BDA members to use that accreditation to be assessed for RPL (recognition of Prior Learning) competency that allowed Sydney TAFE to issue these members with a Diploma of Building Design.

    The next step is to raise the bar, so to speak, by extending that process to the Graduate Certificate and Diploma of Building Design. This caters for those building designers currently practicing but is soon to be extended to school leavers who wish to become building designers.

    The Graduate Diploma of Building design is equivalent to a post graduate degree at university.

    As previously mentioned, NSW has no formal registration of building designers and the BDA would like to see this introduced as a matter of priority. In the other States mentioned there are several different methods of registration but he BDA prefers the Queensland/Tasmanian model that licenses building designers to work on projects to a level that is determined by their level competence – not just the fact that they may have a particular qualification.

    This model has three levels of licence.

    • Low Rise  

    Single and two storey residential developments and multi residential up to three units, town houses and villas) All Class 1 & 10 buildings.

    • Medium Rise

    Class 1 and class 10 buildings

    Class 2 to 9 buildings with a maximum rise in storeys of three storeys and a maximum floor area of 2,000sqm.

    Buildings with a maximum rise in storeys of 4 storeys in the case of a building that comprises only a single storey of class 7a car park located at the ground floor level or basement level and with 3 storeys of class 2 above and with a maximum floor area of 2000 sm.

    Excludes Type A Construction as defined in the BCA.

    • Unlimited

    The preparation of building design plans and specifications for all Classes of buildings and Types of Construction under the BCA

    As these registration levels are based on competence one can presume that the majority of building designers would fall into the Low and Medium rise categories which clearly protects the architect’s natural market of large commercial, institutional and residential projects.

    A limited number of building designers would be assessed with the skills and competence to undertake SEPP 65 type projects and the BDA would argue that if they can demonstrate the necessary competency standards then they should be free pursue this type of work. Likewise, we would also argue that architects should also demonstrate their competency to undertake SEPP 65 type projects and to support this argument the recent SEPP 65 Review conducted by State Planning found that many architects were found wanting in providing acceptable SEPP 65 documentation for this type of project, thus the rewriting of the Residential Flat Design Code.

    How can building designers become ‘architects’? Is it possible?

    In NSW building designers have several paths to become registered as an architect that caters for those who do not have the appropriate university degree.

    • National Program of Assessment (NPrA)

    This sets a design brief challenge that applicants must complete within a 6 month timeframe and is based on demonstrating competence in completing and documenting the design brief criteria. To be accepted into the program one has to have had a certain amount of experience working in an architect’s office. If a candidate is successful they then sit for the Architectural Practice Exam. This program has proved to be extraordinarily difficult for candidates to satisfy and the success rate is very low.

    • Built work Program of Assessment (BWPrA)

    This program is designed for those who have had at least 10 years construction experience and have authored or directed the design of a built project in architecture.        

    Following acceptance into the program and successful completion of the assessment process, the candidate sits for the Architectural Practice Exam. Over the past 10 years, about 45 building designers have been successful using this pathway.

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