Windstorm inspector rules for roofers: the paperwork before tear off

Roofers inside the catastrophe area learn the windstorm program one bad week at a time: a crew held off a roof, a homeowner who cannot get coverage bound, a certificate that never comes. The rules behind each of those outcomes are written down, in section 2210.2515 of the Insurance Code and on the department's inspection process page, and they are worth reading before the tear off rather than after.

A re-roof is an improvement

Section 2210.2515(a) defines an improvement as the construction of, or repair, alteration, remodeling, or enlargement of, a structure to which the plan of operation applies. Replacing a roof is a repair or an alteration. It sits inside the same certificate section as a new house, which is why a coastal re-roof needs a certificate at all.

Before anyone climbs a ladder

Subsection (b) requires written notice to the department, on its prescribed form, of the intent to repair or alter the structure before beginning. The department's process page identifies that form as WPI-1, the application for a certificate of compliance, and says it is submitted to notify the department before construction begins. The obligation is stated for the person seeking coverage, which is why an owner who assumes the roofer filed it and a roofer who assumes the owner did end up in the same place.

The city permit is a separate track. Corpus Christi, Portland, and Rockport each run their own building department, and satisfying one of those does nothing for the windstorm program, or the other way around.

Who can be the windstorm inspector, and when they come

The department's page says a TDI inspector or an appointed Texas licensed professional engineer must inspect construction and repair work, and that TDI inspectors can inspect all non-structural work including most repairs, alterations, and re-roofs. Section 2210.254 says a windstorm inspection may be performed only by a qualified inspector who has been approved and appointed or employed by the department, which is what the statute means by a windstorm inspector: a person the department qualified by training or experience, a licensed professional engineer, or an inspector holding the code body and coastal construction certifications that section lists.

Timing is the part crews feel. TDI inspectors try to conduct inspections within 48 hours of the requested date, excluding weekends and holidays, and all inspectors must see the work in progress, during the repair and not before or after it. On a roof, the deck attachment an inspector needs to see can be covered within the same day it is exposed. Requesting the inspection only once the shingles are on asks the inspector to certify something that is no longer visible.

When the inspector finds a problem

If the work does not comply with the applicable construction requirements, the department's page says the TDI inspector will post a notice at the job describing the problems, and will return for a reinspection after they have been corrected. The notice is the list to work from. Correcting something that was not on it, or covering an item before the reinspection, restarts the argument rather than finishing it.

After the last inspection

Where an appointed engineer inspected, the department's page says the engineer provides the WPI-1 and the WPI-2-BC-1 series forms upon final inspection, and that although the engineer should submit them to the department, they may also be mailed, faxed, or emailed.

Then the clock in subsection (e) applies. The department may not issue the certificate for an ongoing improvement if, within six months after the date of the final inspection, it has not received fully completed forms and payment in full of all inspection fees owed to it, including fees for earlier inspections. A roof can pass and still never be certified because the paper behind it stopped moving.

Once the certificate does issue, subsection (k) says the department may not rescind it. The full section is read through on the certificate of compliance page.

A roofer's list for a coastal job

• Confirm the WPI-1 has been submitted, and by whom, before the tear off.
• Know whether a TDI inspector or an appointed engineer will inspect this roof.
• Request the inspection for the day the deck and its attachment are exposed, allowing for the department's 48 hour target and for weekends.
• If a notice is posted, correct what it lists and keep it visible for reinspection.
• After final inspection, make sure the forms reach the department well inside six months.