The Cinov Federation calls on the government to postpone the implementation of its regulatory audit project

While this provision will apply from January 1, 2022 with regard to thermal strainers (F and G), the Cinov Federation takes note of the willingness of the public authorities to create a “regulatory audit”, which can be carried out by diagnosticians, in addition to the pre-existing energy audits, previously carried out by the design offices alone. However, it warns of the many risks that this new service entails, the first of which is the downgrading of the skills of design offices and architects.

A project that discredits the skills of design offices ...

As a reminder, at present, the phase prior to the renovation of housing is orchestrated by two very distinct professional bodies. On the one hand, the diagnosticians responsible for classifying each good according to its degree of energy consumption (classified from A to G) by establishing the energy performance diagnosis (DPE). On the other hand, the design offices and architects responsible for carrying out energy audits estimating the real cost of the work for the energy-intensive housing detected.

With its “regulatory audit” project, the State intends to accelerate the eradication of thermal strainers by decompartmentalizing the two systems: in the future, the diagnosticians - who previously dealt exclusively with DPEs - will be able to carry out the equivalent. energy audits. However, this decision is not without risks, in the first place for design offices, architects and thermal engineers, who are currently the only professionals authorized to issue these documents.

This decision arouses the incomprehension of the design offices and architects, who consider that the qualifications related to energy audits - OPQIBI and QUALIBAT in particular - have proven their value in recent years. Thus, the “regulatory audit” project undoubtedly competes with and devalues ​​pre-existing tools, which are synonymous with specific know-how and expertise. In addition, the more attractive cost that will undoubtedly be offered to households by diagnosticians for this new service will de facto contribute to depreciating the expertise in place.

… And which operates to the detriment of households.

In addition to the devaluation of the skills of design offices and architects, Cinov regrets that this new qualification is based on a low-quality benchmark whose outlines raise many questions, create confusion for sellers and buyers and generate a very high risk of loss.

If the proposed regulatory audit is semantically equivalent to the energy audit currently in place, it remains fundamentally different. Where the energy audit is based on precise benchmarks established by ADEME in consultation with the various players in the profession, the regulatory audit would be based only on the data collected during the DPE - a less precise method in this respect. which concerns the identification and promotion of energy saving avenues.

Furthermore, this new regulatory audit would not be usable by households to obtain MaPrimeRénov 'or Energy Saving Certificates as part of the overall renovation, which are essential levers for massive renovation. Future buyers will therefore be forced to carry out a new incentive audit in order to be able to benefit from renovation aid, this time carried out by qualified architects and thermal engineers. A double cost, to the detriment of said households given that it is very likely that differences will appear both in the recommendations of the audit and in the financial estimates of the works.

Frédéric Lafage, President of the Cinov Federation, warns: "Insofar as this regulatory audit will be opposable, we wonder about the methods of covering the financial differences between this one and the energy audit, the risk being that the difference will be endorsed in the long term by the communities."

Cinov calls for postponement of the project

On the eve of the effective implementation of this law, the Cinov Federation reiterates its commitment to a massive renovation of the residential stock and concedes that the announced objective of 100 audits per year remains difficult to achieve as it stands. . Nevertheless, the current energy audit is an essential link in the building renovation process, the quality, reliability and clarity of which are essential to achieve the aforementioned objective.

In addition, Cinov warns the government of the impossibility of properly training a sufficient number of operators by January 1, 2022 - unless the quality of audits is severely degraded, which will inevitably have less value and less legitimacy.

For Frédéric Lafage, President of the Cinov Federation: “We regret today that this consultation leads to a new system which degrades the quality of the audit service. It creates an inequality between the professions and the qualifications of the auditors and disturbs the message to the owners, to the detriment of the initial objective of massification of renovation operations. "

Faced with this observation, the Cinov Federation calls minima the government to rename this new service in order to avoid any confusion between the two types of audits. It also urges him to postpone this project in order to satisfy all the stakeholders. Indeed, the implementation schedule seems too ambitious for the time being insofar as the software solutions have not been completed and to date the qualification reference systems have not been sufficiently completed.