October 13, 2016
Re: Draft Rule: Ordinary Maintenance and Minor Work
Dear Members of the Uniform Construction Code Advisory Board:
It is our understanding that on October 14 the Uniform Construction Code Advisory Board will consider whether to recommend a proposal regarding ordinary maintenance and minor work. It is our further understanding that the intent of the proposed amendments is to eliminate some permit requirements, presumably in effort to reduce red tape. Further, it is our understanding that the draft rule proposes to change the definition of “minor work,” so that projects that require a prior approval be categorizes as minor work.
While the League is a proponent of, when appropriate, reducing red tape and creating administrative efficiencies, it should not be done at the expense of public safety. These codes have been developed through the years, with the significant input of those who must administer them, for public safety purposes. It is not appropriate to dilute these standards. It is therefore, the opinion of the League that the proposal is profoundly bad public policy and we request that the Board does not endorse it.
If it is the opinion of the Board, and the Department of Community Affairs, that in some circumstances fees are excessive then that issue can be addressed surgically through the administrative process. If the Board is of the opinion that approvals take too long in some circumstances, then that can also be dealt with in a surgical manner through regulations.
We strongly disagree with an across-the-board, one-size-fits-all approach, particularly when that such change not only do not advance life-safety issues but may in fact undermine them. The League joins the New Jersey Building Officials and our other affiliate organizations which object to these proposals, and urge that you oppose this proposal.
Very truly yours,
Michael F. Cerra
Assistant Executive Director &
Director of Government Affairs