Not necessarily, see my previous comments, I can assure you that I am by no means unique in this approach, though I did stress to check with the BCO. The adjacent authority to where I work are notorious for their inflexibility, so much so that one of my colleagues used a private inspector when he replaced his flat roof with a pitched roof.
The actual regulation and AD is full of statements such as "reasonable provision", "not economically or technically feasible" and "payback". So its not that a particular BCO is doing any favours, the regulations allow for things like floors not to be insulated.
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