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PROJECT MANAGEMENT PRACTICE NOTE

PM-RY-01/2015
SUBJECT: REGULATORY

TITLE: MANAGING AUTHORITY SUBMISSIONS

Background
1. Authority submissions, if not managed properly, will have serious repercussions on project
delivery. Many of these submissions are inter-linked and some critical authority approvals are
required before construction activities can commence. Authority requirements affect every stage
of the project life-cycle.

2. This note will help to clarify the types of authority submissions, the key submission and approval
milestones as well as the advance works which dovetail into the authority submission programme.

Good Practice: Managing Authority Submissions

3. This GPN covers 3 key aspects of Authority Submissions:

(i) A workflow that covers the main authority submissions and actions that Development
Agencies (DAs) need to undertake.(Annex A)
(ii) Checklist of Agency Submissions Required at TOP/CSC Stage (Annex B)
(iii) Typical agencies response times. (Annex C)

4. Annex A shows the key Authority submissions from planning and design up to TOP/CSC and the
corresponding actions by DAs. It is not meant as an exhaustive manual of all the submissions
required but serves as a guide for Public Sector Project Managers to focus on the key areas
which have significant impact to successful delivery. The start of the project is assumed to be the
point where the business case has been approved and the site specific technical feasibility needs
to be carried out.

5. The workflow diagram has been divided into 6 phases of submissions:

(i) Feasibility Study
(ii) Development Control (DC) Submission
(iii) Structural (ST) Submissions
(iv) Commencement of Construction Works
(v) Building Plan (BP) Submission
(vi) Temporary Occupation Permit (TOP)/ Certificate of Statutory Completion (CSC)

The phases are not consecutive and the degree of overlap depends on the sequence of work
and the relationships between submissions. For example, Structural Submissions can occur in
parallel with Development Control submissions but Structural Plan approval will only be granted
after planning permission has been obtained (provisional or written permission). These
relationships have been indicated in Annex A.

6. The key milestones with respect to regulatory submissions that Project Managers need to note
are as follows:

(i) Appointment of Consultancy Team 1

(ii) Award of construction works tender and commencement of structural works
(iii) Commencement of non-structural building works

1
For appointment as the Qualified Person (QP) pursuant to statutory requirements and also to undertake
additional consultancy services associated with the development requirements.

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(iv) Preparation for TOP/CSC

7. As consultants QPs undertake authority submissions, the procurement method may affect the
submission workflow. For example, for Design and Build (D&B) contracts, the authority
submissions commence only when the main contract is awarded; and for Design Development
and Build (DDB), the Agencys QP may be retained for the entire project to follow through with the
authority submissions or there will need to be a handover of duties to the Contractors QP when
the contractor comes on board.

Feasibility Study to DC Submission Stage

8. DAs will need to engage the relevant agencies and URA to inform them of the infrastructure
requirements and uses of their proposed development. DAs should obtain no objections from
these agencies before submitting their Planning Application to URA via their Electronic Planning
Application and Consultation system (ePAC). Depending on the scale and impact of the project,
the proposal may have to be considered by the Master Plan Committee (MPC) before Planning
Approval is granted.

9. DAs will need to liaise with URA and SLA for land alienation or allocation at the feasibility study
stage however the actual transfer of land title can take place either upon obtaining Planning
Approval from URA or upon award of construction contract depending on circumstances 2.

10. For projects with high security risks, early engagement with MHA is necessary to ensure that the
design security requirements such as building siting/ massing, stand-off distance, etc are
incorporated into their Development Application to URA, which is to be submitted via Corenet eSS
.3

11. DAs are advised to call services detection work early so that services diversions, if required, can
be completed ahead of the piling or earthwork tenders. Services diversion works are undertaken
by licensed contractors appointed by the utility service providers directly. The progress of such
diversion works is not within the control of the Project Team and may lead to unforeseeable
delays. This activity must be included in the project master programme with ample lead time .

12. Soil investigation work needs to be conducted for the design of foundations. DAs should call soil
investigation work early to allow sufficient time for the design of foundations prior to Structural
(ST) plan submission. Some consultants tend to leave certain construction details (eg
balustrades, railings, etc) to contractors or appointed specialists. In so far as possible, it is a good
practice to set out comprehensive design work in ST submissions. As an industry norm,
consultants tend to adopt the approved design submission as the baseline tender requirements.

13. Following a Development Application to URA, URA generally issues a Provisional Permission
(PP) 4 first as project details may still be changing. This is to allow the project to proceed while

2
Where the site has an ongoing use, e.g. a carpark, the transfer of land title usually takes place as late as
possible. Development Agency should liaise with the landowner for access to carry out soil investigation and
other advance works.
3
Agencies are to refer to FCM M13/2014 for details on submission requirements for high risk projects. For
projects of high security risks classification, Planning Permission is normally given upon clearance of Security
Plan submission by MHA. The review by MHA is an iterative process.
4
Sometimes, the first application to URA is the Outline Planning Application to test out the key planning
parameters, among others, land use, plot ratio and height before spending an inordinate amount of resources on
drawing board.

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certain technical conditions are being met. DAs should take note of the specific written directions
from URA at this stage as some may require calling of specialist consultancy tenders (e.g. Traffic
Impact Assessment) or be subjected to the review of Design Advisory Panel (DAP) for
developments in strategic areas such as the downtown core area. However, if DAs are able to
finalise project details early and pre-consult with regulatory agencies, they may be able to obtain
Written Permission (WP) in time for their construction works tender.

14. DAs can generally call construction works tender after receiving Provisional Permission 5 .

ST and BP Submissions
15. Commencement of construction work will require BCAs Permit to Commence Structural Work
which is contingent upon obtaining ST approval. While the foundation and superstructure works
proper cannot commence until the permit to commence work is obtained, contractors may carry
out the site preparation and preliminary works while waiting for the permit to commence work.
For complex projects and for purpose of fast tracking the construction programme, consultants
will usually split the foundation and sub/super-structure works into separate structural plan
submissions in order to proceed with the physical foundation work on site while the design for the
super structure work is ongoing 6. For projects with many structural plan submissions, it should
be noted that only relevant parts of the development that have already obtained ST approval can
proceed to be constructed on site. Submission of amendment plan to BCA is also required before
construction changes involving material change 7 to key structural elements can be effected on
site.

16. Project Managers are to note that BCAs Building Plan (BP) approval must be obtained prior to
commencement of non-structural building works. BCA issues their BP approval independent of
the other Technical Agencies. As the regulatory agencies involved are broadly similar as those
involved in Development Control submissions, agencies should get their consultants to
commence early engagement with the regulatory authorities to ensure that critical requirements
are conveyed at the early stages.

Construction TOP/CSC
17. Given the nature of construction work on site, there will be changes along the way triggered by
events such as changes in operational requirements, unanticipated authorities requirements, site
problems, consultants oversight etc. It is critical to incorporate all crucial changes in relation to
authorities requirements into amendment plan submission before making application for
TOP/CSC. Depending on the nature and materiality of these changes made on site, consultants
may have to revisit the planning submission to URA as well as repeating the entire BP
submission stage. In some circumstances, late submissions of amendment plans may lead to
surprises when new or more stringent requirements are imposed at a critical stage of project
completion. Project managers will need to monitor the amendments that may necessitate
resubmission to Technical Agencies.

5
Ministry projects e.g. schools are issued Planning Clearance or Provisional Planning Clearance, if
submission is still not in full compliance (versus Written Permission and Provisional Permission for
Statutory Board projects).

6
Under BCAs one permit system, a separate application to commence work only needs to be done when there
is a change in the Developer, Builder or Qualified Person (QP) for that portion of the works. Generally, a single
permit will be issued regardless of the number of structural (ST) submissions made.
7
Material change in relation to building works, is defined in the Regulations as any changes that affect the key
structural elements of the structure to such an extent as to require a re-design of the key structural elements

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18. DAs must procure the services of the Architectural & M&E Registered Inspectors 8 prior to
TOP/CSC as their inspection certificates are required for the application of the Temporary Fire
Certificate (TOP stage)/Fire Safety Certificate (CSC stage). DAs should note that for
performance based fire safety design, SCDF may request for Fire Safety Plan audits prior to
TOP. DAs should also note that for sewerage designs which QPs self-declare on compliance
with the prevailing Code of Practice, Sewerage Department may request for random audits of the
plans submitted prior to TOP. Similarly the electrical sub-station commissioning and power turn-
on are critical activities that need to be completed prior to application for TOP inspection.
Agencies can proactively engage their consultants and contractor to ensure that there is
sufficient time for these activities prior to application for TOP/CSC.

19. Annex B shows the list of agency submissions required for TOP and CSC. NEA, CBPU and
FSSD clearances are required as part of the supporting documents for BCAs TOP application.
For fit-out works, TOP application to BCA may not be required unless there are changes to
Building Plans. Usually only TOP application to FSSD is required for such works.

20. DAs should also closely monitor that the consultants close outstanding issues arising at TOP
stage prior to application for CSC.

21. To facilitate the monitoring of authority submissions, agencies can request for an authority
submission micro-programme from the Technical Consultants.

22. Where there are conflicting regulatory requirements affecting project delivery which the Technical
Consultants are unable to resolve, DAs may highlight such cases to the Inter Agency
Coordinating Committee (IACC) for resolution. BCA is the Secretariat of the IACC.

Enclosures
Annex A - WORKFLOW OF KEY AUTHORITY SUBMISSIONS & KEY PROJECT
MILESTONES

Annex B - CHECKLIST OF AGENCY SUBMISSIONS REQUIRED AT TOP & CSC STAGE

Annex C - TYPICAL RESPONSE TIME REPORTED BY REGULATORY AUTHORITIES

CP2M would like to acknowledge the contributions of BCA and URA in the preparation of this
GPN as well as all the Technical Agencies who have contributed in the preparation of Annex C.

Note: The views expressed in this Practice Note are CP2Ms own based on our research and
experience. We welcome feedback and inputs so that we can improve the Good Practice Notes.
Please send your feedback to CP2M_COMMS@cp2m.gov.sg

8
The Architectural and M&E RI are separate consultants engaged by agencies directly.

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ANNEX A-1
Feasibility Study Stage Development Control Structural Submissions Commencement of Construction

Agencies may procure Procure Accredited

Agency Actions

Procure Checker (AC) /AC(Geo)

Development

feasibility study
Procure Procure soil services services as required3.
consultancy services
Consultants investigation diversion,
and conduct a
to engage and services temporary Consultants to
topography and site Award
frontline detection access appoint Site
boundary survey at Construction
technical works. works, if Supervisors4
this stage. 2 Works tender
agencies required

Planning Application
Submission Development URA Issues ST application can be Application
Pre-requisite Under BCAs one
Requirements

Agencies to justify land Plan Provisional split into piling, for Permit to permit system, a
Authority

take, locational Submission Permission5 substructure, Commence separate permit is

requirements, (PP) superstructure, civil Structural only required for a
highlight development defence shelter for Work

Pre-requisite
separate ST
constraint (if any) and separate approvals
submission if there is
obtain approval from (URA PP required)
URA issues Written a change in Owner,
URA and clearances Permission5 (WP) if QP or builder
from technical PP conditions are
agencies, including BCA Issues
met
NOTES: URA, SLA, MHA & LTA Permit to
1
2
Technical agencies to be consulted include URA, BCA issues ST Commence
1 FSSD, NEA( Environmental Health, Pollution Approval Structural Work
SLA: Land and lease information; URA:
Planning parameters; LTA: Road widening Control), PUB(Sewerage, Drainage), 4
LTA (Vehicle Parking, Roads & Transport, Rail), Site supervision services are usually packaged
and access requirements; MHA: Security under the scope of consultancy services on a
classification. CAAS/DSTA: Height NParks, CAAS (Aviation Control), IDA 3
PE(Geo) & AC(Geo) are
(telecommunication services) & EMA (SPPG). reimbursement basis for each site supervisor.
constraints. Other agencies consulted required if project has
Where required: DSTA(Military Facilities), MHA Resident Engineer/Resident Technical Officers
include JTC, SLA, PUB, NEA, NParks, IDA, Geotechnical Building
(RE/RTOs) are required to be appointed before
MSF, HDB, DSTA, MCCY, MPA & MOE (Security & Blast), MOE(near schools), NHB Works
application for Permit to Commence Work
(monuments)

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ANNEX A-2 TOP/CSC Stage

Building Plan Submission

Electrical Sub-
station
Commissioning
Agency Actions
Development

Non Structural
Consultants to Building Work
Appoint Specialist submit Building activities can only Procure
Consultants5, as Plans/Detailed commence after BP Registered Application for
required Plans to Technical approval has been Inspector Svcs Power Turn on
Agencies obtained from BCA (Arch, M&E)

BCA issues BP TOP Application7

Consultants obtain Approval subject to BCA, NEA-CBPU (Sanitary,
Requirements

BP
building plan approval WP approval Sewerage &/or Pollution
Authority

Application 6
Control), FSSD (TFP), URA
from Technical Depts IRAS House &
Unt Number (for conservation projects)
NEA, LTA, NParks, (subject to WP
FSSD will issue approval) CSC Application
QP to apply for commencement their BP approvals BCA, LTA Rail, Road &
of sanitary/sewerage/ independently Transport & Vehicular
NOTES: drainage works Parking, NParks, FSSD (FSC)
5
Specialist consultants required include ABC Waters Professional, Fire Safety IRAS House & Unit Number can only be applied after WP application has
Engineer, Fire Safety Peer Reviewer, Traffic Engineer, Aborist, etc been submitted. PP approval Is required for this application
6
Technical agencies to be consulted are similar to DC stage. Requirement for 7
At TOP stage, only BCA inspection is mandatory while FSSD and NEA inspections
additional details eg Traffic Impact Assessment, etc will be made known at DC are non-mandatory.
stage. For LTA & NParks, only BP clearance certificates are required as supporting
Agencies can apply for Technical Departments Building Plan clearances in parallel documents at TOP stage. These agencies will instead conduct inspections at CSC
to BCAs BP Approval stage. For more details on TOP/CSC refer to Annex B

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ANNEX B - CHECKLIST OF AGENCY SUBMISSIONS REQUIRED AT TOP & CSC STAGE

1 Clearance for Building Control, BCA TOP CSC

1 Clearance for sanitary, drainage and/or pollution requirements from CBPU, TOP CSC
NEA

2 Fire Safety Certificate for building works, FSSD TFP FSC

3 Clearance for road & transportation requirements, LTA-Road & Transport BP CSC At TOP stage only
Building Plan
4 Clearance for vehicle Parking requirements, LTA/VP BP CSC clearance is
required.
5 Clearance related to MRTC line affected by projects BP CSC Submissions and
inspections where
6 Clearance for greenery requirements, NParks BP CSC required are only for
CSC stage

7 Cable Readiness Certificate, IDA

8 CAAS and DSTA if specified in the WP from URA

9 URA (for conservation projects) TOP CSC

10 URA (for foreshore works) BP CSC

11 Any other clearances specified in the WP from URA

Source: Building and Construction Authority

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ANNEX C

TYPICAL RESPONSE TIME REPORTED BY REGULATORY AUTHORITIES

S/n Agency Activity KPI / Reported Publicly Typical Approval
Response Available? Times (from first
Time submission to
final approval) 9
1 URA WP issuance 20 working Y 3 months
days
2 BCA Structural Plan Non-AC cases: Y 1 month
7 working days
AC cases: 10
and 14 working
days
3 BCA Building Plan 7 working days Y 1 month
4 NEA a. Development control within 7 Y 3 months
(CBPD) working days (Range from 2 6
months)
b. Building Plan/Detailed within 7
Plan working days

c. TOP/CSC clearance within 7

working days

5 LTA DC / Building Plan 10 working N 6 months

clearance days (Range from 3
months 1 year)
6 NParks DC/BP/CSC clearance 7 working days N 2 months
(Range from 2
months 2 years)
7 PUB Development 21 Working Y Depends on the
Control (Major Days progress of
Project) developers work
Detailed Plan 21 Working onsite. This is due
(Major Project) Days to the issuance of
Development 14 Working completion of work
Control+ Detailed Days clearance
Plan (Minor Project)
Application for 14 Working
Work Affecting Days
Public Sewer
Completion of Work
(Sewerage / 14 Working
Drainage) Days

9
Based on a sample of 34 project walkthroughs of various types of developments in a study conducted by
Deloitte commissioned by the Construction Productivity Steering Committee (CPSC) . The values serve as a
guide for planning purposes only. Actual approval times will vary depending on the types/nature of submissions,
how quickly applicants resubmit and the number of resubmissions involved. Inputs and clarifications from the
regulatory agencies have also been sought in the preparation of this table.

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8 SCDF To provide outcome of Within 7 Y N.A.

waiver application working days
To provide outcome of
fire safety plan Within 2
applications working days
To issue Temporary
Fire Permit/Fire Safety
Certificate Within 3
working days
9 Services Service Diversion N.A. Y 6 months
PUB
Water
Supply
10 IDA To provide outcome of Within 7 Will publish N.A.
waiver to COPIF working days
application once all
information has
been submitted
11 Services Service Diversion N.A. N 6 months
SingTel/
StarHub/
Netlink
Trust
12 Services Response to requesting Within 7 Y 6 months
SP party working days (Range from 3 9
Power Quotation to requesting months for
Grid party Within 3 weeks energisation of
after various electricity
confirmation of service
scope by both connections up to
parties 22kV) 10
13 Services Service Connection N.A. N 6 months
SingTel/
StarHub

CP2M would like to acknowledge the contributions of as all the Technical Agencies who have
given their inputs in the preparation of this Annex.

10
For electricity service connection from existing main, the time taken by SP Power Grid (SPPG) to implement
the project is 4-6 weeks from the date consumer's premises is ready to receive the service cable. If a new
substation is needed, the lead time for electricity connection up to 22kV is within 10 weeks after handing over the
substation.

For Cable and Gas pipeline diversion works, SPPG has published the standards for diversion works on its
website

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