bc safety authority fee consultation 2018-2020 verbatim ......bc safety authority fee consultation...

BC Safety Authority fee consultation 2018-2020 p.1 of 46 Verbatim feedback

BC Safety Authority Fee Consultation 2018-2020 Verbatim feedback Includes comments received up to August 8, 2017 Comments have been moderated as per BC Safety Authority’s Content Submission Guidelines.

Item # comments received

General fee increase 100

Compliance & enforcement fees 54

Commercial gas installation fees 12

Certificate renewal for power engineers fees 25

Internationally trained worker portfolio assessment fees 21

Additional feedback 31

https://www.safetyauthority.ca/consult/content-submission-guidelines


COMMENTS ON THE PROPOSED GENERAL FEE INCREASE

Company Reasonability / Support

Comments

Service provider in Boilers, Pressure Vessels, and Refrigeration, Electrical, Gas

Unreasonable / Strongly opposed

$162 an hour seems excessive for the value. The permit fees are in excess of the safety value BCSA brings How do they justify $180 per gas appliance when there are 10 in a building. Why do they charge $25 for a rooftop unit that they don't inspect, it’s a money grab and should be exempt. Many of the things they now charge fees for seem to be a money grab and not a safety issue. Why charge $43 or $88 per year for small refrigeration pressure vessels that they never inspect, Has there been an injury to justify this? If so why aren't they inspecting. BCSA is building a BC Ferries type bureaucracy and has lost sight of - is there value in what they do, or are they just dotting the I's and crossing the T's of the regulation and fooling themselves into thinking they are doing something useful

Service provider in Boilers, Pressure Vessels, and Refrigeration, Gas


OK so the proposed annual 2% fee increase will not stop licenced and unlicenced companies and individuals from performing work without obtaining permits - only cause more unpermited work. If the BC Safety Authority needs extra funds - maybe they should be going after the unlicenced unqualified - companies that do not get permits - do shoddy work - give the industry a bad name. I believe that anyone can get a gas contractor’s licence - maybe gas contractors licences should only be available to licenced gas fitters - this may help to minimize un permitted work. If every company obtained a permit for permited work - BC Safety Authority would not have to raise prices and every contractor would be working on the same playing field.

Fraser Valley Refrigeration

Somewhat unreasonable / Opposed

BCSA is becoming too large of a Bureaucracy. Who decides what provides value for the BC Public on both safety and cost

Service provider in electrical


I don't know if you've noticed but we've just stepped out of a huge recession. Maybe it's time the BC Safety Authority increase fees in good times and lower them in tough times. But your history has never shown that consideration.

AECO Design & Engineering

Somewhat reasonable / Supportive

It is a minimal increase for the service


Pfitztech Electrical Service


Can someone explain to me why increases are being made every year. This is basically making it more and more expensive for customers. Since there is no repercussion for electricians to do work on homes via home owners permit you are basically putting licensed electrical contractors out of work. Homeowners will just get a home owners permit and hire some apprentice or electrician to do the work for dirt cheap. There needs to be a substantial increase in a homeowners permit so they will think twice before cutting corners. Like Ontario, there needs to be something along the lines of certification stickers to prove that work has been done by a certified contractor. We are losing a lot of work to unlicensed electricians and they are not caught or fined. Fix this problem and you won’t need to keep raising rates because more people will be forced to get permits Homeowners will just hire unlicensed electricians to do the work for cheaper. There is basically nothing preventing them from doing this. There needs to be some collaboration between the safety authority, the banks and the insurance companies to prevent un-authorized work on homes and commercial buildings. Solve this problem and you won't need to raise the rates.

Dancor Electric Ltd Unreasonable / Strongly opposed

As per usual, we now need to explain to our customers that they again will be digging into their pockets to come up with more funds. As an organization, you have removed the local offices, removed a local focal point for clients to go. This has reduced costs. The inspectors now work out of their vehicles, you have gone more computerized with less people oriented hands on. So Sorry but no, you cannot justify another rate increase. Your costs have not gone up, and you are a corporate company, try to stop being a for profit. Government needs to see things for what they are, and stop passing this down to us. I am totally against this increase.

Marker Electric Somewhat unreasonable / Opposed

Not all areas and people see growth at the same pace. I deal with many rural, retired and fixed income people. For these people, doing smaller jobs, the permitting cost is already a significant portion of the final bill. Higher prices may result in needed fixes going undone, or being done by unlicensed individuals.



Wages for the working man have frozen for years, so should permitting.


Institution/equipment owner

Sent via email Being honest, I have absolutely no idea what I pay your fees for. I don't see you. You don't do anything for me and I don't have a clue what value you provide. You are just a permit I have to pay to do business. If you want to increase fees. you should start by explaining to all of us, who pay your fees, what value you specifically provide to us. In the end you will increase your fees and I and everyone else will pay it, because we have no choice, but please explain to us all...... For What?.....Don't tell me what [the utility company] does in terms of inspections etc. because you charge them for that and they pass that on to me......What do you do????? How do you make me and or my job site safer???? I think your organizations has lost sight of your original goals, and are now nothing but a profit center, at least that is how it seems, so you should start explaining your value before increasing your fees to increase your profits to pay your CEO and execs a higher wage Love the $150 dollar soon to be $153 dollar permit hanging on my wall

Service provider in elevating devices


It's completely necessary to move you offices to a Vancouver address driving up costs for everybody.

Complete Circuit Electric

Somewhat reasonable / Neutral

The category I am most interested in commenting on is the job cost below $250 permit.... $52 per $250 represents the equivalent of a 21% fee. I don't believe all contractors are pulling permits for this fee level - it is too high & it takes time to pull permits. There should be something in place like a Tag system where a contractor can pull a booklet of tags at $20 per permit .... then the contractor simply submits a very quick - Tag #cccc used at address *** Street. Compliance, safety, and reasonable administration. All other levels of permit fees work fine.



As an electrical contractor who rarely, if ever sees an electrical inspector on a job I don't know what I should be paying more fees for. Homeowner permit costs should go up drastically to offset any costs the BCSA needs to cover as I see that as the only aspect of my trade that the BCSA spends much time on.....and needs to. I understand that the fees get passed to the owners anyhow, but if the homeowner permit fees get raised that may even drive them to use a contractor more and the BCSA will have less to worry about and more time on their hands.

Douglas McBurney Reasonable / Strongly supportive

The proposed fee increases are reasonable, in my opinion, and will contribute to improvements overall in the safety system.


Russell Food Equipment Service Dept

Reasonable / Strongly supportive

The fee is in line as long as we will have stronger enforcement and inspections in the field.

Rainbow Electric Somewhat reasonable / Supportive

Cost is increasing across the board , this is a cost

Vancouver Island University


BCSA does good work, critical work, to keep workers and end users safe against a tide of ignorant unprofessional hacks undercutting professionals by doing substandard and unsafe work. We need more supervision of the trades, not less.

Manufacturer in boilers, pressure vessels & refrigeration

Somewhat unreasonable / Strongly opposed

The level of service the BCSA has provided in the last 10yrs has steadily declined, lack of inspections, lack of technical support/education, enforcement, etc.



Any increase is not necessary and unreasonable! BCSA increased our fees a few years back and then closed most offices, so tell me where is the value I am receiving from that fee increase? If anything my fees should have dropped when you closed the offices. This is nothing more than another tax on the working, to pay for what?



First, fee increases should be based on past CPI performance not what could happen in the future, especially for a non-profit, quasi-government entity. I would not mind the fee increase if services were better or added. The online portal is very clunky/slow to make changes, seems manual entry on the back end. Also, multiple times I've needed to call to receive documents/receipts that were supposed to be emailed. I would also love to see the multi-permit extra low voltage 25 permit decal sheet be extended to include up to $5000.00 values. $250.00 values seems out of touch with real world installation values on a typical 1-2 day small job. When we are busy this creates a lot of paperwork and individual permitting. If your fees increase, I find it reasonable that your multi-permit value ceiling increases to better reflect real world installation values I see no benefit in a fee increase without the current services being performed better or additional services added to make permitting faster and less complicated, especially for extra low voltage installers where the paper work is becoming a full time job.


BC Forest Discovery Centre

Reasonable / Supportive

I think you, as a group, have a thorough understanding of your operating budget and expenses. A 2% increase is not at all out of line.

Homeowner Neutral / Neutral I would not be opposed with a 2% fee increase, HOWEVER, in my view some of the fees cannot be justified in the first place the fees charged the homeowner should be nil. how can you justify a fee for replacing a fixture or adding a plug. once the fee is larger than the service, I will do it myself. this has two impacts - the electrician does not get the work and you don't know about it.


AES Engineering Unreasonable / Strongly opposed

Value for cost. Regardless of risk management techniques that might support auditing of Inspection requests, the result is local safety officers are becoming more unreachable, rarely perform inspections, and generally seem to provide less customer service, answer fewer questions, visit jobsites less often and on occasion are completely unsuited to the role. There are still a few safety officers that use intimidation to get compliance. A few who make calls but do not provide said decisions in writing, perhaps to cover their own lack of knowledge? A permit has a fee and fees imply some service that directly benefits the payer. While much of this money is earmarked to support the growing management and number of employees that work in offices rather than for safety officers to do inspections. Business liaisons? Just how much administrative load can the system support? We pay fees expecting that we also get some actual service for the fee. when permit fees exceed materials costs, especially on small projects we see more permit avoidance. Given how unlikely these small jobs will be examined or audited it becomes a tax rather than a service. then there is the limits on fees and the exemption from utilization equipment to be included in the fees? Frankly the permit should not have a maximum value and should be based on total installation costs including design. The scale of fees should be adjusted to a curve as well. low value jobs need a reasonable permit fee and super large projects should have very low fees once a project exceeds a value for service. IE at some point the permit fee is clearly subsidizing projects with lower fees that may not recover all administration costs. The perception amongst contractors is fees are too high especially for low value jobs like changing a luminaire. and too cheap for a huge project like a hospital. A permit fee for a hospital in a municipal government inspection authority might be higher than the BCSA fee but the permit fee is seldom a source of complaint if it also gets regular visits by the safety officer. A permit fee of $50 for changing a $40.00 fixture does not actually generate much income to BCSA because the fee is too high and the inspector won't visit. It would just be more honest to charge $20 and make no claim it is anything other than an admin fee for the paperwork. Evidence out of risk management systems may focus the efforts of safety officers to deal with the higher risk activities as well as focus on poor performing contractor but it also has the effect of instilling a no service for fees mentality. Regardless of success, these risk management programs are not taking service into account and constantly overlook the value of a safety officer's visit. Many contractors work to maintain good communication with the Safety officers and value the ability to call the local safety officer with code related questions but instead we get call centers staffed by people that often are only able to provide account and permit information


and cannot make a Call on a code question. This is a cost increase since contractors are losing this valuable resource and now are spending more time on the phone and in emails only to wait 2 days for a reply? This is a great way to alienate your customers and pass more cost onto them. Certainly MY time as a Safety officer working in a municipal government that I found I was frequently being called for code opinion or ruling by contractors who were unable to pose their question to BCSA for a project under their jurisdiction. In this case the local government is also subsidizing BCSA by the simple virtue of accessibility of their safety officers. BCSA has to control their admin cost and salaries of upper management who provide the least value at the highest costs. Contractors look for guidance from their safety officers. fees imply service for fee. Contractors want a level playing field with regard to fees and permits. Make more effort to catch and prosecute permit avoidance and spend less time on reports and self aggrandizement. reduce the size of upper management. Get back to basics. When construction is as active as it is right now, permit fees should not be lacking. The growth of BCSA should also ebb and flow with the economy. In bad times maybe there needs to be fewer safety officers except that they are likely understaffed at any level of construction activity. Look at your own careers page. How many administrative jobs are posted as opposed to safety officers? There are also some positions that seem to be eternally posted as well? No expertise or not enough compensation to attract qualified people? Frankly it just made more sense when the provincial government had direct responsibility. At least they have some tax revenue to support the low times and everyone benefits when their revenue exceeded costs.

A post secondary training provider in boilers, pressure vessels & refrigeration


In many areas wages have stagnated for several years. BCSA has reduced customer contact time by reducing hours that they are open to the public, and moved to a more self-serve/online model so the savings should be passed on to the customer instead of increasing prices.

Club Aviva Recreation


We don't feel the fees we pay in order to operate our single inflatable are reasonable given the services (or lack thereof) we receive from the Safety Authority.


A service provider in passenger ropeways

Unreasonable / Opposed

The ski industry is different than the other industry you service and you need to be mindful of this. The ski industry is for the most part in decline and all operators are working hard to maintain their skier visits, especially the small to medium operators who do not rely on accommodation for revenue. Considering the health of our industry and our challenges I cannot support any increase in fees unless you start to implement them differently. For one your definition of a small operator which allows an area a 50% off fees needs to be more in-line with the CWSAA definition. Having an aerial lift does not mean you are a more substantial ski area. We only operated 2 of 5 lifts last season so we could come to a balanced operating budget due to the fees. I do not see this as good or healthy for our area or the ski business. There are a handful of very big players in the ski industry- of course they do operate more lifts (more fees) but they are also in a category all their own due the ski lifts being an amenity to their lodging/F&B. They in turn make a very sizable profit from this and I believe you should be charging fees into categories of very small/small/medium and large resorts- based on either skier visits or revenue. If you are increasing it needs to be fair to the smaller operators that operate just a ski area. The [four largest] resorts can afford to make more sizable fees relative to their revenue. The small areas are truly suffering financially and this has to be a consideration as well as offering assistance with program building as Worksafe BC does.

A service provider in boilers, pressure vessels & refrigeration


Each year costs go up for everyone. It's a fact of life.

BC HYDRO Unreasonable / Strongly supportive

Real estate prices are up 200-300% over the past 15 years, there are likely 200% more buildings, houses and service connections in the past 15 years - but you continue pretending you could provide the same quality of service and 17% inspection rate with 10% fee increase over the past 15 years. Property taxes doubled - who's got the extra money?? You need to strengthen your education and violation review process, increase inspection rate to 25-30%, increase BCSA presence around Province, etc. Make BCSA great again!


Lorne Kethler o/a Reltek Installations and Maintenance

Neutral / Neutral I believe the incremental fee increase is better than the MASSIVE increase from [the utility] in April, but the money needs to be directed effectively. Here in the North, there aren't enough safety officers to cover the area they have for permitted work. I feel that if there is to be any enforcement or investigation, to keep the under-the-table work under control, there needs to be more officers in the field and willing to impose the fines enforcement orders on those not licensed or qualified to do the work.

A-West Services Ltd (B electrical contractor)

Reasonable / Neutral

Permit fees for 0-$500. A small service call (Less than $100 should be exempt) A large service call $100 to 250 could be $25 or better yet a no fee permit like the old days-just notification that the work was done by a licenced contractor-after all you are all about SAFETY and the inspector is probably not going to check it anyway. $250 to $500, how about $50. Works out to about 10%. Add more exemptions for no permit required. Making small value permits easier to fill out. After all, we are certified, bonded and licenced professionals. Lets not go to the cash grab like Ontario where you to pay annually for individual workers and high WCB rates in order to recover lost WCB mismanaged moneys.

Diamond Heating & Spas


The consumer is being hit once again, customers already feel they are being "ripped" off as it is. Penalized the people who deserve to be - the people installing without permits not those that are following the rules.

Service provider in boilers, pressure vessels & refrigeration


Fees are already ridiculously high, you should be introducing fee cuts, to go with your service cuts.


Sent via email NO To increases people will go without permits

Service provider in gas

Sent via email Increase the fees increase your service, people will take as much advantage of poor workmanship as long as you allow them. There are more hillbillies in the trade more than proud tradesman. I CAN'T CHANGE THIS ONLY YOU CAN. Do your job and things get better.

Epscan Industries Somewhat unreasonable / Opposed

The cost of permits in relation to Value of project is out of line especially on small projects. Ranging from 35% ($251) to 1.38%($200,000). Now I do realize that it takes time and money to inspect small jobs.However the cost of the permits smaller projects is getting to large. Many customers are complaining about the cost of permit being so high. I firmly believe that with the costs climbing many people are turning to do their own


work without permits. What about pegging all permits at 1% of value of installation. Simple and easy to calculate.



I am unsure why the fees are being raised annually. I seldom see my local inspector, have to wait days for an email response (if ever) and can't always get my questions answered. I'm not seeing a full understanding of the Code by the visiting inspectors which becomes apparent when I ask questions. The safety officers are reluctant to provide advice or give options when a non-compliance is found. I was flustered when a recent situation required me to spend time and money on researching and implementing one of 3 options with there being a possibility that the option chosen would not be an acceptable solution but the inspector refused to tell me ahead of time which option would be best or unacceptable? Now I have to start paying to keep my license valid like a hairdresser would. I hold a red seal in electrical but I don't have to renew that. I can basically not perform any electrical work for 5 years then suddenly get back into it with no fees, no test, no anything. What good is my power engineering certificate in comparison to that if will just expire? My employer should require that I prove knowledge and experience or even take an upgrade course if I've not been actively working as a power engineer for a while. I agree with other people that have complained that BCSA has lost its vision and is no longer about providing a service and is all about being profitable. I've said it before and I'll say it again, get rid of the Alternative Safety Approach. Force companies to hire qualified people and get them trained. Stop damaging the field by de-regulating plants. I sure don't want surgery by a non-qualified surgeon who just has some site-specific training. Inspect more, train your safety officers to be able to answer questions. And don't just train them to answer questions, train them to answer them properly. One complaint I hear a lot is contractors who work in Alberta claim any inspector will give you the same answer to your question no matter who you ask. In BC, every inspector has their own interpretation. This devalues the word of the safety officer. If BSO A says one thing then moves on, BSO B is going to nail me for doing what A said. It is hard to get any safety officer to put anything in writing so I can have it on file. Demonstrate the actual value in increasing fees and requiring re certification fees.

Gas plus plumbing and heating


Quite reasonable

Homeowner Neutral / Neutral 2% is fine


Homeowner Reasonable / Strongly supportive

Homeowner permits are cheap, so BC Safety Authority needs to make some money too.

GBR SERVICE GAS Neutral / Neutral How owners see these fees as going to me not you its enough getting them on board with current prices


Sent via email I think it is a total ripoff to charge a tradesperson ANYTHING to renew his license. This amounts to a tax on my income doing work for which you are already charging additional fees! If I am NOT performing any installations and NOT remaining current then perhaps a reexamination fee might be advisable. You already have my fitters number on every job I do so knowing which fitters are current and active would be very easy. Fee increases should be made up by non licenced violators, both installer and permit applicant, and reinspection fees for shoddy workmanship. Increased fees and fines for violators would also help deter the practice! I pride myself on being a knowledgeable and competent gas fitter and take umbrage at constantly being financially gouged for the RIGHT to perform my job.


Sent via email The BCSA fees are very high now. My customers complain every time I show them your rates. Add onto this the [utility] meter move, the fees are out of control. I would like to see them frozen for 2018.


Sent via email I Think it is a very reasonable increase which 99% of the people will not object. There is always one out there

Owner of gas equipment

Sent via email I think it's getting expensive enough to build. So why add to it. Pretty soon no one will be building.


Sent via email Fee increases are not a problem to me as they are passed on in my business. My concern as a Gas contractor as well as a Boiler [refrigeration] contractor is that there are so many companies operating out there without trade qualifications, contractor licenses, bonding, or even business licenses. I know several personally. The BC Safety Authority should and could come down on all of these contractors simply by auditing the local suppliers. If you don’t have trade qualification for the type of


equipment you are trying to purchase, you simply cannot purchase it. As for new equipment, If a supplier sold 100 installation (permit required) units, the Safety Authority should have 100 permits or 100 units accounted for on permits. It is becoming increasingly difficult to compete with the unqualified & unlicensed companies and individuals out there. As a Boiler (Ref) contractor I am competing with residential companies with no refrigeration licensed individuals, who are installing over 5kw ( 18000 btu, 1 ½ ton) on a daily basis and I am told that they do not require qualifications as they are residential. Residential contractors are installing 20 tons (+/-) of heatpump on commercial sites because of the implied grey area of the law. The B-52 code should be enforced. The Safety Authority should not only be protecting the regular citizens but also the Contractors out there that are following the rules.

Owner of boiler, pressure vessel or refrigeration equipment

Sent via email It is my considered opinion that there is no grounds for an increase in fees. Incomes are stagnant or decreasing for a fair number of clients and to add another 2% to the burden is asking too much at this time, especially in light of what might happen politically in B.C. there may and will likely be an increase in the overall tax burden to all British Columbians. NO increase.

Service provider for boiler, pressure vessel & refrigeration

Sent via email What would be impressive if we were advised that 5% was cut by running the branch better.

Boilers, Pressure Vessels, and Refrigeration, Elevating, Gas Institution/equipment owner


No concerns with the proposed increase in fees. Increases are in alignment with other sectors

City of Burnaby Parks and Recreation Dept

Neutral / Opposed

I have two waterslides at one location and one water slide at another location. Following the fee schedule we pay, roughly 360 for the contractor’s license plus 600.00 for each water slide. This totals close to 2000.00 per year. For $2000.00 a year, we typically receive one visit, which lasts an hour per facility which adds up to two hours. This can be followed by receiving incorrect bills.


This does not strike me as being good value. I can’t say I feel like we are receiving 2000.00 dollars’ worth of service.

Bakerview Heating & Cooling Ltd.


The fee schedule recently sustained an increase. What used to cost us/the homeowner for a furnace installation was $111; now it is $113. I received negative feedback from homeowners when the prices went up. I can only imagine how they will feel if I have to pass along yet another increase to an already frustrated, taxed BC resident

Origin at Longwood Unreasonable / Strongly opposed

The BC Safety Authority issues the permits, for which there is a charge, you do not actually inspect the equipment; when a complaint is made about a provider you do not provide support; I'm not sure what the fees are for.

CanaDream Inc Unreasonable / Strongly opposed

Annoyed that the info e-mail mentions a 2% increase, when the details reveal a 2% per annum increase over several years, making the actual increase 3 times the "advertised" amount. It sounds like false advertising and minimizing the cost under the guise of being open and transparent of a proposed upcoming increase in rates from another regulatory service that (however justified) really comes down to a cash grab from most businesses trying to survive and earn a profit, and faced with trying to pass the increase along to consumers, who are more likely than ever to do cash deals under the table to avoid extra costs associated with getting things done by legitimate businesses. Curbers, unlicensed dealers, and people and businesses who do cash under the table styles of business will have yet another advantage over the brick and mortar businesses who play by the rules. Those paying the fees are assured it is "in the name of safety", but the assurance is not very convincing, and the costs are already difficult for most businesses to absorb when trying to cover the increasing costs of overhead. 2% per year for several consecutive years is not easy for most businesses to absorb, as consumers become ever more price conscious.

Boilers, Pressure Vessels, and Refrigeration, Electrical, Elevating, Gas, Passenger Ropeways Institution/equipment owner

Neutral / Opposed

As a building owner and operator we are invoiced annually for operating permits. However we do not receive any service for the operating permit. If an operating permit gave us some assurance that our installation contractor had done a proper job or that the equipment was being maintained properly by licensed contractors there may be value in that. However I do not see any value in the operating permits.

Industry Training Authority


The fee increases in line with CPI seem reasonable to cover ongoing cost increases incurred by the organization.


Pacific Integrated Contractors Inc.


Your fee's are fair and better than city fees. Not really opposed.......



BC safety authority charges too much money for inspections that don't even happen

Manufacturer in Boilers, Pressure Vessels, and Refrigeration


I can understand that costs go up. I am concerned about the value provided for the fees we pay to register designs and have inspections performed.

SM Electric Unreasonable / Strongly opposed

All Permit Fees have gone up steadily however the Service provided has deteriorated incredible in the last 5-6 Years. The Service & El Inspections were very good in the 70s-90s, the El Code-Rules made sense . All Safety officers were approvable & approachable, everything made common-sense! Not the case now!!! As it is the Fees are way too high already!!!!



If the BCSA needs more money they should be going after, and fining, unqualified and unlicensed people doing regulated work. The burden of this shouldn't be on the legitimate contractors who diligently pay licensing and permit fees to the BCSA.


Neutral / Opposed

Not enough is being done to catch the no-permit/homeowner-actually-contractor-permit jobs. There always seems to be an undercutter around who'll do a job for cash, no questions asked, and there's always somebody around who'll hire them. It's all underground economy and makes it very hard for above-ground contractors to compete, especially the contractors who do smaller jobs (< $5k). A coupon system for smaller value jobs would be good.

End user - Manufacturing/Maintenance Industry Company

Neutral / Neutral The Fee Increase Discussion Paper is not persuasive regarding the need for a fee increase. Many industries are not able to justify CPI increases in the current marketplace, so why should BCSA be an exception? An increase in construction activity should directly correspond to a revenue increase from permits/fines, therefore not in itself a justification for fee increases. (We're busy so we need to charge more per customer, is not justifiable.) We use a BCSA recognized FSR for all electrical work required on our premises, therefore we expect that any BCSA inspection will find 100% compliance. The need for permits is understood. However, our perception of value of BCSA does not support an increase in fees given the oversight provided. Like others have commented, permit fees should still represent value for money. Without visible increases in inspection/enforcement activities, the proposed successive year to year increases do not seem reasonable. From a consumer perspective, I do not feel a credible job has been done educating


the public about BCSA's core purpose and benefit (encouraging permit compliance). Practically speaking, BCSA needs to identify and ensure compliance at sites where work has not been performed by qualified personnel or in a manner not conforming with code requirements. Where quality work is done by licensed professionals in conformance with code, where does BCSA add value that justifies a fee increase? If the reality is that BCSA needs to implement the proposed increases to attract and retain the talent required to provide safety oversight, just say this. Don't obfuscate matters. I don't perceive that the respondents to this survey are economists, so using phrases and terms such as "for continued delivery of safety services" (too vague), "CPI" (too specialized) and "projected construction activity over this three year period" (relevance) is not making your point succinctly. (Based on other comments, the consensus appears to be that the number of inspectors has declined and therefore this is where BCSA needs to improve.)



2% fee increase may seem reasonable to some if there was value in the fee to begin with. The problem is there is no value. We the contractors are fee collectors for the BC Safety Authority in order to support their heavy loaded office management team. Looking at your job opportunity board on the web site there is over 25 job positions you are looking to fill. A lot of these are roles to support other office staff that do roles that have nothing to do with us contractors. BCSA has turned into a heavy loaded office with no boots on the ground. Example - you need a senior business analyst @ $54.00 per hour. Job description is Supports the Leader in the strategy and operation of the BC Safety Authority’s business intelligence program. Provides an advanced level of expertise in business intelligence to develop and deliver data and information products for internal and external customers and stakeholders. Independently carries out complex needs assessment, identifies opportunities to optimize use of data and information extracted from internal and external sources, and determines optimal methods to deliver resulting products to meet business needs. Provides day-to-day technical guidance to the Business Intelligence Analyst. I'm sorry but I'm not thrilled that my money goes to pay $120k per year for some guy to give technical guidance to some other guy that got a job called " business intelligence analyst". Both roles sound like [nonsense] to me. How about you guys learn to manage your 60 million a year budget ! How about you stop blowing wads of cash on a software package fondly called MY DISCONNECTION by your customers. The one that you gave your management team a year end bonus


for because it was rolled out on time only to replace it 4 years later with something else. How about you guys put boots on the ground and go after permitted work. How about you go after box retailers selling gas appliances direct to homeowners that will never pull a permit. How about stop buying fancy office equipment for your glass tower every year and start running an efficient business. I'm sorry, just can't see why us the contractor ( your customer ) should pay more but get less in the end.



The funding model of the BCSA, paid for on the backs of PERMIT COMPLIANT customers and contractors, is broken. The organization is important and I support the activities of our Electrical Inspectors. Get government funding like any other enforcement agency i.e., police, bylaws etc. Like any other retailer, lower prices, higher volume, more safety. Finally, the fees on small jobs. 6 - 21 % of the customer’s bill goes to the BCSA to make sure we know how to wire a kitchen of potlights!!!!!

Krolow electric Unreasonable / Strongly opposed

Prices have already increased dramatically.

VJLS-JH Neutral / Opposed

It's unclear why BC Safety Authority collects fees in the first place. I can somewhat understand fees for larger devices such as elevators, but why is there a fee for ordinary gas equipment and boilers including hot water tank? It is unlcear as a role of BC Safety to ensure the safety and it feels like the fee is money grab.

bc hydro Unreasonable / Strongly opposed

MONEY GRAB

Property owner Unreasonable / Strongly opposed

I don't see a reason to increase any of its fees since I don't even see the benefit of any of it to begin with.. I think to be called the BC Safety Authority, it should be a Government organization. This is a private entity collecting fees for a so called safety authority. I don't see how they have made it safer for me. If they want to impose fees on trades, they can do that. But it is not reasonable to impose fees on property owners.

John Sadler Plumbing & Heating Ltd


I don’t need to read [the discussion paper] to know that putting permit costs up further is going to create a situation where less people are taking them out. We lose jobs because people don’t want to pay a permit fee and other companies are not telling


them they need a permit. Many jobs we come across have no permit and the work is done poorly and unsafely. We report it, but who knows what happens after that. Many skilled people are moving out of the lower mainland because it’s too expensive to live here leaving many unskilled people to fill their place, and those unskilled people do not care, or even know about permits. If you are going to charge $114 for a gas permit, then every job should be inspected. I understand there is a cost to do business for the BCSA. I understand putting fees up when needed, but maybe you need to reduce your operating costs rather than put fees up. Our concern is and it is a fact that some companies are not taking out gas permits. Gas permits are required for hot water tanks, yet I hear time and time again from clients calling in on the phone, oh so and so company said I don’t need a gas permit for a tank. The BCSA needs to find a way to level the playing field and ensure permits are taken out. The gas hot water tanks that are sold at big box stores are not tracked. How many of these have a permit?



the increase is worth the services, safety it provides

G & S Heating Ltd. Neutral / Neutral I don't feel that the increases are justified due to the lack of inspections that are carried out by the inspectors. Funds are taken in but the safety authority does not inspect jobs as they should.

Viterra Neutral / Neutral It is understandable that a fee increase is being requested as costs for everyone are increasing to this we provide only a neutral comment. As a large facility operator we see the inability of BCSA as being able to provide consistent inspection services and suggest that a reformed model where inspections are waived for certified contractors be established or where the work is being certified by a Professional Engineer. This would eliminate trying to draw a mandate for inspection services which are not necessary and frankly undeliverable. This provides not only a better cost model but a better focus on higher risk activities with a new focus on periodic audits of certified contractors. Our issues are not with an appropriate increase in relationship to managed costs but the delivery model as a whole.

Graham Johnson Neutral / Neutral I have no problem with a fee increase if its going towards the proper uses. Stop going after insured workers who are certified to do the work and start targeting those who are not.

Canada Place Corporation


As the fee increase aligns with CPI increases, the increase is justified


Sync Mechanical Ltd. Somewhat unreasonable / Opposed

2% seems a bit high for the industry. I can agree with 1% for inflation costs.



Am concerned about the value that will be provided for the increased fees. Specifically, there ought to be more inspectors (to ensure availability); one should not have to book 3+ weeks in advance to secure an inspection. There are other issues that I have difficulty with, such as the practice of being charged on a per unit basis for final inspections rather than an hourly flat fee. Those issues were not addressed in the consultation materials. I am not seeing where there will be additional services provided. Also, word on the street is that the BCSA is planning a move from the New Westminster offices to downtown Vancouver. If that is so, that does not seem like a prudent use of 'not for profit' funds.

Electrical and elevating devices institution/equipment owner


I have owned equipment for 2 years and have never seen and inspector. What value and I getting from these permits. How will the increase rates increase the level of service I receive? Not receiving any value from the permits I currently pay for. Each year I renew with no visit from an inspector to verify my equipment. Feels like BCSA is more interested in collecting renewal fees than it is about making sure equipment is actually safe.

wind heating and cooling


I am strongly in support of safety and regulation. I also have a lot of respect for the inspectors and administrative staff of the safety authority. I recently became aware that the top 5 or so executives of the safety authority earn what I consider to be too much. Additionally I understand that the safety authority is currently making more money than they spend. For those reasons I am opposed to increase in fees. Thank you

Arete Mechanical Somewhat reasonable / Supportive

Government of policy and regulatory safety by a corporation is an expensive task given the requirement of interaction with all parties involved in any relative undertaking.

Masonic Temple Association of Victoria


I wasn't at all impressed with the budget figures. The forecast was based on the application of a standard 4% increase in costs and expenses annually. Indirect costs (the cost of operating the Safety Authority) was a steady 39.6% annually. The figures could have been developed by any high school student who can multiply. I looked at the 2015 "State of Safety Report" to see how well the Safe Authority has been doing. In all but elevating devices and railways, the number of injuries has fallen since 2012. It appears to me that the Safety Authority might continue to reduce injuries with greater funding, so I am willing to give higher fees a chance, particularly if they are applied to elevating device safety.


Client in railways Unreasonable / Strongly opposed

A 2% increase in fees is making it less attractive for business in the north east that are already struggling to survive. we will only get 32 railcars thru this plant this year with cost of track lease BCSA fees things are looking good

DISTRICT OF SUMMERLAND


Raising the fees would have no impact on our operation.

Industrial user Somewhat unreasonable / Opposed

I think the increases are going to be piled on top of increased permitting requirements. This will be a double dip (or more). In industry, we are challenged with finding savings to offset increasing costs or to "eat the inflation". BCSA should be looking at cost savings to reduce the need for fee increases. Looking at the available job vacancies at BCSA, it is likely that the expenses will continue to climb.

Burnaby Manufacturing Ltd.

Somewhat reasonable / Opposed

There has been a substantial increase in revenue over the last five years, up to the tune of 20%, as the construction industry is very busy. I do agree that there should be regular small increases in fee's verses freezes and large increase. I think that B.C. Safety Authority has an opportunity to become a leader and set the tone for the other Authorities and a 1% increase would set that tone and would give the Safety Authority plenty of revenue to work with. Not only that it would set the tone to their employee's

Facilities maintenance at BCHydro sites


Some of Power Engineers are not compensated properly, our Salary is not on standard as provided by BC Safety authority, Therefore how can we afford to pay for the renewals and not all are employed and it takes time to get employed, employer are looking for experience PE and yet they offered below pay salary that BC safety authority required.

Anonymous Reasonable / Neutral

I haven't noticed an increase in a few years so 2% seems reasonable



1.5% is more appropriate. worker's wage usually does not increase much.


Sent via email I feel the fee schedule is getting a little extreme. The fee structure should be based on the amount of inspections required for the project. Not based on Job Value. Some projects require multiple inspections while others may only require two or three. A project with a value of $30,000.00 could only have two visits from an inspector. So the cost of each inspections relates to more than $400.00 per visit. That’s crazy.


A re-assessment of the way fees are based, need to be adjusted. The value of the ministries fees are becoming well beyond the cost of local city municipal fees, in relation to their fee schedules. So the justification of the fees at this point are in question. It also seems that the enforcement of non- compliant companies are not being fined or even being enforced. Lack of manpower and penalties. A list of such: Handyman, Home renovators, Property Management companies, and commercial property owners. Who is chasing them down? Lack of money and manpower? This needs to change. It’s hard to sit back and see the years of qualifications, training, insurances, bonding and permits be put to the wayside, because an unqualified person takes the job away. Enforcement is needed. The Ontario trade association has implemented strong laws to enforce this issue. Why has BC not done the same? In the fee schedule there is a section for Operating permits. But how many companies are complying? Very few. ( because there is no bite, and most companies are not aware of this regulation (law) ) Just my rant, as I have felt the pain of non-compliant work continually being done by unqualified personnel.

Brodan Industries Ltd Neutral / Neutral My concern is the continual increase is increasing the job costs for the customers. Possibly on a project with 3 inspections lasting less than 1 hour each, could cost the customer upwards of $ 400.00 per visit depending on the job value. A fee schedule should be assessed based on the amount of visits from the inspectors.



Fees keep being increased and nothing ever seems to be getting done. There are a lot of us out there that follow the rules and still get undercut on jobs by other unlicensed individuals or un-permitted work. There are many projects carried out by what would be considered the "larger" companies that have code violations and those don't seem to be being caught. With so much of this going on day to day I do not support an increased budget for BCSA when the current budget is not working.

Service provider in boilers, pressure vessels &

Neutral / Neutral I wish my annual wages were increasing 2% each time Commence, Government, Utility, Banking, and all other entities increase fees and services.


refrigeration and electrical

Prince Rupert Senior Citizens Housing Society


Our group is a volunteer non profit Board. We have kept our rate increases to a minimum so we do not like to see raises of any kind. We do understand that costs go up and that raises in fees are required from time to time.

Boilers, pressure vessels & refrigeration union / association


We pay enough in taxes as it is BC, I do not feel we need to pay any more money. I barely make enough to pay for where I live, and I am a Certified Power Engineer. They build bike lane everywhere, but the government can't throw money towards an organization within their own government



For services we receive from the authority already lacking, increases seem out of line.

Epscan Somewhat reasonable / Supportive

I agree that the fees have to rise and the annual fee over multiple years is a good way to introduce the increases. I feel that the fee increase is needed to catch up to increasing costs.

canada bread Neutral / Opposed

I oppose all government related fees, get your own house in order before asking for more money

PJs Electric / Mott Electric GP

Neutral / Neutral Is the increase to better service or collect more money to have more to do less? Fines and fees seem to also increase, is there any proposed increase to service? Tech Talks were used as a justification for services provided but I believe these are now have a fee for service.

Boiler, pressure vessel & refrigeration union or association


Just another tax grab.

Opposed (boiler, pressure vessel & refrigeration)


Once you qualify for a power engineer certificate it should be valid for life like all other trades. Value isn't there for this proposal.


Sent via email I struggle with the reasoning to keep revisiting permit fees. Construction costs have risen an average of 3.11% since 2002 The consumer price index has risen half of this since or 1.35%, which is about the same as the wages have risen. As the fees are primarily cost of project based they are inherently rising faster than the wages and expenses, unless these are not following the balance of the economy. I see no reason to change the fee rates


Canfor Pulp and Paper

Reasonable/ Strongly Supportive

I don’t think that 2% is an unreasonable increase in fees.

Gas Contractor/custom gas fire feature manufacturer

Unreasonable/ Strongly Opposed

Permit fee increases in some categories have become unreasonable. $600 plus for a commercial gas permit where the total connected load is below 200,000BTU is outrageous and represents about a 20% plus cost of the total job value based on the current and proposed continuation of that dysfunctional fee calculation method. Add to this the understanding that the building and plumbing permit for the same job was less than half the cost of the gas permit and an actual plumbing and building inspector shows up on site. I turn down work on a regular basis from clients that aren't willing to accept permit costs. They know the work will be completed to code (or better), that the gas contractor gets in trouble (not the equipment owner) for not taking out a permit, they know the contractor and fitter are still responsible for the regulated work, permit or no permit, if it's completed by a competent fitter. Their only risk is that they might have to pay for a permit down the road if they get caught. Having read the feedback already received on these permit increases it seems to me it's a no brainer that increasing fees really shouldn't be happening at all, if you want to listen to the feedback. The feedback isn't a 70/30 split, it's about 90/10 split (90% being opposed). Having to provide additional feedback, on top of what you already have is a moot point. If those percentages of opposed are ignored and you go ahead with your proposed 2% increase I can only conclude that this was just a publicity exercise and nothing more. Many comments have already addressed why this is not popular, I would only be repeating what's been said already and it tells me participants in the program are not a dull bunch.

Service Provider in Electrical


The amount is nominal and in keeping with inflation.

houle Reasonable / Supportive

I understand the need to increase cost to accommodate daily increases and I hope as a result we get a better system to use moving forward.

An association By email [We believe we have] a positive and strong working relationship with BCSA. The Safety Authority has a knowledgeable team that brings value to the [industry in BC], and communication between BCSA, [operators], and [this association] is open and unrestricted. This is evidenced by the many cooperative initiatives between industry and the authority.


BCSA has asked for input on a proposed fee increase for 2018. At this time, [our association] opposes [the industry] fee increases in 2018, and strongly opposes an automatic increase for each of the next 3 years. During 2017, BCSA and [the industry] were to review the [technology’s] fee structure together. This had been the intention between the agencies since May 2016. For understandable reasons related to unexpected transition in the [technology’s] branch, such plans were disturbed. The result, however, is that the [technology’s] fee structure has still not been discussed. The reason for a fee structure review is as follows. Many [operators] in the province invest heavily in the training of their own staff and technology. BCSA determines frequency of inspections, in part, by the training and skills of the [operator]. These [operators] receive less benefit from BCSA and also use less BCSA resources. In short, they are paying more for fewer services. The [technology] fee structure is made more complicated by the need to find a funding balance for the entire industry. To BCSA’s credit, it understands the significant differences between all the [operators] (eg: small non-profit [operators] versus larger destination [operators]). A change to the fee structure must not compromise safety standards, but an alternative model may better serve stakeholder needs. For this reason, BCSA and [our association] had agreed to review the structure of fees before 2018. [Operators] and BCSA will both be attending the [the association’s semi-annual] meetings in late September. If agreeable to BCSA, [we] would be pleased to assemble a committee to meet with BCSA regarding fee structure for [the technology]. Until such consultation, [we request] a freeze on [the technology’s] fee increases.


COMMENTS ON THE PROPOSED COMPLIANCE & ENFORCEMENT FEES


Comments

A service provider in Boilers, Pressure Vessels, and Refrigeration, Electrical, Gas


Excessive, should start with a double permit fee, no need to be an executioner

A service provider in Boilers, Pressure Vessels, and Refrigeration, Gas


So long as the proposed compliance fees are aimed at the BAD guys and not aimed at the contractors who have always been in compliance except for the occasional laps in permit application or late in applying for a permit - and 99% of the time do good work - then enforcement fees may work - then again how do you enforce unlicenced people from doing permited work? - can you charge them with a criminal offence?


Somewhat reasonable / Strongly opposed

Seems to be going from Nothing to extreme, start with a double permit fee. How do they propose to justify a $980 investigative fee



Enforcement is extremely important.

Pfitztech Electrical Service


Contractors who perform un authorized work should be fined accordingly

Dancor Electric Ltd Somewhat reasonable / Neutral

Unsure

Marker Electric Somewhat unreasonable / Opposed

The framework put forward only seems to be in place to target licensed individuals who are already working in the permitting system, and does very little to deal with non-permitted work. The data provided to support the enforcement fee schedule is that there were more than 3400 sites without permits, and "that a number of sites" of sites were under permitted. I would like to see more information about how many sites were under permitted and how these fees would help in eliminating non-permitted work.





This is simply a money grab disguised as "in the interest of safety"



Totally in favour

Rainbow Electric Somewhat reasonable / Supportive

This could curb contractor from cutting corners , it will only work with increased inspections = more inspectors

Vancouver Island University


see previous comments on 'hacks'


Neutral / Supportive

The BCSA should not have issues with repeated compliance issues if enforcement was managed. Those who do not play by the rules should be taken out of the game. The old song and dance that the BCSA doesn't have time to inspect the compliant sites due to the number of non-compliant sites has to end. This does not imply heavy repeated fines to non-compliant individuals is the answer.



First of all this is just more taxation, rather than providing a service relative to value received. If we contractors gouged our customers the way you rip us off with fees and permits we would have no customers. BCSA can get away with it because they have no competition!! Not fair to expect everything to continue to increase with reduced value in our services.



What triggers a full investigation? One missed permit in 10, 100, 1000? Can you clarify what the criteria would be to launch a full investigation. What consideration do good reliable contractors get with a track record of hundreds to thousands of permits pulled? Full investigation $972 for un-permitted work vs compliance audit charged per hour. Which one is first and what is the difference? Standardized is a loaded word. When all contractors are held to the same standard then, I would support standardized enforcement fees



Homeowner Somewhat unreasonable / Neutral

fees to run your business are one thing. fees to the homeowner are another - it fuels the underground economy

AES Engineering Somewhat unreasonable / Neutral

It is hard to dislike the idea of the scofflaw paying costs to prosecute them but it is sort of like imposing court costs before the case has reached its final outcome? Would I have to pay a fee above the ticket if a cop pulls me over? i.e., I pay the cops wages to investigate and prosecute me? do I get a refund if I win an appeal? can BCSA deal with an increase of appeals? how does it deal with non stakeholders working completely outside of the regulations like a handyman changing light fixtures? I presume that BCSA has some authority to collect outstanding penalties but does a handyman care if you write an order if he had no license anyway? Part of the risk management model includes a calculation of savings by permit fee avoidance. If parking cost $3.00 per hour, a ticket costs 20 for an early payment and if on average I get a ticket every 8 hours of parking, is it cheaper to not pay the meter, and instead pay the ticket? I suspect that already is part of the permit avoidance formulae. If fees are too high, are they creating part of the problem? You can put me down as soft support but I have a lot of doubts as to whether this will cost more than revenue it generates and I do want to see more prosecution of permit avoidance and charges where harm is created, especially to the client. While I suspect that permit avoidance is often supported by clients I would not support their prosecution for that. they always have naivety on their side. In the end they can become victims of their own greed when unpermitted work goes awry.



But the standardized fees should NOT be more than the average person/company is paying now.

A service provider in passenger ropeways


Do you want to see strong and healthy programs at all areas? Then consider this when imposing these high fees across the board to everyone

BC HYDRO Reasonable / Strongly supportive

That's just helping you keep the lights on and pay your bills - no money to reach out to public and education community, promote your services, improve your procedures, etc.





If there is a hefty deterrent, then some might think twice before doing unpermitted work or low-balling a project value for a cheaper permit. My question is, "How well the fees will stick to an apprentice or journeyman doing a side-job with no company to fine? Will it be attached to their apprenticeship or TQ records?" If not, then why not and can it be done?

A-West Services Ltd (B electrical contractor)

Neutral / Neutral I will have to read more of your posted information on that subject



Again why penalized those that are following the rules. Yes, occasionally a permit is not put through as we are waiting on more information from the customer but it eventually does get done - I am not saying it is right just saying errors are sometimes made and things sometimes do not get done in as timely a fashion as we would all like in a perfect world. Making your software easier to utilize would definitely solve some issues at our end, we should be able to edit a permit and add to it and be billed accordingly. This would help almost eliminate a permit being not requested in time. Having to call in for small changes etc. is a waste of time on both ends - not to mention your software is NOT at all user friendly, very frustrating to use and horrible to have to train a new employee on.

Epscan Industries Somewhat reasonable / Opposed

I like the idea of Standardized fees but they are too high. Again flat rate at 1% makes sense.



This is the bread and butter of the BCSA in my opinion. If you exist to keep us safe in the applicable fields, then bill us accordingly. Fine those who offend or re-offend.

Homeowner Somewhat unreasonable / Opposed

I think things are fine just the way they are.



Industries that are compliant , should not be subsiding industries that are not compliant.



Origin at Longwood Somewhat reasonable / Neutral

To date there has been no indication of enforcement.

CanaDream Inc Somewhat reasonable / Supportive

Those businesses who do registered business should be on a level playing field, and all have to pay, and perform to a safe level. However, our cash-under-the table competitors will never even be on the radar, and still not have to pay fees.


Neutral / Neutral I think that education needs to be a stronger focus. Safety Authority staff should offer free orientation training to property owners and operators. It is very difficult to keep up with all of the legislation and in some cases interpreting the legislation and regulations. I have asked for clarification from Safety Authority employees on regulations and it has taken some time to get back to me. For instance high efficiency boilers needing operating permits based on the size of the heat exchangers instead of BTU rating.



Compliance enforcement costs money to ensure the system performs as planned.

SM Electric Unreasonable / Strongly opposed

It is totally unreasonable and only creates more mayhem on job sites ! Get back to the Format of the 1970-2000 and increase your Permit Fees according to the index not the idiotic ideas of some CEO.

End user - Manufacutring/Maintenance Industry Company


Compliance and enforcement appears to be BCSAs value proposition. This is where non-compliant sites should pay for the safety oversight to become complaint. Having a standard schedule sets clearer expectations with industry.

Krolow electric Unreasonable / Strongly opposed

I believe putting money into the equation will decrease the credibility of those doing the inspecting. As if a police department stood to gain by giving out more tickets. It is already the job of the bcsa to do exactly what you are proposing to do. Just adding more money into the penalties. Feels like a Money grab.

VJLS-JH Neutral / Opposed

What is wrong with funding them through general revenues as BC Safety Authority currently does?

Property owner Unreasonable / Strongly opposed

This should be the responsibility of the provincial government, not a private association that is imposes its rules on non-members.





it just makes sense



I support the proposal of putting burden on those who are not in compliance rather than those who are in compliance with the regulations. This is a good initiative

Sync Mechanical Ltd. Neutral / Neutral Enforcement fees are necessary but I would also agree with a warning system first then impose fees after that if someone does the same thing if someone reoffends.


Neutral / Neutral Would have expected this to not be a new thing.

Electrical and elevating devices institution/equipment owner


Sounds like another fee equipment owners will need to pay without receiving any benefit.

Arete Mechanical Reasonable / Neutral

The need for compliance and enforcement fees has always been necessary to ensure present and future stakeholders (and other) respect

Service provider in boilers, pressure vessels or refrigeration


The need for compliance and enforcement fees have always been necessary to ensure present and future stakeholders: - take responsibility for their action or in-action; understand and acknowledge the legislation and or regulatory requirements of the tradesperson and or stakeholder; understand and acknowledge the need to safeguard the public and or fellow tradespersons.



I was surprised to find that a "Compliance and Enforcement Provincial Safety Manager along with dedicated safety officers" was a new development in 2016. I thought that was the job of the Safety Authority all along. I have no doubt that compliance and enforcement is necessary, so I am in favour of funding this work through fees on non-compliant practices.

Client in railways Somewhat unreasonable / Opposed

fees should be more regional



Industrial user Neutral / Opposed

The proposed fees are high to start with. The hourly rates do not reflect reality. It does not cost any employer 1.5x and 2.0x for overhead and benefits to pay an employee to work overtime, yet BCSA is proposing to charge 1.5x and 2.0x their straight time rates. In private industry, you would not be competitive.

Brodan Industries Ltd Reasonable / Strongly supportive

There are a lot of companies who are running without operating permits. They are using unqualified personnel to accomplish work which many companies are paying for fees, licensing, and insurance in order to be compliant. There is no bite to the current laws or regulations for these types. Therefore there is an abundant amount of work being done without any regulations being adhered to. This must stop and heavier fines must be given to the offenders, otherwise it is a joke to be compliant.



fees for non compliant work are a must to keep us all on level playing field. It keeps everyone in check.



As stated costs go up and fee increases are required to cover costs.



If the repeat offenders are being kept honest that can only be a benefit for our industry.

Epscan Reasonable / Supportive

I feel that enforcement is too relaxed due to a lack of inspectors to enforce. Additional fees may provide the funding to hire and support additional resources.

PJs Electric / Mott Electric GP

Somewhat unreasonable / Neutral

Standardized fees may not reflect the range of severity of the individual instance of non compliance.



Another tax




Unreasonable/ Strongly Opposed

Knowing that firms such as ours indirectly subsidizes un-permitted or unqualified work, with no substantive improvements in addressing this by the BCSA since it's inception doesn't really provide any real sense that improvements are coming. The main issue is that it is the participants in the Safety Program are the ones you're again relying on to make your intended program financially viable. I'm not sure how else I could explain; unless you go after the ones your afraid of going after(unlicensed workers performing regulated work, large retailers and/or suppliers not complying with the regulations, other institutions and individuals that push back on a political level, etc) AND that there are tangible, measurable, visible results... the chances of getting buy in from the participants such as my firm won't happen. You've had time since your inception to take some very simple steps to alleviate this yet you're still asking for feedback on how to address it. You have the suggestions and the feedback already and had it for more than a decade, it begs the question ' why ask for feedback if you don't intend on using it?' Enough talk, let's see some results now first before you propose further costs to that program. No buy in from me on increased fees for enforcement until I see some real results, you've had 10 years and a bunch of very good employees that have tried to initiate improvements with no real changes to the problem to date. Yet you have the legislative authority to do so much more (making forging of documents very difficult/requiring sellers of regulated equipment to record identity information as required by the Regs/backing down as soon as there's uncomfortable push back, etc). It just doesn't add in my view. the results to date based on the support you've had to go after the ones you're afraid of has always been there, I expect it to continue... as long as you don't put it on the backs of those of us that participate in the Safety Program already.


Reasonable/ Neutral

The current non-permitted work fines are GROSSLY ineffective. Make them 10x the permit fee plus a progressive fine aka WorkSafe for repeated violations and rescind their licenses. That should help the coffers. The industry wants these people out of our business. If you want to keep the hourly rates, fine, but combine the other fees. Keep It Simple.


COMMENTS ON THE PROPOSED COMMERCIAL GAS INSTALLATION FEES


Comments



There needs to be a volume discount for multiple units at one site. It is one visit and there could be 10 units, should be 10% off per unit up to 70%


Somewhat reasonable / Strongly opposed

There needs to be a discount for multiple units at the same location. How is it reasonable to charge $180 per heater when there are 10 on site. Excessive. Time on site is probably only 2 to 3 times what a single unit would be



The commercial gas fee schedule needs to be different.



The changes for 2018 are fair and reasonable


Neutral / Neutral A bit unclear, can we not just say a permit for 1 appliance is $, 2 appliances $, 3 appliances $, etc. Keep it simple why so much mumbo jumbo



I understand that logic behind the fee structure from 100k BTU to 6million BTU as the larger boilers are more complicated and require more time to assess. However 7 tiers seems like too many. Could this not be broken down to small medium and large appliances?


Neutral / Opposed

Changes to the fees would be fine if it meant we would get boots on the ground but we all know that wouldn't happen. [Definitely] we will get more shirts and ties in New West, maybe even a new office building for all of them to sit in as well.

Viterra Somewhat reasonable / Supportive

They do not have the appearance of unreasonableness


COMMENTS ON THE PROPOSED COMMERCIAL GAS INSTALLATION FEES

Sync Mechanical Ltd. Somewhat unreasonable / Opposed

The fees are already very expensive and should be left the same.

wind heating and cooling

Neutral / Neutral I have not done enough research to determine whether the net result of restructuring is over all higher cost. If it is I am opposed as commercial gas permits are excessive


Neutral / Neutral If anything the fees will be more costly. However, it is a 'user pay' not a 'trades pay' business. As such I see no issue. Perhaps a little easier for the 'user' or 'client' to grasp.


Unreasonable/ Strongly opposed

Same comments as already noted.


COMMENTS ON THE PROPOSED CERTIFICATE RENEWAL FOR POWER ENGINEERS


Comments



Do doctors have to pay to remain active, it is like a TQ and BCSA should not have the right



It is a trade certification, do they have to pay to maintain their University Degrees??



I am hoping that this will help stop Power Engineers who have been out of the industry for many years from coming back to the industry with no re-training and are completely out of touch with the new rules and regulations.



I do not see how this fee provides any advantage to the individual. It reads as if it is to provide a data base for manpower available to industry. Should this fee go to the individual or Industry?


Neutral / Neutral what will the administrative cost be to invoice all Power engineers every three years. Will it be more or less that fees collected?



The "Certificate of Qualification" should be treated like any other "Certificate of Qualification" (e.g. Electrical red seal journeyman) and be valid for life. To keep track of the Power Engineers employed in the province all you need to do is check CoQ's on the wall when inspecting the plants annually.

Power engineer Somewhat reasonable / Neutral

I am supportive of the fee if it allows creation of a searchable database of registered Certificate holders.





I worked hard to get my certificate. Now you tell me I have to keep paying to keep it valid? Doctors don't, electricians don't (I am one) but any doctor or electrician can stop practicing for several years then suddenly get back into it with no problems. Why is power engineering any different? Don't claim that 'all the other provinces are doing it' and say that's a good reason. Get rid of the field-destroying ASA department, don't give overseas people an equivalent ticket unless they can pass the full exam for the ticket they apply for and stop milking us for more money. You claim there will be a shortage of power engineers soon; get rid of ASA. That is killing it more than anything. Fine offenders, actually perform inspections. And start inspecting electrical contractors. Those guys are the very worst (big construction/industrial) offenders in terms of code violations.

Boilers, Pressure Vessels, and Refrigeration, Elevating, Gas Institution/equipment owner


Will the BCSA be reviewing the need to post certificates in the workplace as they are not being supplied by the BCSA? I disagree with the BCSA not providing a proper sealed certificate. Electronic certificates are fine but they do not show the hard work and dedication which many Power Engineers put into obtaining them.

Origin at Longwood Reasonable / Supportive

At the very least it gives us some assurance that there is governance

Manufacturer in Boilers, Pressure Vessels, and Refrigeration


Is this being pushed by industry? Are employers asking for power engineer qualification standards? I'm not directly involved so it's hard for me to effectively comment.

bc hydro Unreasonable / Strongly opposed

BIGGEST MONEY GRAB YET. To charge someone every few years for something they spent so much time on and money is ludicrous. It’s like you just like making new rules for no reason some times. Most of the material I studied is completely irrelevant to my job. So after 3 years most of the garbage I learned is useless and flushed from my head. I work 12hr shifts and know my plant inside and out the experience I've gained working compared to reading the poorly made PanGlobal books is no comparison. It should be up to the plant manager if the person isn't competent in their job not more government meddling. MONEY GRAB authority





I am unclear about the justification or value in forcing practicing power engineers to regularly recertify. I have a second trade certification that does not require regular recertification, and am wondering why power engineers will need to recertify.



Given the level of responsibility the renewal fee is reasonable. More to the point, the increase should more readily enable BCSA to monitor the qualification.

Industrial user Somewhat unreasonable / Opposed

The rationalization used by BCSA for the new certificate was to help their administration and to keep track of the power engineers working. It sounds like a flaw in BCSA's administrative role and now they want the users to pay for it.

Facilities maintenance at BCHydro sites


Strongly opposed



I view any new fees as a cash grab from the Safety Authority because it has been under funded by the Province.



Seems to be in line with fees

Boilers, pressure vessels & refrigeration union / association


I earned this certificate and payed good money to do so already. You make enough money from your tests every year, and the government can afford to give you more money.



canada bread Unreasonable / Strongly opposed

concept was nonsense, re:3 year renewal of boiler certificate- how does having a 3 year renewal make the system better?Will the applicant be tested every 3 years, or is it just a cash grab?Trade tickets are for life, unless you want to make power engineer a non trade. how does a 3 year cash grab improve your data base? Do you not already know who is a power engineer in this province? Will "active power engineers" be required to upgrade to keep their certificate, or just pay a fee, and non engineer government workers suggest improvements. If power engineer is to be thought of as a trade, it should be a permanent endorsement, not some phony pay as you go, certificate for sale government program. This proposal is a joke, kind of like the current safety authority.



Just more taxes



Once you have the certification it should be valid for life like all other trades

Canfor Pulp Ltd. Reasonable / Strongly supportive

It’s about time that the BCSA entered into the same tracking format used by the other provinces. The information needs to be shared so that we all have an idea as to how many PE’s are employed/ticketed in BC.


COMMENTS ON THE PROPOSED INTERNATIONALLY TRAINED WORKERS PORTFOLIO ASSESSMENT

Company Reasonability/Support Comments

for internationally trained workers

for Canadian trained workers

for Canadians with international experience


Neutral / Neutral

Neutral / Neutral

Neutral / Neutral

Not my area of expertise



Somewhat reasonable / Unsure


Assessment should be available to individuals where required, therefore a reasonable fee.

BC Forest Discovery Centre

Neutral / Neutral

Neutral / Neutral

Neutral (reasonability)

I do not have enough knowledge to comment on this scenario





A 30% jump in evaluation fees seems unreasonable to me. While I support a hourly rate for evaluating international work I find $240.00 a high rate.

Power engineer Somewhat unreasonable / Supportive


Somewhat unreasonable / Supportive

The $1390 appears quite high compared to other jurisdictions.





I don't agree with this policy at all. No one who can't pass the exam should be given a ticket in Canada. Inter-provincial equivalency is bad enough. I have a 2nd class guy from the East coast who can barely do the job of a 5th class. No knowledge, no demonstration of ability, nothing. No test, no ticket.

Viterra Somewhat unreasonable / Opposed



We need to avoid financial encumberences to immigrants being certified. BCSA should reconsider this process as being reflective of a fair way to assess skill level


COMMENTS ON THE PROPOSED INTERNATIONALLY TRAINED WORKERS PORTFOLIO ASSESSMENT





Yes, I think it is reasonable to have qualification assessment of internationally trained workers and Canadian trained workers with international experience only. However, if the Canadian worker has Canadian and international experience then there should be no need for assessment fees.

canada bread Somewhat reasonable / Supportive


Neutral / Neutral

International workers, in my opinion, are less well trained than through the Canadian system, and this is based on personal experience, not a survey. A proper assessment of their work history is important, I do not think this is currently done well, this could be improved. As for existing, Canadian trained engineers, I am totally opposed to any fees to maintain their certificate. I took the courses, got the firing time, and worked in the trade for most of my life, how is a 3 year renewal fee going to improve anything?





Just a money grab

Canfor Pulp Ltd. Neutral / Supportive



I am not supportive of internationally trained PE's coming into BC in any way, shape or form. I've heard the screening process will be arduous and something that a BC PE may have trouble making it through which should keep the numbers down considerably. At the end of the day, knowing how many PE's we have practicing and licensed in BC should drive the overall number of screened individuals, not some "perceived" shortage of PE's.


ADDITIONAL FEEDBACK

Company Comments


There needs to be a better dialogue with industry, in some areas I think BCSA believes they are adding to the safety of the province but they are focusing on the minutiae and not truly impacting the system safety, although they are busy they are not effective.


A minimal increase of 2% per year up to 2020 is lower or in-line with the European fee schedule.

Marker Electric I find the price for the 0-$250 permit to be very over priced. For example, if a customer buys a $15 used light fixture to replace a damaged one that will take me 15 minutes to install (which I would only charge $30 for) I have to explain that I will also charge them over $50 for a permit to do so. This nearly always results in a homeowner telling me "not a chance" and then, I will have to assume, either doing it themselves or getting someone else to do it without a permit. I would like to see either light fixtures mounted on an electrical box in residential detached dwelling be exempt from the requirement of a permit, or an altering of the fee schedule to include a $0-$100 level that would still require a permit, but would have a cost of zero. If I do work, it is covered by my insurance. And at this cost level, the price of a permit drives customers who are most in need of quality electrical work away.

A service provider in electrical

Freeze Fees

Rainbow Electric The problem with asking contractor in good standing is we are doing things correctly . The fringe element , strata companies , home handy companies etc are doing a large segment of 'easy' jobs , change baseboard heaters , change lights . These are the companies who are doing work , contractors should be doing , they are not insured and doing their part .


Education and enforcement should be the pillars of the BCSA


ADDITIONAL FEEDBACK

AES Engineering I have been frustrated over the years since BCSA took over the role of enforcing the several technologies they have authority but I believe philosophically that this is the role of Government and not as a separate private Safety industry with all the salary expectations of Private sector administration compensation that come with it. Safety officers are highly skilled and as such expect that their compensation is competitive with a project superintendent in the trade they work in. I know of more than a few electricians that earn more than $150,000.00/ year. (yes OT is part of that number) Given the cost of good technically superior safety officers, adding large administration salaries is expensive such that the emphasis at BCSA looks to be revenue and that makes little sense especially during fat years when the number of permits should be high. Increasing costs has already tipped the scales toward permit avoidance based more on cost than a resistance to get a permit and pay a rational fee that recognizes a component of service, which includes actual inspections over Authorizations. We also expect to see prosecutions and penalties for permit avoidance especially for those performing work without qualifications.

A service provider in boilers, pressure vessels & refrigeration

Stop the carnage. If the big box stores want to sell gas fired equipment and the homeowner installs it without taking out a permit, there should be ramifications. Set up a system where the store has to report the sale somewhat like your appliance decals. You will have the name and address to check on a permit.

BC HYDRO How do you budget extra work that you provide working with BC Hydro ... that is a very important aspect of your service - working with utilities?


The BCSA is increasing fees gradually, which is better than the MAJOR jump in BC Hydro fees this April, but still hard to take with these fees going up when wages and hourly rates are being cut in order to compete with fly-by-night electricians doing work illegally. In the Northern areas of BC, we have 2 (two) safety officers to cover a massive territory that they cannot ever be expected to cover just the permitted work, let alone investigate the un permitted work. If the fees are to increase, then have more officers to force people to do things by the book or be put out of business. That being said, there are many unemployed electricians right now that do not have an FSR or a contractors license that are doing work under the table for less than wages to supplement their EI, if they're still getting it...how do we compete with that??? In order to have a level playing field in the North, it would seem there is a staffing issue that needs to be addressed. Perhaps a whistle blower line similar to the Crime Stoppers program, where a suspected infraction can be called in anonymously. Unless there is another suggestion/idea to stop the unpermitted work...


ADDITIONAL FEEDBACK

Power engineer The regulations require that an original Power Engineer Certificate of Qualification be posted in the workplace, but the proposed changes include no longer issuing a paper Certificate of Qualification. Will a printed version of the electronic Certificate be adequate to meet the regulation requirement for posting a Certificate in the workplace?

Homeowner If it is not broken, don't fix it. It seems to me that a lot of the new regulations coming out today, seem to add a substantial cost to the home owner, with a minimal increase to safety. Example one.- arc fault breakers for all plug ins. This added $500.00 to my renovation with a very minimal safety increase. Example # 2. Smoke detectors, I now have four smoke detectors within ten feet of each other.


Your web site is not really user friendly. Far to much jargon and it does not appear to be designed from the perspective of someone who is not familiar with the act and what to look for. For instance If I did not know that a water slide was an Amusement device I would not know where to look for the information on your site.


Since the Safety Authority was privatized I have seen numerous increases to fees and very little increase to service. The addition of website access is good, but I have not had much luck in using it. It takes quite a bit of time to get set up and I can't seem to consolidate all of my assets into one login.


It all seems reasonable to me.

SM Electric Most of the new El Code does not make Sense !!!


Legitimate contractors are being undercut by those who don't take out permits and work under-the-table. It's the honest people that pay and get penalized, yet the people who work on the sly keep getting away with it with no penalties.

End user - Manufacturing/Maintenance Industry Company

Whether it is BCSA salary increases, permit fees, hiring plans, marketing, selections of sites for inspection, etc., one hopes that every decision BCSA makes is considered in the context: "Does this make BC safer?"

VJLS-JH Provide an options for one consolidated bills for all permits within the same building/premise, instead of sending invoices for each individual equipment.


ADDITIONAL FEEDBACK

John Sadler Plumbing & Heating Ltd

I think the gas inspectors and safety authority are doing a good job, but the gas fitting industry is becoming a bit of a mess for a number of reasons, mostly due to people working with gas that shouldn't be.

Graham Johnson After all we are all partners?


I would like to see the same level of enforcement across companies - for example, we take elevators on maintenance from other companies and prints / car top data tags are missing, there are no records of maintenance / service, etc.. There should be a level playing field, not multiple sets of rules.


I really didn't know what the Safety Authority's mandate is. I saw its work as applying another tax - every year we pay fees to operate an elevator and never hear much from the Safety Authority. We bought the Canada Safety Council standard for elevator maintenance so we could evaluate the maintenance program we buy. I was disappointed that we had no guidance on elevator maintenance from the Safety Authority other than a statement that we are required to maintain our elevating device. As responsible building owners, we have had an elevating equipment maintenance program for longer than the Safety Authority has been in existence. However, we buy what the maintenance company offers us with no guidance from the Safety Authority on what we need. I hope the Safety Authority doesn't put a lot of information on its web site and assume that people will look for it. That approach is not proactive, and I expect that our fees should at least pay for a program advising us of what we should do to be in compliance.

Brodan Industries Ltd

Like I mentioned in the previous feedback. The professional sector of property Management operations need to be brought back into compliance, with the use of operating permits. Most companies do not use qualified personal for repair and installations. There is no bite or penalties so they will continue. If operating permits are required for all commercial buildings then it should be enforced. They need to have letters sent by the ministry letting them know that they need to comply. My rant. It’s hard to be beat on cost, to a handy man, with no credentials. Just a cheaper price.


ADDITIONAL FEEDBACK

Owner/operator in boilers, pressure vessels & refrigeration

I am writing to express my concern with the BC Safety Authority and their plan to implement expiration dates and renewal fees for operating certificates. I find it incredibly disturbing that since the Provincial government has contracted out this operation we’ve seen steady increases in unsubstantiated fees, all implemented since the BCSA came into operation. Now, we are being told that all operating certificates will have regular expiration dates and will need to be renewed, with an eventual fee applied. I see this as nothing more than a greedy money grab by a mismanaged company that is flailing to stay afloat. In our industry, we continually struggle to find qualified operators. We have had to implement an internal training program, at great cost to our local government, in order to maintain day-to-day operations with qualified operators. The newly planned fees will only make it more difficult to find and retain operators. Instead of finding a proper solution to their funding issues, the BCSA is choosing to pass along the cost to the operators. This, in turn, will cause a substantial shortage of operators throughout the industry and the BCSA will be left to find a new line of funding once again. This plan is so short-sighted, it is baffling to me how this plan came to fruition in the first place. I sincerely hope the BCSA is prepared for the backlash that is coming from the operators and their employers over this ridiculous proposal. Unfortunately, from the lack of thought that went into this idea, I cannot believe there is any kind of hope for the future of the BC Safety Authority.

Service provider in boilers, pressure vessels & refrigeration and electrical

I would like to see Contractor fees extended to a 3 to 4 year renewal process - just like renewing a driver’s licence. Yearly renewal is very costly especially from an administration function . Saving could be had if renewal was once every so often as opposed to renewing each year.


I have enjoyed the notices that I receive from BCSA especially the safety updates.

Epscan I feel that the fees should be on a linear scale not the exponential one that is currently in use or that the project cost divisions should be adjusted to normalize the curve for the existing fees. For reference I am only considering the Electrical fees in my comments.


power engineers who are already certified should not ever have to pay another fee.


ADDITIONAL FEEDBACK

Gas Contractor/commercial gas fire feature manufacturer

What I find most concerning is the amount of feedback this forum has generated that is NOT in support of what you're proposing (in a number of technologies), that was an eye opener for me and should be for the BCSA as well. Clearly there's a disconnect.


I note some gas fees went down. The current "rating" of (electrical) contractors based on inspections of work in determining the best use of inspectors time is a good one.

bc safety authority fee consultation 2018-2020 verbatim ......bc safety authority fee consultation...

Documents