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Avi Barzelai on building permit requirements
For a bathroom renovation
A thread that went viral. You may or may not think each of these regulatory requirements are justified for a small renovation, but it’s valuable to have all of them collected in one place.
The paperwork needed to do a bathroom renovation in Vancouver will:
1.) A SURVEY $2000
Every house renovation, and therefore building permit application in Vancouver requires a survey. Every, single, one. Doesn't matter how small your project is. You could be installing a powder room. Doesn't matter. No survey, no building permit for you!
2.) ENERGY ADVISOR AND REPORT $1500
Every project that costs more than $20,000 requires an energy report and blower door test. Every, single, one. Doesn't matter what type of project you're doing, you need an energy report. No energy report, no building permit for you!
3.) HAZARDOUS MATERIALS REPORT $750
If you're working on a house that was built before 1990, you will need a report from a HAZMAT Qualified Professional, as many materials before that time may contain asbestos.
4.) AN ARBORIST REPORT $750
Every project needs an arborist report. I've tried arguing that section 7.3 of the protection of trees bylaws doesn't require it. They don't care. You can spend weeks arguing with staff, or you can just pay an arborist $750.
5.) A SCHEDULE FROM A STRUCTURAL ENGINEER $750
You could be doing absolutely no structural work, but city staff couldn't tell a structural wall from a partition wall. If you're doing a renovation, best just to submit a letter from an engineer.
6.) DRAWINGS $2000
No need for an architect here. For small renovations a drafter or technologist will do. You can't just submit plans of the renovated area, you will need the entire floor area. Also, a site plan and details. All this for a bathroom. Yup. I'm not kidding
7.) OWNER'S UNDERTAKING LETTER AND BUILDING PERMIT APPLICATION $0
Not a big deal. Just a couple of forms.
8.) ELECTRICAL, PLUMBING, and HVAC Permits $1000 Total
Once you've received your building permit, you will still need to take out electrical, plumbing and HVAC permits. The city says that electrical permits are taking 5 business days, but it's more like 10 right now.
For a simple bathroom, you will need to get a plumbing inspection, an electrical inspection, a framing inspection, possibly an insulation inspection if it's on an exterior wall, and then electrical, plumbing, HVAC and building final inspections.
For a bathroom.
I'm not exaggerating, this is not hyperbole. This is 100% what we have to go through to get a small powder room built in a house.
This is the MINIMUM amount of paperwork required. The larger the project, the more things get added.
I could deal with all the red tape if city staff processed applications in a reasonable amount of time. Of course they don't. You go back and forth with them for weeks on completely meaningless details.
Tell me, after all the consultants involved, what is there left to review?
Joseph Heath, A Defence of Administrative Discretion:
Administrative rules seldom have independent deontic significance; they are instead aimed at achieving some objective. This is usually articulated in terms of the rules having a “point.” And yet there will often be ways of applying the rules that defeats their point (e.g. by being overly literal, or insensitive to circumstances, or by ignoring the interaction with other rules). In some cases, applying the rules too literally can actually work to defeat the point. This sort of formalism – an insistence on following the rules even when doing so does not serve their objective – is the quality of bureaucracy that is most often described as “Kafkaesque.”
This suggests some potential changes:
Make sure that the underlying objective (the “point”) of each requirement is clear. The point of the hazardous materials report is clear. The point of the arborist’s report is to protect trees; enforcing the requirement in this case is pointless.
Corporate culture: staff should be administering each regulation so as to meet the underlying objective, not as an end in itself.
Discretion: staff should have the authority to administer each regulation in a flexible way, backed up by a short written description of their reasoning. Barzelai quotes a section of the bylaw which apparently gives discretion to staff to waive the arborist’s report for an interior renovation … but which requires the approval of the Director of Planning.
Simplification: remove regulatory requirements which don’t pass a cost/benefit test. For an explanation of why this criterion makes sense, see Joseph Heath, Cost-Benefit Analysis as an Expression of Liberal Neutrality.