Comments to the Proposed Changes
Submit a comment
- Mechanical Contractor's Proposal
Click the above link to see what was discussed by several HVAC contractors at a meeting held at the
Southside Hall on May 1, 2008.
- Stephen Balogh letter dated May 23, 2008
- Midland Empire Home Builders Association letter dated June 3, 2008
- D'Agostino Mechanical Contractor's letter dated June 3, 2008
- Email to Sam Barber from Dan Fitzpatrick dated June 4, 2008
- Bill Falkner's letter on licensing dated June 5, 2008
- Standardization Memo to Council dated June 3, 2008
- Jim Giefer, Wachter Electric, letter to Council dated September 12, 2008
- November 15, 2006 and February 13, 2007 Council Work Sessions Comments
OTHER COMMENTS:
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(06/30/08)
Comment: We feel the grandfather clause should cover more areas than just testing. We have been in business for 30+ years with a very good record; therefore I consider that the best test. We have always been licensed and insured. Why should we be punished for those who do not follow the law? Each company should be considered on its own merits.
Response: The proposed grandfathering for general contractors does cover more than just the testing. It also includes most of the experience requirement. In order to qualify for grandfathering, you must have completed at least 3 permits in St. Joseph within the last 5 years within the classification being requested.
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(06/30/08)
Comment: After so many years being in business, the continuing education requirement is ridiculous. Most contractors are so busy earning a living that they don't have time for this. Ron is a 36 year employee of the St Joseph Fire Department. This requirement would be too time consuming and unnecessary since he keeps up with all the changes anyway.
Response: These continuing education requirements were identified during the public meeting in November 2006 and again in February 2007. We also found that every community, that has contractor and trade licensing, has some level of continuing education requirement. Additionally, every other professional licensing program such as lawyers, doctors, real estate agents, engineers, architects, and surveyors, all have continuing education requirements. The reality is that changes in the building standards and the use of materials occur on a constant basis. Most builders and contractors, as you are aware by your own practices, keep up with the current trends through a variety of methods. Unfortunately, the only way to keep this on an even playing field is to identify some general standards that everyone needs to abide by. The intent is not to create a set of rules that are so restrictive that only specific, approved training is accepted but to allow most of the existing training count. Under this proposal, the Contractor Licensing Board or CLB will provide a recommended list of standards for this training to be approved by the customer assistance director. The intent is for the continuing education to be relevant to the contractors license. To keep everyone on the same playing field, certain criteria must be used to determine if the training is adequate. Our desire is to have all training accredited by the International Association of Continuing Education (IACET), to include training provided by governmental entities, trade associations, contractor education providers, and classes provided by post-secondary education institutions or technical schools.
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(06/30/08)
Comment: A person can learn more from hands-on experience than from a textbook. We feel we are being punished for a few. Doesn't a good record and reputation mean anything to the City?
Response: A good record and reputation means a lot, however, it is extremely hard to measure in a reasonable fashion and much more difficult to apply objectively across the board.
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(06/30/08)
Comment: Since I was told this proposed ordinance is a result of some faulty roofing contractors, why go after the General Contractors and those who follow the law?
Response: As indicated above, this proposal is based primarily on input from the building community, a survey of six other communities within the general area and input from the advisory boards and staff. It is not specifically intended to address faulty roofing contractors, even though we have received a few requests to have this proposal expanded to address them specifically.
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(06/30/08)
Comment: We also feel there is an opportunity for bias with the CLB.
Response: The CLB will be appointed by the city council based on recommendations from their constituents, their familiarity with the individual nominee and/or a nominees availability and interest. These appointments will follow the same process and procedure as our current advisory board members do. Will there be bias on the board, absolutely. This is the primary reason for the boards diversity. This board is intended to be a representative board and it is presently being reviewed to ensure that the design is so structured. Will it be perfect? No. But we believe it will be fair and reasonable. Please keep in mind that this board cannot make any changes to the program. Only the city council can change the ordinance.
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(06/30/08)
Comment: When is it the City's responsibility to oversee the proper hiring of a contractor? It is the homeowner's responsibility to ensure that the contractor is licensed, insured and has the proper permits. They should also call the Better Business Bureau and check the contractor's complaint record.
Response: You are correct. The home or property owner is ultimately responsible. Unfortunately, many owners are not as diligent as we would like them to be either because they are unaware, or they dont understand or they just dont care. Either way, it is our community as a whole who suffers in the long run. We hope that by raising the bar, we can help our citizens avoid some of these problems.
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(06/30/08)
Comment: I urge the City Council to consider some changes to this proposal by not punishing all for the mistakes of a few. We hope the City shows a cooperative attitude towards the businesses that are tried and proven by their work record and reputation.
Response: We hope that this will support our tried and proven contractors by requiring their competition to move up to their level and make it a more even playing field.
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(06/30/08)
Comment: We feel our ability to continue in our present occupation is being threatened and the City is infringing on our way of making a living. We plan on doing whatever it takes to stay in business.
Response: This proposal is not intended to put any qualified contractor out of business. It is intended to raise the bar but not so high that our good contractors cant make it. If there are any requirements that you feel are so burdensome that they would put you out of business, please let us know. We are doing everything we can to develop a program we believe will improve our community, not hurt it. A number of changes have already been made to address concerns expressed to us by various members of our community. For example, several mechanical contractors opposed the idea of not having any grandfathering for the mechanical trade. We now have grandfathering proposed for them. We received various concerns about the requirement that the contractors name and business license be permanently printed on all their vehicles. We have changed this and will only require that the contractors name and at least one of the following, their phone number, contractors license number or the city they are from, be placed only on their work vehicles. They wont even need to be permanent. This is just a couple examples of the changes we have made based on input from our community.
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(06/30/08)
Comment: The City is biting off too much. This is just another example of too much government interference. We do not feel we should absorb the cost (license fee) for an unnecessary ordinance the City feels compelled to enforce.
Response: We understand your concern and frankly, we would not support this proposal if we didnt believe it would add value to our program. The fees being calculated are based on what we believe it will cost us to administer and no more. This is not a fund raising venture. The fees will likely range from $45 to $65 for a new contractors application and around $25 to $30 for their renewals. We hope that the benefits of this program will far outweigh the cost.
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(06/29/08)
Comment: Nice Site!
http://google.com
Response:
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(06/22/08)
Comment: I am very concerned about the proposed changes for contractor licensing. As far as the testing requirement, I feel our company has been "tested" by over 30 years of honest reliable work. I do not feel that a degree should be required. A person can learn more with hands on experience than they can anytime from a textbook. Many famous professional people do not have college degrees,yet they are successful.I object to the exhorbitant insurance. I am very concerned about the motive involved in these drastic changes. I understand the concern for keeping quality work in the city,but I wonder how many inferior jobs were done to justify this kind of drastic ordinance.One wonders if the larger contractors are trying to push this thru and thus get rid of some smaller companies.Also, instead of just "grandfathering" in the application testing, aprovision should be made for a company with say 25+ years experience and a good reputation, to "grandfather" it all in. We feel we're being punished for a few. I feel my rights are being violated and the city is infringing on my ability to make a living and continue in my respected company. I don't feel it is right to issue these changes "across the board". Each company should be considered on its own merits. I urge you to consider some changes to this proposal. I'm sure the city is putting themselves at risk of a lawsuit or class-action should the proposal be adopted.
Response: I fully understand your concern about the changes to our licensing program. Im not sure Im entire clear about your concerns with respect to the proposed testing. Those businesses, who apply and have been working in St. Joseph and completed at least 3 permits in the last 5 years within the licensing classification requested will have the testing and experience grandfathered. The education paragraph under the contractor licensing is stating that if you have a college degree, you will be exempt from having to take the test. This applies to new applicants. As for the insurance, we dont presently require any liability insurance at all and believe we should. This will protect the home and business owner and will help weed out those businesses that cant obtain any insurance because of poor past performance. The recommended rate is what many of the businesses in town, both small and large, have recommended. In talking to some of our local insurance providers, the cost increase for liability insurance is not very much between $500,000 and $1,000,000 as proposed. If I havent adequately answered your questions or if you have any other questions please feel free to email me and I will try to answer them.
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(06/08/08)
Comment: This proposal ignores many of the construction related problems in St. Joseph and seems to offer solutions to problems that don't exist. Any trade licensing and testing that DOESN'T allow for practical testing does a disservice to that trade and it's customers. Trades are taught primarily through work in the field, supplemented with some type of book work. Yet you propose to test applicants only on the bookwork portion of their trade education, ignoring the much more important skills required to safely install most systems covered by our codes. More importantly, while our codes do a good job of portecting the public health and safety in commercial and residential applications, they are totally inadequate in industrial applications where potentially dangerous, even deadly materials are handled in systems installed without any code enforcement or licensing. When will we begin addressing these issues?
Response:
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(06/03/08)
Comment: I don't understand how the city has the resources to correctly manage the proposed changes. Some of these I agree with but the majority are absurd.
Why are roofing and tree cutters excluded from the list? These two professions have the most potential for disaster and often the contractors are hiring illegal workers. While you're at it why not include the lawn mowers and landscape contractors?
Response: Thank you for taking the time to submit your concerns. I agree that this is going to be a tremendous program to manage. Most of our enforcement will be on a complaint basis. We will not have the resources to do any active enforcement. However, this will give us the tools to do something when we do receive a complaint about a contractor who is not properly licensed and/or doesnt have the required permits. Roofs are included under the Class D licensing and will be required to provide liability insurance just like everyone else. Tree cutters already have to provide insurance when they are working in the right of way or could affect the right of way. I am curious as which items you believe are absurd and why. The intent is to establish a program which will meet our communitys needs.
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(05/29/08)
Comment: I have several questions, but I'll address your question first Re NICET ll licensing. The distinction has to do with the industry descriptions, Engineered systems and Pre-engineered systems.
Engineered systems are designed to protect rooms, buildings or storage spaces. Because no two spaces are the
same, an engineer must be on site to design the specifications. These systems include, Fire Alarm systems, water-based systems and Special Hazards Suppression systems. Special Hazards Suppression system agents are chemicals such as, Halon, Halotron, CO2,FE36 and Cleanguard R. (all generally referred to as Clean Agents) There is one brand of water-based kitchen system out there. It does not comply with UL300 and therefore are no longer installed in commercial kitchens. Kitchen fire suppression systems (or paint booths) are not considered Specialty Hazard Fire Systems.
Kitchen and Paint Booth systems are Pre-engineered by the manufacturer and installed by factory trained distributors. UL300 is the newest standard for Kitchen systems and it mandates a wet agent.
NAFED (Natl Asso Fire Equip Dealers) has created the standard for the testing and licensing of technicians who service and install pre-engineered systems as well as portable fire extinguishers.
NICET level ll licensing is the standard for Engineered systems.
Please consider removing the NICET ll license requirement from the kitchen and paint booth system category and replacing it with the NAFED training and license.
Many states accept a certificate of "Factory Trained Distributor" in place of 3rd party training.
FYI, factory distributor certificates, as well as, NADFED's certificates are valid for 3 years. Could you factor that in place of an annual re-testing requirement for the city?
I am quite pleased to see the "bar raised" for our industry, in our city. We will doing everything asked, to comply.
Response: I very much appreciate your interest in this area and thank you for your comments. We will certainly see what changes need to be made to our current proposal so it is more in line with what your industry is doing. That is our intent. Once I get the changes made, I will send you a copy.
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(05/28/08)
Comment: 2.)7-506; This needs simplified; most contractors will not give old employees notarized letters and provide a copy of their license. A letter from the contractor verifying hours should be enough for a Journeyman's license; if not setup this way it may take months for a person to obtain a license; this is not fair to the person seeking employment or the contractor trying to obtain license workers. If a person has past the required test and has proof of hours they should be granted a license, anything less is discrimination against the person seeking employment.
Recommended Change
(3) Journeyman commercial electrician applicant shall provide a letter(s) of
experience from properly licensed master electrician(s), licensed electrical contracting
company(s), or a manpower agency(s).
a. A minimum of 8,000 hours active employment as an electrical apprentice (hours in an
approved electrical apprenticeship program or trade school may be considered for credit
toward the 8,000 hour requirement) or equivalent.
Response: 2) As you are aware, these documentation changes were made at the recommendation of the electrical board. Since then, we have had numerous problems trying to meet the specified documentation requirements, especially for the master electrician to a point where the fees for these licenses are being studied. I agree that we need to simplify the documentation requirements. Im just not sure what is reasonable. Getting a copy of the contractors business license is not as difficult as it seems given that it is public information and a copy can be obtained from the jurisdiction who issued it. Breaking out the hours between commercial and residential can sometime be cumbersome and is something that, although not required, we highly recommended as it is required for the masters application. I will be presenting this issue to the electrical board and city council and identify the cost impact as well.
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(05/28/08)
Comment: Comment: Page 62. Sec. 7-491. Contractor's vehicles. I understand the need for easy identification of contractor's at job sites by inspection and/or emergency personnel. However, the requirement to have at least one company vehicle at the site is flawed. A contractor with multiple jobsites can't be expected to have a company vehicle for each site.
Signs in front of job sites are not logical either.
Recommend a small weather proof envelope or something equal for a sign in sheet for contractors working on site, there they will have to list their Company's name and permit number.
Response: Based on inputs from the building community, this paragraph is being modified to remove the requirement for a yard sign or vehicle to be on site while work is underway. The section number is now 7-492. The items still under discussion are whether:
The vehicle signs must be permanent or if a magnetic sign is sufficient.
What else should be on the sign other than the contractors business name; i.e. phone number, contractors license number and/or city. We are even entertaining the idea of letting it be one or all of these.
We had not thought about this sign in sheet with a list of all the contractors and their permit numbers being posted at the job site. We will consider this recommendation. It would certainly address a lot of concerns.
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(05/28/08)
Comment: 3.) CLB - this is a joke; the City needs to handle these affairs;
I would like to know who came up this ideal and where the information for setting this up came from.
The City is setting themselves up for a major law suit here. If this board is made up of bias individuals and they put contractors out of business - watch out.
Response: 3) I understand your concerns about the Contractors Licensing Board. However, I think it is there to protect the City rather than give it more exposure. First of all, any action taken by the city as sever as suspending or revoking someones right to work in our city should be allowed due process to include the right to appeal. I expect that the city will normally be the ones to take the initial action to suspend a contractor or tradespersons license. They should then have the right to appeal it to a board of their peers. This board is intended to be a representative board so configured to prevent a single individual from having undo influence on the process. I believe the city would be more exposed to a law suite without it than with it. If you notice, all the other duties of this board, with the exception of suspensions and revocations, are advisory in nature. I will ask our legal staff to address your concern as well.
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(05/28/08)
Comment: 1.) How can you deny a person a license just because he took some time off from his/hers; as long as they have the proper credentials they should not be denied (discrimination). Please explain why it is needed:
7-511
The examination shall
be accepted as long as the applicant has provided proof that they have been working in the related
trade and classification from the time they took the exam to the present
Response: 1) This was put in here to prevent someone who had a Journeyman or Master Electrical license 5 or 10 years ago from obtaining a current license without having to re-test. Keep in mind that this paragraph only refers to reciprocity. I will closely review this paragraph and make any changes we might need to clarify its intent. It does not prevent the individual from retesting and providing documentation of the hours of experience even though they were 10 years old. Another example might be an individual who obtained his journeymans license 15 years ago from Topeka, KS. Ten years ago, he married and moved out of town to run work with his wifes familys real estate business. Recently, he divorced and moved back to his hometown of St. Joseph. Now he wants to get back into the electrical trade. Should he be able to obtain a current license without re-testing? If you think he should retest, then how long should a person be allowed to remain out of the trade before they are required to retest?
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(05/26/08)
Comment: I was wondering how this will affect my business as far as manufactured and modular housing is concerned. thanks
Response: You would like need to obtain a Class C contractors license to continue installing your manufactured and modular homes. Your other option would be to obtain a Class D license and hire a Class C contractor to pull the permit and manage the over all installation.
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(05/23/08)
Comment: I recommend that the insurance requirement for a business license be expanded to include liability insurance in the same manner as there is a requirement for workmans comp. If someone sees this as a tax, then let them take it to court. When I went to work in Parkville, I obtained a business license and provide proof of both insurances.
Response: Understand. I will submit your suggestio for consideration. However, I don't see how it is any different from what we are proposing.
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(05/23/08)
Comment: I suggest that the Roofing trade needs to be examined and licensed in the same manner as the other trades.
Response: We could establish a separate license for roofers. Our current proposal does not because we wanted to start out small and expand the program at a later date once we had an opportunity to see how it worked. We will need to consider a variety of specialties when we get to that point not just roofers.
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(05/23/08)
Comment: I believe a 4th category for each trade be added to include a student permit, thus allowing students to enter a trade such as for a summer job. This could add to their hours if they wished to continue on and register as an apprentice.
Response: I think this is a great idea. I've also discussed this idea with the HVAC instructor at Hilliards who suggested we establish an internship program of sort where a high school student could document and get credit for ours worked in a trade. We will pursue this idea and see if we can't include something in this proposal.
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(05/23/08)
Comment: I recommend that the city continue the Contractors Day similar to last year with presentations from the inspectors, as well as trade specialists. This should become a responsibility of the staff of the Conventions and Trades Center who run the Civic arena. Instead of a super board we could have a super Trades convention. This could also incorporate the recently held inspectors meeting that Steve Allen chaired. Thus the continuing ed requirements could be accomplished as well as approved as CAD-D (read staff?) would need to be involved. This could also generate money to self support itself as well as generate $ for the city and involve the trades from throughout the state. This could become a BIG DEAL.
Response: I think this would be an excellent idea and we will look into continuing it this coming fall. We will need your support as well as others in the trade to help develp an agenda for the workshop.
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(05/23/08)
Comment: I see no reason to alter the existing trade boards. They should remain responsible for Examining and Appeals for their respective trades. Peers need to be testing and judging peers. We do not need to continue the Sarbanes-Oxley fiasco by creating a six sigma (CLB) group. We aint Enron.
Response: Understand your concern. I don't necessarily agree but will forward your comments to the City Council.
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(05/23/08)
Comment: I agree that the Mechanical trades need to be examined and licensed in the same manner as the other trades.
Response: We do too and that is what we are proposing.
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(05/23/08)
Comment: I also agree that a Contractors Examining and Appeals Advisory Board should be implemented with the same duties as the other boards, i.e., regulatory regarding appeals and examining for the contractors license as we have for each of the other trades that are licensed/registered.
The composition of the CEA (Contractors Examining and Appeals) Board should include, at a minimum, a representative from each ABC and D groups, as well as have representation/liaisons from each advisory board.
Response: I assume you are suggesting that this board only administer the licensing for the contractors and not the trades. Based on this assumption, I understand your suggestions and will submit them for consideration. There has already been quite a bit of discussion concerning the composition of the this board and I suspect it might change based on the various groups it will represent.
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(05/23/08)
Comment: I suggest that if the community wishes to become a reciprocal community, then the plumbers could look over the IAPMO test and incorporate it into the testing process along with the other current requirements. I would guess that many of our questions cover the same material and that the two tests are quite similar. We might get some ideas from the IAPMO test.
Thus if a person from a reciprocal community wants to test in, all they need to do is complete the remainder of the requirements like we have to do. I believe the plumbing board could proctor the additional testing on an as needed basis.
Response: I apprecite your views on this issue and think they are a resonable alternative to the existing proposal. The only part of this that needs to be addressed is the frequency of this testing and to determine if the additional practical part of the test is worth the cost to our community.
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(05/19/08)
Comment: Just for clarification please, where do sign companies fall in to your proposed changes?
Response: Sign companies will be required to have a Class D, Specialty License. The major requirements in order to obtain this license is liability insurance and the payment of the licensing fee which is still being determined but will likely be under $50 per year. Their work vehicles will also have to have the business name, as a minimum, on the sides. Class D license does not have any testing or experience requirements for new licenses and no continuing education for renewals.
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(04/18/08)
Comment: We fully support the city's efforts to license the HVAC trade.
Response: We also believe it is time to expand our program and appreciate your support. We encourage you to stay involved and if you have any questions or concerns, please call me at 271-5315.
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(04/18/08)
Comment: I believe there is a need to tighten down on the requirement for HVAC duct designs and duct sizing for residential construction.
Response: The Mechanical Board has been struggling with that exact issue. They have not come up with any changes to the code as of yet, but they do want to recommend some changes to the existing program. If you have any suggestions, please share them with us.
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(04/18/08)
Comment: I support the requirement for licensed contractors to have their names on their vehicles. Platt Co. laminates the permits for their contractors and requires that all permits be posted on the job site. This might also help.
Response: We appreciate your support. Our already require that a permit be displayed at the job site. We've discussed enforcing this issue and decided to table it for now because of all these other initiatives currently underway. We encourage you to stay involved and if you have any questions or concerns, please call me at 271-5315.
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(04/17/08)
Comment: In the "general requirements" pages of your presentation I understand you have included the insurance req for class D licenses. I believe It is important to add to all the insurance req that "Work comp as req by the state" be include be added.
Here's why (you may have to call me to decipher this)
Contractor A is an individual, not required by law as a single person to have work comp, who subs-out all aspects of his jobs.
He hires contractor B , who is not req by law to have work comp because he is a single individual or has only one employee, to some aspect of work for him.
By state law Contractor A should pay work comp on Cont B. However since neither contractor A or B are in the system of work comp this is never picked up.
But when contractor B is injured on the job Who is liable because no one is paying work comp I've got A few other thoughts but I'll only give them to you one at a time.
Response: As you can see, we are talking about some significant changes to our building practices. I believe I understand your concern about workmen's comp. insurance. As you're probably aware, we do require workmen's comp. insurance when we issue a business license. However, that would not address the concern you presented in your example. Based on your suggestion, I believe a change is warranted and I will include it as a requirement for our class A, B and C general contractor licensing. Most of the time, a general contractor will already have employees and as such have workmen's comp. insurance, but just in case, we should require it. As for all other contractors, I'm afraid we might be going overboard. I will include your proposal in future presentations and if any of the boards want to recommend it to council, I will gladly include it.
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(04/17/08)
Comment: Is there a better term than "Class D license contractor" Since there is no req. other than insurance. It gives that contractor a sort of air that they have been through some type of specialized training. My only concern is the term not the fact that that category exists
Response: I'm certainly open to using another term, but I can't think of one at this time either. I will pose this question to our Advisory Boards and see if we can't come up with something that would be more appropriate. Thanks for your input. Please keep it coming.
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(04/14/08)
Comment: Your docs call for meetings on April 20,22, or 28 for review. April 20 is a Sunday.........also additional meetings in May, same dates. Would like to attend, please advise correct dates and place of hearing.
Response: Sorry about that. The public meetings are in May, not April. I'll have to get that changed right away.
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(03/28/08)
Comment: Page 62. Sec. 7-492 Supervision.
This section appears to be well intentioned yet once again flawed. First, no contact is ever available 24-7. Second, for smaller projects, the contractor's work force (including foremen) could change frequently based on work load and/or phasing. The idea that a supervisor needs to be present at every job site when any work is being preformed by the contractor or his subs is impractical. This will only add cost to a project. All the city should require is that the Licensed Contractor be responsible for the supervision of their work.
Response: Do you think it would be reasonable to expect a contractor to provide an emergency contact number as part of their permit application process? My intent is to ensure that we can contact the contractor when something happens during other than normal work hours; i.e. we find erosion control problems on a weekend. Is it unreasonable to expect that a general contractor have a supervisor on site anytime work is being done by either their own crews or by their subcontractors? Keep in mind that we are making the general responsible for all those working on the job.
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(03/28/08)
Comment: Page 6. Sec. 7-9. Permit expiration.
Many larger projects have durations that exceed the one year limit. Examples: American Family Insurance, Triumph Foods, Heartland Regional Medical Center. These large projects would have generated large permit fees. Is it fair to these owners, to ask that they incur additional cost due to the size of the project? I am referring to the half-cost extension fee.
Response: We havent charged anyone to extend a permit when we felt they were diligently working on the job. Ive even tried to set a policy that we will extend a permit beyond a year without charging for it unless the permit expires. Then we handle it on a case by case basis. I will look at amending the language to give us the ability to extend the permit duration beyond a year when the permit is issued so we can all agree to a longer duration initially and prevent getting into a situation where it is allowed to expire.
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(03/28/08)
Comment: Page 62. Sec. 7-491. Contractor's vehicles.
I understand the need for easy identification of contractor's at job sites by inspection and/or emergency personnel. However, the requirement to have at least one company vehicle at the site is flawed. A contractor with multiple jobsites can't be expected to have a company vehicle for each site. Example: We had a contract a few years ago for the St. Joseph School District. We were working at Central, Benton, Lafayette, Pershing, and Humboldt all at the same time. We had two superintendents sharing the responsibility of the combined sites. Placing a company vehicle on each project was not practical. As an alternative to "mobile signage", a better solution would be to offer the choice of a company truck with the required signage, or job site identification signage.
Response: I understand your concern and think this is a viable alternative. The only problem we will have is making sure that every vehicle owned by the company, have the companys name on it. The main purpose for this requirement is to be able to identify who or what company is working at an address which may or may not have a permit.
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