Oh - I thought the consensus was the opposite of that - namely that RCDs should be used to provide ('additional') 'direct shock protection) in addition to that (less 'direct') protection provided by OPD-based ADS ?Yeah, it's not very well worded but I think the consensus is that should be read as forbidding the use of RCDs to directly provide shock protection, rather than using them as a means of ADS.
At least if "ADS" is taken literally, one cannot avoid the fact that RCDs, as well as OPDs, will provide ADS (whether or not with the required disconnection times). I (and I thought most people) have always assumed that the reg means that one should (ideally) not rely on RCDs to be the primary provider the ADS 'IF there is a TN-based alternative'.
In a sense I agree, but the important thing is that if a TN earth is "not good enough" (for ADS) then, regardless of whether one just 'accepts' the under-spec ADS or installs TT rods, all circuits must be RCD protected.It just seems perverse to me to when faced with a "not good enough" TN earth to replace it with a "worse" TT earth.
What I suppose would be a little perverse would be to provide a new TT earth and then disconnect the "not good enough"TN one (particularly if it was only "not quite good enough") - if the TN 'earth' had any continuing connection to true earth, to leave it in parallel with the TT earth would improve things at least a bit (in terms of OPD-mediated disconnection times). However, it would still need to be regarded as a TT installation (particularly as regards the requirement for RCD protection of everything).

