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Te Kāhui Whaihanga submissions

Te Kāhui Whaihanga frequently prepares submissions to relevant government bodies and local councils, giving our members a collective voice around issues relating to architectural practices and impacts on our cities, towns and natural environments.

2023

MBIE Options Paper: Building Consent System

The Ministry Business, Innovation & Employment (MBIE) is seeking feedback on its Options Paper: Building Consent System.  The Options Paper follows MBIE’s release in 2022 of an issues discussion document alongside of a policy position statement on risk, liability and insurance in the building sector.  

You can download the PDF version of the MBIE Options Paper here. 

A copy of the Institute cover letter and submission can be found here.

For more information about Te Kāhui Whaihanga and this submission, please contact Teena Hale Pennington, Chief Executive on thalepennington@nzia.co.nz or 027 527 5273.

 

Consultation paper: Draft Incorporated Societies Regulations 2023 and proposed 'initial fees' under the Incorporated Societies Act 2022

Ministry Business, Innovation & Employment (MBIE) is seeking feedback on an exposure draft of the Incorporated Societies Regulations 2023 and initial fees to be charged under the new regime.  You can download the PDF version of the MBIE consultation document here.

A copy of the Institute submission can be found here

For more information about Te Kāhui Whaihanga and this submission, please contact Teena Hale Pennington, Chief Executive on thalepennington@nzia.co.nz or 027 527 5273.

 

Released for discussion
Review of key industry documents under review SCC 2023 and DZ3910

Te Kāhui Whaihanga New Zealand Institute of Architects (NZIA) is proactively releasing its comparison of the key documents currently under review, Standard Construction Contract (SCC 2023) and DZ 3910:2023 Conditions of contract for building and civil engineering construction (DZ 3910). Click here for a copy of the Institute’s discussion document.

This document is released for discussion and represents the Institute’s thinking currently, and we welcome feedback to practice@nzia.co.nz

The document may be updated over the next few weeks, and is likely to be the basis of NZIA’s response to Standards New Zealand on the Consultation Draft of DZ3910. Members and others are welcome to make use of the points and suggestions made in this document in their responses if they wish.

For more information about Te Kāhui Whaihanga and this submission, please contact Teena Hale Pennington, Chief Executive on thalepennington@nzia.co.nz or 027 527 5273.

 

Occupational regulation reforms in the building and construction sector

The Ministry of Business, Innovation and Employment (MBIE) has sought feedback on occupational regulation reforms in the building and construction sector. The reform of occupational regulation is part of a series of changes to the wider building control system, called Building System Reforms. 

You can read the consultation documents here. A one-page summary can be found here.

Our submission is here

The Schools of Architecture also collaborated on a submisson. You can read it here.

The submission from our emerging professionals - Emerge members can be found here.

The submission from New Zealand Registered Architects Board can be found here.

Occupational Regulation Reforms - Summary of Submissions can be found here.

Occupational regulation aims to protect the public from harm by ensuring services are performed with reasonable care and skill. MBIE want to ensure occupational regulation is fit for purpose and is moving towards a consistent approach across the sector where appropriate. Statutory reviews and previous consultations have identified some areas for improvement in the current occupational regulation regimes.

The four (4) occupational regulation regimes MBIE sought feedback on were:

• Licensed Building Practitioners, including proposals for change regarding supervision and licensing, as well as seeking feedback on issues with competencies.
• Plumbers, Gasfitters and Drainlayers and Electrical Workers including consulting on the scope of codes of ethics to help lift the quality of the work and promote public confidence.
• Registered Architects, including a review of the current settings to determine if the regime is still fit for purpose.

Registered Architects are highly skilled professionals whose design expertise, professionalism and technical knowledge are relied upon to design, innovate and manage construction and infrastructure projects, across a variety of scales and complexity. The profession’s Code of Ethics (established by the Registered Architects Rules 2006, part 3) and the minimum standards for registration defines the profession, setting it apart from other occupations within the building industry, which have only recently introduced Codes of Ethics and codes of practice prepared by membership organisations.

For more information about Te Kāhui Whaihanga and this submission, please contact Teena Hale Pennington, Chief Executive on thalepennington@nzia.co.nz or 027 527 5273.

2022

Review of Building Consenting System

MBIE is consulting on a review of the building consenting system. You can read the consultation documents here.

Our submission is here.

This is a once in a generation opportunity that will shape the future of the construction sector. It is essential that the questions asked by MBIE are far reaching, not artificially limited by how we’ve always done things and focused on outcomes that deliver high quality and performing buildings, a well-functioning sector and a system that is easy to operate and cost effective to maintain.

Our members offer a wealth of experience and knowledge on the current system and are passionate about creating a better system for the future.

For more information about Te Kāhui Whaihanga and this submission, please contact Teena Hale Pennington, Chief Executive on thalepennington@nzia.co.nz or 027 527 5273.

Building Code update 2022: Transition period for the energy efficiency of housing

MBIE is consulting on a proposal to extend the transition period for Acceptable Solution H1/AS1 and Verification Method H1/VM1 Fifth Editions (first issued on 29 November 2021) for housing. You can read the consultation document here

Our submission is here

For more information about Te Kāhui Whaihanga and this submission, please contact Teena Hale Pennington, Chief Executive on thalepennington@nzia.co.nz or 027 527 5273.

 

2021

Resource Management (Enabling Housing Supply and Other Matters) Amendment Bill

This bill amends the Resource Management Act 1991 to rapidly accelerate the supply of housing where the demand for housing is high.

Our submission.

Other relevant documents:
PwC and SensePartners (October 2021), Cost Benefit Analysis of proposed Medium Density Residential Standards

Ministry for Environment, Intensification Options Fact Sheet

Regulatory Impact Statement: Bringing Forward the Upzoning of Land for Housing

For more information about Te Kāhui Whaihanga and this submission, please contact Teena Hale Pennington, Chief Executive on thalepennington@nzia.co.nz or 027 527 5273.

 

Inquiry on the Natural and Built Environments Bill: Parliamentary Paper

This inquiry is the first part of reforming the resource management system, and replacing the Resource Management Act 1991 with three pieces of legislation. The purpose of the inquiry is to provide feedback to the government on the extent to which the provisions in the exposure draft of the Natural and Built Environments Bill will support the resource management reform objectives. A copy of the Terms of Reference can be found here.

Our submission

Other relevant documents:
Summary of Initial Impact Analysis of RM Reform
Provides a summary of the impacts identified at this stage of the reform process. It is not a Regulatory Impact Statement and is not designed to meet Regulatory Impact Assessment requirements.

Interim regulatory impact statement: Reforming the resource management system
This Interim Regulatory Impact Statement provides Ministry for Environments initial advice on how to implement the Resource Management Review Panel’s (the Panel) proposals in a way that best achieves the reform objectives.

Parliamentary Paper on the Exposure Draft of the Natural and Built Environments Bill

Natural and Built Environments Draft Exposure Bill

For more information about Te Kāhui Whaihanga and this submission, please contact Teena Hale Pennington, Chief Executive on thalepennington@nzia.co.nz or 027 527 5273.

 

Solving the Building Consenting Trilemma

During August to October 2020, Te Kāhui Whaihanga hosted a CPD event, Solving the Building Consenting Trilemma was hosted in 11 locations, with the support of Jacobsen. More than 500 members had the opportunity to participate and engage in this important professional conversation about how to ensure greater certainty, consistency, and affordability in the building consenting process.

The three perspectives of Client/Contractor, Architect and Building Consenting Authority provided important context and perspectives for these discussions. Many positive and thoughtful suggestions and improvements were identified and are included in the summary. These key insights are being shared with local councils, Local Government NZ and Construction Sector Accord to facilitate change.

Read a PDF of the summary.

For more information about Te Kāhui Whaihanga and this submission, please contact Teena Hale Pennington, Chief Executive on thalepennington@nzia.co.nz or 027 527 5273.

 

Building (Building Products and Methods, Modular Components and Other Matters) Amendment Bill

The Ministry of Business, Innovation and Employment (MBIE) has been consulting on proposals for regulations to support the Building (Building Products and Methods, Modular Components and Other Matters) Amendment Bill.
Essentially, the proposals included in the Bill will create:

• New product information requirements to make sure basic information about building products and how to use them is available to users.
• A new voluntary modular component manufacturer scheme to make consenting more efficient for some manufacturers of homes and modular building components that are built off-site.
• A strengthened CodeMark scheme to build confidence in the scheme and to provide confidence that innovative building products and methods do comply with the Building Code.

Please refer to the MBIE discussion document for more detailed information.

Read a PDF of our submission.

For more information about Te Kāhui Whaihanga and this submission, please contact Teena Hale Pennington, Chief Executive on thalepennington@nzia.co.nz or 027 527 5273.

 

Building Code Update 2021 - consultation

Every year the Ministry of Business, Innovation & Employment (MBIE) consults on the Building Code and selected acceptable solution and verification method documents, providing an opportunity for the public and the building and construction sector to have their say on the proposed changes. This year, MBIE sought views on proposals for acceptable solutions and verification methods relating to Building Code clauses B1 Structure, E2 External Moisture, G7 Natural Light and H1 Energy Efficiency.

The most significant proposed changes to the Building Code aim to:
• increase the number of climate zones to six, to better reflect the weather in different parts of New Zealand 
• change the amount of insulation needed in homes and buildings across the country, depending on where the building is located
• introduce a new verification method to ensure heating, ventilation, and air-conditioning systems in commercial buildings are designed and installed to reduce the load on the national grid
• ensure complex buildings over three storeys, such as high-rise buildings and apartments, have enough natural light.

Further information on the proposed changes are included in MBIE’s consultation document (PDF).

Read a PDF of our submission.

For more information about Te Kāhui Whaihanga and this submission, please contact Teena Hale Pennington, Chief Executive on thalepennington@nzia.co.nz or 027 527 5273.

 

Incorporated Societies Bill

A draft Bill to replace the Incorporated Societies Act 1908 was introduced to Parliament on 17 March 2021. The Bill had its first reading on 6 April 2021. The purpose of this Bill is to put in place a modern framework of basic legal, governance, and accountability obligations for incorporated societies and those who run them.

Te Kāhui Whaihanga was invited to make a submission on the bill. 

For more information about Te Kāhui Whaihanga and this submission, please contact Teena Hale Pennington, Chief Executive on thalepennington@nzia.co.nz or 027 527 5273.

Read a PDF of our submission

Read the draft Bill on the Parliament website

 

He Pou a Rangi Climate Change Commission - 2021 Draft Advice for Consultation

The Climate Change Commission's first package of draft advice to government on Climate Action for Aotearoa was released for public submissions. Consultation opened on 1 February 2021 and closed 28 March 2021.

Te Kāhui Whaihanga supports the objectives of the Climate Change Commission and the Commission’s willingness to engage with the construction industry on multiple occasions. While we take a different view to the Commission on some issues, we greatly appreciate the opportunity to discuss these differences in an open and constructive manner.

Read a PDF of our submission.

 

Supplementary documents

•  Draft Advice Report
This report contains the draft advice of He Pou a Rangi – the Climate Change Commission. It includes advice on the first three emissions budgets and on policy direction for the Government’s first emissions reduction plan.

 • Executive Summary

 • Evidence Report 
This report accompanies the Commission’s draft advice report. This report sets out the detailed evidence that we have drawn upon to support the development of our recommendations and advice.

 • Consultation Questions
The Commission released a set of key questions it was asking all New Zealanders to provide feedback on.

 

For more information about Te Kāhui Whaihanga and this submission, please contact Teena Hale Pennington, Chief Executive on thalepennington@nzia.co.nz or 027 527 5273.

 

2020

Building for Climate Change: Transforming operational efficiency and reducing whole-of-life embodied carbon

Te Kāhui Whaihanga was invited to make a submission on the first public consultation under the new Building for Climate Change programme – the building and construction sector’s contribution to New Zealand’s goal of net zero carbon emissions by 2050.  

The Ministry of Business, Innovation and Employment (MBIE) has set out three main objectives to increasing a building’s operational efficiency:

1. Reduce operational carbon emissions

2. Reduce water use

3. Improve the health and wellbeing of occupants by improving buildings' indoor environmental qualities (IEQ).

MBIE proposal documents:

• Transforming Operational Efficiency

• Whole-of-Life Embodied Carbon Emissions Reduction Framework.

Read a PDF of our submission

 

The Construction Industry Council also made a submission on the proposals. Read a PDF copy of its submission.

All correspondence should be addressed to Teena Hale Pennington, Chief Executive.

 

Building (Building Products and Methods, Modular Components, and Other Matters) Amendment Bill

Te Kāhui Whaihanga | The New Zealand Institute of Architects was recently invited to make a submission on the Amendment bill. This bill follows on from the MBIE Discussion Paper – Building System Reform in April-June 2019.

Key changes in the Bill will:

• introduce minimum information requirements about building products to support better and more efficient decision-making;

• introduce a specialist framework for modern methods of construction such as offsite manufacturing and prefabrication and speed up the consenting process;

• strengthen the product certification framework (CodeMark) to improve trust and confidence in the scheme; and

• introduce new offences and penalties to support product information requirements and modern methods of construction.

Read a PDF copy of our submission and the Amendment Bill.

Additional resources and fact sheets are available:

Product certification (CodeMark)
Product information
Modern Methods of Construction (MMC)
Offences and penalties, building levy and time to lay charges


All correspondence should be addressed to Teena Hale Pennington, Chief Executive.

 

Urban Development Bill

Te Kāhui Whaihanga | The New Zealand Institute of Architects was recently invited to make a submission on the Urban Development bill. This bill follows on from the Kāinga Ora–Homes and Communities bill, which disestablished Housing New Zealand and set up a Crown entity in the same name.

The bill would enable Kāinga Ora to facilitate these projects, which are called specified development projects (SDPs). SDPs are intended to improve urban development outcomes through a mix of housing types, transport connections, employment and business opportunities, infrastructure, community facilities, and green spaces.

The bill would give Kāinga Ora:

 • access to a tool-kit of development powers when undertaking SDPs
 • access to land acquisition powers when undertaking SDPs.

Attached is a copy of the Institute submission and the Urban Development bill.

All correspondence should be addressed to Teena Hale Pennington, Chief Executive.

 

2019

Copyright Act (1994) review

The Government is reviewing the Copyright Act 1994. Copyright refers to the exclusive rights given to owners of original works such as literature, artistic works, communication works (eg, broadcasts) films and sound recordings.
In our submission, we argue the current review of the Copyright Act is an important opportunity for the creative work of an architect to be recognised. 

Further information on the proposed changes are included in MBIE's Issues Paper (PDF). 

Read a PDF of our submission

For more information about Te Kāhui Whaihanga and this submission, please contact Teena Hale Pennington, Chief Executive on thalepennington@nzia.co.nz or 027 527 5273.

 

Government Model Contract – ‘refresh’

The New Zealand Institute of Architects was recently invited to make a submission on the Ministry for Business, Innovation and Employment (MBIE), Government Model Contract – ‘refresh’ – public consultation.

The Government Model Contract templates are being refreshed to ensure they are up to date with current procurement Rules, and new elements such as Broader Outcomes.  The new templates are proposed to be finalised and issued in November 2019.

In response to the issues raised by the GMC templates, the NZIA and ACENZ partnered on a submission.  The joint submission noted that the GMC contract was inappropriate for the procurement of professional services (i.e. architects and engineers) and requested MBIE make appropriate references in the templates and the information provided to Government agencies.

Attached is a copy of the NZIA/ACENZ submission and the MBIE public consultation document. 

All correspondence should be addressed to Teena Hale Pennington, Chief Executive.

 

Kāinga Ora – Homes and Communities Bill

The New Zealand Institute of Architects was recently invited to make a submission on the Kainga Ora – Homes and Communities Bill and to present to the Environment Select Committee on 17 July 2019.

The NZIA was represented at the Select Committee by Chief Executive Teena Hale Pennington and NZIA Distinguished Fellow and Past President, Richard Harris.

Set against the backdrop of New Zealand's urban area pressures – population growth, an ageing population, a housing shortage and changing housing preferences – the long-awaited urban development authority bill was introduced to the House on 29 May 2019.

The Bill had its first reading on 30 May 2019 and is intended to come into force on 1 October 2019. 

The Bill establishes Kāinga Ora – Homes and Communities as a Crown Entity. Kāinga Ora – Homes and Communities will subsume existing central government capabilities, including HLC, Housing New Zealand, and some of the functions and assets of KiwiBuild, noting that the Land for Housing Programme will not be immediately transferred to Kāinga Ora – Homes and Communities.

The Bill also provides that the Minister must introduce a Government Policy Statement on housing and urban development to promote housing and urban development system that contributes to the current or future well-being of New Zealanders. The following documents are available to download:

All correspondence should be addressed to Teena Hale Pennington, Chief Executive.

 

Building System Legislative Reform Programme

The New Zealand Institute of Architects was recently invited to make a submission on the Ministry for Business, Innovation and Employment (MBIE), Building System Legislative Reform Programme – public consultation. This consultation seeks feedback on changes in five areas: building products and methods, risk and liability, occupational regulation, the building levy, and offences, penalties and public notification.

NZIA Members across the country have actively contributed to the development of the submission. Attached is a copy of the NZIA submission and a copy of the MBIE public consultation document. All correspondence should be addressed to Teena Hale Pennington, Chief Executive.

2018

The NZIA supports a new connectedness between government departments, institutions, agencies, professions and the public, and wants to support KiwiBuild by taking a leadership role on issues of architecture, design excellence and the built environment (May 2018).

 

2015

Building Act Emergency Management Proposals

The New Zealand Institute of Architects was recently invited to make a submission on the Building Act Emergency Management Proposals – Consultation Document. Members of the NZIA Resilience Working Party have actively contributed to the development of the submission. Attached is a copy of the NZIA submission and a copy of the Consultation Document. All correspondence should be addressed to Teena Hale Pennington, Chief Executive.

 

Buildings (Earthquake-prone Buildings) Amendment Bill

The New Zealand Institute of Architects was recently invited to make a supplementary submission on the Buildings (Earthquake-prone Buildings) Amendment Bill, given the previous NZIA submission on the Bill. Attached is a copy of the NZIA submission and the interim report of the Local Government and Environment Committee, which includes a copy of the revision tracked version of the bill and a report summarising the proposed changes. All correspondence should be addressed to Teena Hale Pennington, Chief Executive.

 

Australian Productivity Commission – Review of Trans-Tasman Mutual Recognition Arrangement

The New Zealand Registered Architects Board (NZRAB) was recently invited to submit on the Trans-Tasman Mutual Recognition Arrangement.  The Commission was particularly interested in improvements in the movement of skilled workers, reduction in red tape and opportunities for single occupational registration.  The final report will be presented to the Australian Heads of Government and the New Zealand Prime Minister in September 2015. If you have any further questions on the NZRAB submission, please contact Paul Jackman, Chief Executive, New Zealand Registered Architects Board.

 

Submission on Standards and Accreditation Bill to Commerce Committee

Attached is a joint submission made by the Institution of Professional Engineers New Zealand (IPENZ), the Association of Consulting Engineers New Zealand (ACENZ), the Institute of Public Works Engineering Australasia New Zealand Division (IPWEA NZ) and the New Zealand Institute of Architects (NZIA) on the Standards and Accreditation Bill. All correspondence should be addressed to Teena Hale Pennington, NZIA Chief Executive, Kieran Shaw ACENZ Chief Executive and Kieran Devine IPENZ Interim Chief Executive.

 

2014

Submission on Proposal to change the occupational regulation of engineers in New Zealand 

Attached are the Institute and the New Zealand Registered Architects Board (NZRAB) submissions on the proposals document, Proposals to change the occupational regulation of engineers in New Zealand. The Institute submission has been developed and discussed with the NZRAB and Institution of Professional Engineers in New Zealand (IPENZ). The Institute advocates that like Chartered Professional Engineers (CPEng), Registered Architects should be the other professional deemed appropriate for commercial and multi-storey/multi-unit residential development.  To support this position, the Institute seeks a unified registration system for Registered Architects and Design, Licensed Building Practitioners under the NZRAB registration authority.  All correspondence on the Institute submission should be addressed to Teena Hale Pennington, Chief Executive. Correspondence on the NZRAB submission should be addressed to Paul Jackman, Chief Executive.

 

Canterbury District Council Replacement District Plan

Attached is the Canterbury Branch of the Institute submission on the Christchurch City Council Replacement District Plan - Stage 1, Priority Chapters. Further information on the notified draft plan can be found here. All correspondence should be addressed to the Canterbury Branch Chair, Colin Corsbie

 

Modernising Parental Leave

Attached is the Institute submission on the Modernising Parental Leave - discussion document. The submission has been developed in collaboration with members and Architecture + Women. Flexibility in the workplace and recognising the importance of parental care to new born development is supported by the Institute. All correspondence should be addressed to Teena Hale Pennington, Chief Executive.

 

PAUP Further Submission

Attached is the Auckland Unitary Plan, further submissions. For further information, please contact David Gibbs.

 

Canterbury Branch Submission – Christchurch Central Recovery Plan

Attached is the NZIA Canterbury Branch Submission on Christchurch Central Recovery Plan: A Liveable City - Draft Residential Chapter. For further information, please contact Colin Corsbie, NZIA Canterbury Branch Chair.

 

IPENZ/NZIA Submission: Developing regulations to support the new Health and Safety Work Act

Attached is the joint submission from IPENZ and the NZIA on Regulations to support the new Health and Safety at Work Act. All correspondence should be addressed to Teena Hale Pennington, Chief Executive.

 

New Zealand BIM Handbook and BIM Schedule

Attached is the Submission to the Building and Construction Partnership on the NZ BIM Handbook and Schedule. All correspondance should be addressed to Teena Hale Pennington, Chief executive. 

 

Building (Earthquake-Prone Buildings) Amendment Bill

Attached is the NZIA submission on the proposed Amendment Bill. All correspondence should be addressed to Teena Hale Pennington, Chief Executive.

 

Palmerston North District Plan Change No.13

Submission by the NZIA Western Branch.

 

Auckland Branch Submission on PAUP

Attached is the NZIA Auckland Branch submission on the proposed Auckland Plan. The submission is accompanied by a set of of ward maps.

 

2013

Auckland Council Procurement of Architectural Services

Attached is the Discussion Document on the Auckland Council Procurement of Architectural Services. All correspondence should be addressed to Teena Hale Pennington, Chief Executive.

 

Residential Construction Sector Market Study

Attached is the NZIA Submission to the Ministry of Business, Innovation and Employment on the Residential Construction Sector Market Study. All correspondence should be addressed to Teena Hale Pennington, Chief Executive.

 

NZRAB Rule Change Consultation

Attached is the NZIA submission to the NZRAB on the current rule change. All correspondence should be addressed to Teena Hale Pennington, Chief Executive

 

All of Government Materials Discussion Document Submission

Attached is the NZIA Submission to the Ministry of Business, Innovation and Employment on the Government Materials (AoG) Discussion Document. All correspondence should be addressed to Teena Hale Pennington, Chief Executive.

 

NZIA submission on changes to Acceptable Solutions and Verification Methods

Attached is the NZIA submission to the Ministry of Business, Innovation and Employment. The proposed changes update, replace, or withdraw the references to the Standards cited in the Acceptable Solutions and Verification Methods used to establish compliance with the Building Code. All correspondence should be addressed to Teena Hale Pennington, Chief Executive.

 

Explaining the changes to the Resource Management Act

The Resource Management Amendment Act has now passed into law and can be viewed online. The Ministry has also produced a series of seven factsheets to explain the changes.  See the ministry website for further details.

 

Submission to the Commerce Select Committee on the Contracts Amendment Bill

The NZIA submission to the Commerce Select Committee on the Construction Contracts Amendment Bill. All correspondence should be addressed to Teena Hale Pennington, Chief Executive.

 

AACA Review of National Competency Standards in Architecture

This submission is prepared jointly by the New Zealand Registered Architects Board and by the New Zealand Institute of Architects. The NZIA and the NZRAB thank the AACA for the opportunity to provide initial feedback on the current NCSA.  For further information please contact Chief Executive, NZIA, Teena Hale Pennington or NZRAB, Chief Executive, Paul Jackman.

 

Request for information, All-of-Government provision of consultancy services to government agencies

Attached is the NZIA submission to the Ministry of Business, Innovation and Employment, who are looking to establish an All-of-Government solution for the provision of consultancy services.  The Request for Information applies to 'Architect' consultancy services. Please note that the response due date was extended to 5 July 2013. All correspondence should be addressed to Teena Hale Pennington, Chief Executive.

 

Housing Accords and Special Housing Areas Bill

Attached is the NZIA submission to the Hon. Nick Smith, Minister for Housing on the Housing Accords and Special Housing Areas Bill.  All correspondence should be addressed to Teena Hale Pennington, Chief Executive.

 

 

The document may be updated over the next few weeks, and is likely to be the basis of NZIA’s response to Standards New Zealand on the Consultation Draft of DZ3910. Members and others are welcome to make use of the points and suggestions made in this document in their responses if they wish.