Some measures of the future RE 2020 are worrying design offices and consulting engineers

Elements that deserve to be saluted ...

The CINOV Federation is perfectly in line with the initial ambition of preparing and anticipating the implementation of the next regulations and the principle of the Energy-Carbon Experimentation, which consists of promoting the construction of positive energy buildings and low carbon footprint (E + C-).

CINOV is therefore delighted with the inclusion of carbon in the RE 2020 and also of “Summer comfort” as well as “Indoor air quality” (IAQ).

CINOV also welcomes the presence of elements that it considers positive in this new regulation, including the principle of progressive carbon thresholds (in line with the evolution of the decarbonization of construction activity and its products, as well as energy), the desire for support for sectors and a gradual acculturation of actors to RE 2020, and the foreshadowing of labels that would make it possible to distinguish certain operations.

... but which fail to compensate for the fears of the Federation

Despite these positive elements, the CINOV Federation regrets that the administration did not place more confidence in the players in the field in the development of this new regulation, even though they have in-depth knowledge of the subjects which would have deserved better consideration. CINOV regrets that certain proposals which received a large number of unfavorable opinions during the consultation phase were nevertheless maintained. Conversely, other elements - including feedback on the implementation of RT 2012 - were only too little integrated into the RE 2020 approach when they would have had their place there.

The Federation is particularly concerned about the choice of the dynamic Life Cycle Analysis (LCA) method, which consists of carrying out a multicriteria and multistage environmental assessment of a system over its entire life cycle. , while weighting greenhouse gas emissions according to the year of emission.

“The imposition of this method is difficult to understand, and its interest questionable. We are opposed, like the majority of the actors concerned, to this method which we consider to be lacking in pedagogy, that it is difficult to understand and that it does not rest on any scientific basis ” underlines Damien Racle, President of CINOV Ingénierie.

This method also marks a break with the aforementioned E + C- practice, and presents an additional complexity to RT 2012 - already perceived as particularly complex by all the players. To dynamic LCA, the CINOV Federation would have preferred to adopt the static LCA method supplemented by an indicator on carbon storage.

CINOV also regrets the abandonment of the Bilan-BEPOS in the new regulations. However, the majority of the players were in favor of maintaining this tool, which makes it possible to assess the overall energy balance of a building, and to promote “Positive Energy Buildings” (BEPOS) which produce more energy (thermal or electric) than they consume.

In addition, the CINOV Federation deplores the lack of skill requirements in RE 2020. “The administration seems to be betting on the fact that non-competent design offices will de facto be excluded by the market. For our part, we consider that the implementation of skills requirements is essential given the complexity of the calculations and the risk of market capture by “low cost” or above-ground design offices by price effect, to the detriment of references and time investment in training and qualification ” explains Damien Racle, President of CINOV Ingénierie.

This risk is very real and was observed during the implementation of RT 2012, for which no skill requirement was imposed and which enabled a number of "low cost" services (studies or permits) to be develop. In addition, the CINOV Federation is surprised that the energy performance diagnosis (DPE) is itself subject to certification when the stakes are perfectly identical: it is indeed a question of establishing a compliant diagnosis for which it is appropriate to be particularly vigilant during the study and design phases.