SPECIAL INSPECTION REQUIRED FOR MINOR STRUCTURE |
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| This is a subsection of a web site cataloging the many problems we have had obtaining building permits in the County of San Luis Obispo. Here is the main page. This page was last updated 8/3/2025. |
| We submitted a permit application for a ground-mounted PV rack in the unincorporated area of San Luis Obispo County. The support structure we have developed is comprised of steel posts driven into native soil. This racking is robust, economical and demonstrably superior to any alternative. Here is a web-page describing the system and showing photographs and videos of the process. |
| We use SnapNRack 200 series racking supported by this custom support structure. This support structure is fully compatible with the SnapNRAck 200 series as indicated by this declaration from SnapNRack. |
| We have installed many ground-mounted PV systems as can be seen here on our portfolio page. I think it is accurate to say we are well versed in the many options for these racking systems. |
| The rack was to be greater than 6 feet in height above adjacent grade so we knew we needed engineering. We accomplished the engineering and submitted our complete permit packet. |
| After the usual pointless back and forth with the plan checker we received a correction notice with the condition we participate in a "Special Inspection". A Special Inspection is where a third party inspector checks our work because the technical nature of that work is beyond the capabilities of the inspection staff of the building authority. These inspections are intended for critical construction such as steel support structures and other technical or critical structures and infrastructure. These inspections can be quite expensive and time consuming. We have never been required to perform a Special Inspection in the past. This seemed to me to be punitive. |
| The Special Inspection program is governed by 2022 CBC 1704.2. Exceptions 1 and 2 allow the local building authority to waive special inspections for minor construction. I submitted to Matt Varvel that this back-yard support structure that would neither support nor shelter any persons or animal and that was well engineered would be considered "minor construction" and is eligible for the Special Inspection to be waived. I also pointed out that the engineer of record, who is responsible under the code for determining the need for a Special Inspection, is on record as saying a Special inspection is not required. |
Varvel would not have any of my logic and insisted that: "Special inspections are required based on the project design from the building code." |
| Of course we know Varvel to be wrong because 2022 CBC 1704.2. Exceptions 1 and 2 allow the requirement to be waived. |
| In order to determine the areas of construction that are to be considered with a Special Inspection, the "engineer of record" fills out a 20 page form and checks all of the boxes indicating areas that require Special Inspection. Since our structural engineer did not believe from the very beginning that a Special Inspection was warranted, she simply checked none of the boxes and signed the form. |
| When the permit was issued the requirement for a Special Inspection had magically disappeared. |
| Had Varvel reviewed our points and the letter from the structural engineer with an open mind early on, we all could have saved a lot of time and frustration. |
The text of the applicable sections of the 2022 CBC 1704.2. are inserted below for verification. The entire code can be found here. 1704.1 General Special inspections and tests, statements of special inspections, responsibilities of contractors, submittals to the building official and structural observations shall meet the applicable requirements of this section. 1704.2 Special Inspections and Tests Where application is made to the building official for construction as specified in Section 105, or 1.8.4, as applicable, the owner or the owner's authorized agent, other than the contractor, shall employ one or more approved agencies to provide special inspections and tests during construction on the types of work specified in Section 1705 and identify the approved agencies to the building official. These special inspections and tests are in addition to the inspections by the building official that are identified in Section 110. [OSHPD 1R, 2 & 5] In addition, the approved agencies shall provide special inspections and tests during construction on the types of work listed under Chapters 17, 18, 19, 20, 21, 22, 23 and 25, and noted in the Test, Inspection and Observation (TIO) program as required by the Office. The inspectors shall act under the direction of the architect or structural engineer or both, and be responsible to the Owner. Where California Administrative Code Section 7-115 (a) 2 permits construction documents to be prepared under the responsible charge of a mechanical, electrical or civil engineer, inspectors shall be permitted to work under the direction of an engineer in the appropriate branch as permitted therein. Exceptions: 1. Special inspections and tests are not required for construction of a minor nature or as warranted by conditions in the jurisdiction as approved by the building official. 2. Unless otherwise required by the building official, special inspections and tests are not required for Group U occupancies that are accessory to a residential occupancy including, but not limited to, those listed in Section 312.1. |