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Photographic evidence – what’s changing

26 Jan 2022

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The first phase of the Future Homes Standard will launch in England later this year. The aim is to make sure new dwellings use less energy, have lower fuel bills, a lower carbon footprint, and are comfortable to live in. There are also stricter requirements for proving buildings have been constructed as planned.

Over the coming months, we’ll be writing articles to answer your questions about these regulatory changes. This time we’re looking at a new section in Approved Document Part L:

The requirement of photographic evidence

Ever since SAP was first introduced, there’s been a debate about how accurate the figures are compared to real life. This is known as The Performance Gap.

When AD L is updated in June, this will introduce tougher requirements to help tie together the SAP model with the building in question.

Firstly, better communication is required between the designer, the builder and the SAP assessor. More signatures on more pieces of paper should mean no assumptions are used when the Energy Performance Certificate is created.

Secondly, better information should be given to the first occupier of the house. These documents will need to be bespoke for each dwelling and explain how to use the building’s services correctly and efficiently.

But the section that’s raising the most eyebrows is a new requirement to store a library of construction photographs for every new dwelling.

As a new home is being built, photos will prove the design specification is being followed. Pictures are required at six stages of the build:

The first covers foundations and substructure, then the external walls, and then the installation of the roof. At each point, photos need to clearly show insulation in position, and thermal continuity around junctions (the thermal bridging).

More pics are needed when the windows are installed, to prove the dwelling has been air tested, and finally to confirm the precise model of boiler, hot water cylinder and ventilation system.

A separate folder of photos will be required for every dwelling.

The images need to be clear and taken with a camera that notes the time and geolocation (most phones have this feature as standard).

Anybody can take the photos, and anyone can store the photos, however the files must be readily available for the SAP assessor and for Building Control to access.

For the energy assessor, the photos are used as evidence to check the accuracy of the SAP model. EPC certificates and AD L compliance reports may be withheld if photos are missing, not clear or show discrepancies.

The Building Control Officer could refuse final sign off if they are not happy with the images, or if they believe the photos aren’t from the dwelling in question.

As with other requirements that make up this package of new regulations, photographic evidence must be collected for new dwellings where the site is registered with Building Control from June 15th 2022.

They will also be required for any new dwellings where construction hasn’t started before June 15th, 2023 – even if the site was registered under the older version of AD L.

Photographic evidence to prove energy performance is not required when dealing with non-residential buildings, nor renovations, extensions or change-of-use projects on existing buildings.

If you have any questions about these changes, feel free to contact the Energist team. Otherwise keep an eye out on our ‘Articles’ page where follow-on information will be published.

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