bdla Niedersachsen Bremen comments on the draft amendment to the Lower Saxony Architects Act (NArchtG)
In recent years, the Lower Saxony Architects Act (NArchtG) has been amended several times against the background of the implementation of European directives. However, short implementation deadlines left no room to consider the amendment proposals of the associations and chambers.
The current draft law on the NArchtG is different. In parts, the concerns of the professions are taken into account, as the bdla Lower Saxony Bremen expressly emphasises in its statement addressed to the Lower Saxony Ministry of Economics, Labour, Transport and Digitalisation. The regulations for the introduction of a junior membership in the chamber, the creation of the legal basis for the introduction of registers for certain subject areas of architecture and construction, the sharpening and modernisation of the professional tasks as well as the creation of the legal basis for the concretisation of the further training obligation of the compulsory members are therefore welcomed.
On the other hand, it is critically evaluated that in § 6 the increase of the standard duration of studies for the specialisations of interior architecture, landscape architecture and urban planning from three to four years has still not been implemented, a demand which the bdla Niedersachsen Bremen raises jointly with the AK Niedersachsen and the professional associations of interior architecture and urban planning. In particular the increasing complexity of the achievements and constantly rising requirements to these occupational groups make an increase of the rule study duration for the chamber entry and thus a country-uniform regulation necessary.
Equal treatment of landscape architects in the regulations on the design author
A further point of criticism relates to § 53 of the Lower Saxony Building Code (NBauO) with regard to the equal treatment of landscape architects in relation to the other planning disciplines. In the current regulation, architects and interior architects are mentioned in § 53 (3) for "non-procedural" building measures as being entitled to submit building documents; landscape architects, however, are only listed in § 53 (4) for "permit-free" building measures. "The different grouping of the specialist disciplines registered in the Chamber of Architects in the NBauO is associated with an exclusion for landscape architects of construction measures not requiring a permit according to § 61 and 62 NBauO, which typically fall within the scope of landscape architects." The bdla Lower Saxony Bremen questions why landscape architects, who are only qualified for their professional tasks with a degree, are not listed in § 53 para. 3 together with architects and interior architects? "The lower classification of education made here is absolutely incomprehensible, especially against the background of the complex range of tasks of landscape architecture, but also in view of the interdisciplinary cooperation, e.g. in the field of spatial planning, which are dependent on expertise from landscape architecture." The demand is made that, in order to streamline and simplify the approval procedures and to ensure equal treatment of the specialist disciplines of architecture, interior design and landscape architecture registered in the Chamber of Architects, the building submission authorisation of landscape architects be regulated in Section 53 (3).
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