Summary of HB 3329 Discussion

This commentary does not reflect the opinion of its author or of the North Texas Chapter of ICC’s Board of Directors

General Commentary

  • Policy changes must be reviewed by each jurisdiction’s city attorney. It is recommended that building officials provide an explanation and cost analysis of any option or options under consideration to their city manager as soon as they are prepared to do so.
  • BOAT is taking a leadership role in this matter going forward, and RCCC will consider options at the next meeting in July.
  • Having a unified interpretation and approach on a regional or state level would be an asset when building officials approach their city councils and administration about policy changes.
  • Policy changes in response to this bill may affect cities’ code amendments and fee schedules.
  • Contractor registration is viewed as an essential component of the safety goals of the codes. None of the proposed options would diminish cities’ power to verify credentials, issue permits, or review and inspect work.

Permit Fees

  • The general consensus appears to be that cities can still charge for electrical permits as “building permits” under code. The term “building permit,” as opposed to “electrical permit,” is subject to interpretation by each jurisdictions.
    • Option #1: If a jurisdiction’s nomenclature, application documents, etc., already point toward electrical permits being “building permits,” no further action is needed.
    • Option #2: If a jurisdiction differentiates “electrical permits” from “building permits” to a degree that could interfere with the above interpretation, changes in nomenclature for permit types may be a solution.  Such changes may trigger statistical anomalies in reporting, and would likely require alterations to permitting software.  For example, on a residential electrical repair permit:
      • Old permit classification: Electrical (Residential)
      • New permit classification: Residential Building (Electrical)
    • TML legal department agrees that cities can still charge a permit fee.

Contractor Registration Fees

  • Option #1: Differentiate between licensed electricians and electrical contractors, and keep charging electrical contractors a registration fee (charging the business entity rather than the licensed professional).
    • This interpretation is largely a matter of words. While this interpretation may be technically correct in terms of language, the point was raised that it could be challenged in court.
    • There may also be a concern in cases where the licensed professional is also the business entity, blurring the distinction between electrician and electrical contractor.
    • IAEI expressed this opinion.
  • Option #2: Stop charging electrical contractors a local registration fee (but still require them to register with the city and verify credentials).  Members discussed various financial strategies to compensate for lost revenues:
    • Raise permit fees for electrical work to compensate (most common opinion expressed).
    • Eat the loss without compensating (and/or wait and see on budget impact).
    • Spread the loss by raising other types of contractor registration fees (less popular proposal).
    • Assume that this is a trend that will extend to other types of contractor registration in the foreseeable future. Stop charging any type of contractor registration fee.  Raise permit fees across the board.


Submitted by Suzanne Arnold – City of Coppell & North Texas Chapter Secretary

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