There appears to be much disquiet at the moment over exactly how PV installation works are covered by Building Regulations.
Many Local Authority Building Control (LABC) departments are advising concerned callers that a Building Notice application is required at a cost, in some instances, of over £350 – even where the installer will be both MCS accredited and a member of a Part P electrical competent person scheme – in order to cover the non-Part P elements of the work, which would normally be Part A, covering any structural work on strengthening the roof. And it seems that this situation has not been helped by some rather unguarded comments issuing from the NICEIC.
As far as I can see any Building Notice required under Part A would be for notifying that strengthening works are to be or have been carried out on a roof – as a result of a structural survey.
There is no need to notify LABC that a roof is simply being assessed as to its suitability to carry a higher load or that a higher load is being imposed – with no need to strengthen it.
And any building work that is associated with Part P work (which is what a PV install is as far as the Building Regs are concerned) is automatically covered by the Part P CPS self-certification. This is written into the Building Regs legislation and has been since day 1 of Part P. In fact the wording to cover associated building work under CPS self-certification was first introduced way back in 2002.
So, as far as the legislation is concerned, if an installer is competent to self-certify for the Part P electrical work then they are also considered competent for all the other work carried out at the same time and, as far as the LABC should be concerned, is covered by the same self-certification.
This all comes hot on the heels of the recent news that some Local Planning Authorities (LPAs) were advising homeowners that their planned PV installation required planning approval even though it would usually be covered by the revised Permitted Development legislation that has been introduced by central government over the past few years – specifically to remove this particular barrier to the wider roll-out of microgeneration.
I suppose that this sort of reaction by LABCs and LPAs is a result, in these days of financial restraint, of scrambling to get as much revenue in from their customers as possible. But this is not the right (or legal) way of doing it.
The relevant parts are included in paras 17 and 20 of Schedule 3 of the Building Regulations 2010.