Hello Dean,
The NCC's own website states:
"The National Caravan Council ("the NCC") is the trade association for the UK caravan industry.
Our member companies come from all sectors of the industry, including manufacturers, retailers, distributors, park operators and specialist suppliers of products and services to the industry. We have a long history of experience - the NCC was formed in 1939 and became a company limited by guarantee in 1953.
"Our Mission
That the NCC is the recognised and respected, authoritative trade body for the UK caravan industry, providing leadership through a centre of expertise offering support, products and services to members for the successful evolution of their businesses."
They are only a trade body, they have no legal or regulatory responsibilities towards caravanning, and the only but most important sector they do not represent as part of their mission is the consumer.
Because they have been around for a long time they have been traditionally the common mouth piece of the manufacturing side of the industry. As such they have been invited to provide 'experts' to panels that draw up standards and regulations. So whilst they are not the enforcers they can influence the agenda.
Legislation calls for evidence that installations are safe to connect to the mains supply. The NCC have taken it upon themselves to interpret that requirement in the context of a caravans, and they have come up with the proposal that has been debated in this thread.
The NCC can only enforce it so far as they can threaten members of their own council with exclusion from the council if they don't comply.
As for the NCC's PIR its self, that is just one interpretation of how the legislation can be met. There have been other suggestions made in this thread that may meet the requirement.
The problem is that none of the suggestions including the NCC's is a guarantee of compliance. That will only be tested in the event an incident being investigated and prosecuted through the courts.
I consider the NCC's approach to the PIR is an effort to provide their members with a copper bottomed approach that will protect them from claims of incompetence. This is where their mission statement comes home to roost, they are not looking out for the consumer in this matter.
If you are a member of any caravan club, lobby the clubs managers to start to represent their members views on this matter.