A new Approved Document Part L will come into force on 15th June 2022. We have already outlined the increased thermal performance requirements that will challenge house and flat builders, but there are also 2 changes that will affect the admin work. These changes include requirements for photographic evidence, and the Building Regulations England Part L report, shortened to the BREL report.
What is a BREL report?
Currently we provide you with a Basic Compliance Report and a multi-page Full SAP Calculation which you pass on to your building control body (BCB) at design stage, and then again at as-built stage. These documents are not friendly, and are laid out differently according to which accreditation body has supplied the approved software. Therefore we provide you with a simplified and readable specification for the elements and services that will achieve your Part L compliance.
From 15th June there will be a BREL report for all plots, and the report will look the same across all approved softwares.
What do we know about the BREL report?
At the time of writing, we do not yet know what this report will look like. All we have is the description in Appendix B of Approved Document L Volume 1, 2021 edition.
We know that:
- it will be produced at the as-designed stage, and again at the as-built stage,
- the as-built stage BREL report will show any changes since the as-designed stage,
- the list of changes will be automatically generated by the approved software,
- the as-built stage BREL report is to be signed by the SAP assessor “to confirm that the as-built calculations are accurate and that the supporting documentary evidence and photographs have been reviewed”
- the as-built stage BREL report is also to be signed by the developer “to confirm that the dwelling has been constructed or completed according to the specifications in the report”
We also know what information the BREL report will include:
- target and dwelling primary energy rates,
- target and dwelling emission rates,
- target and dwelling fabric energy efficiency rates,
- a supporting list of specifications (including, at as-built stage, any changes to the list of specifications that was provided at design stage).
We do not know exactly what will be included in the list of specifications, but we can reasonably expect:
- U-values and build-ups of floors, walls and roofs,
- junction details with associated reference nos., psi values, and a y-value,
- window, roof light, and external door U-values,
- building services (space heating, hot water, ventilation and low or zero carbon technology equipment),
- target/actual air tightness.
Photographic evidence
Appendix B in the new Part L sets out a list of photographs that need to be taken during the build, mostly to show that details have been constructed correctly before closing-up works.
It also sets out how they should be taken:
“Photographs should be digital and of sufficient quality and high enough resolution to allow a qualitative audit of the subject detail. Close-up photographs may be needed where a long shot image provides insufficient detail. More than one image of each detail may be needed. Geolocation should be enabled to confirm the location, date and time of each image. Each image file name should include a plot number and detail reference according to the numbers used in paragraph B7. For example, Plot 1 eaves detail would be P1/3b.”
Although SAP assessors have to sign a declaration to say that they have ‘reviewed’ the photographic evidence, they are not responsible for demonstrating compliance to the building control body or approving the quality of the photos. It is the developer’s responsibility to ensure that the building control body is satisfied with the photographic evidence:
“Building control bodies are authorised to accept notification of (a) to (d) above as reported in the completion stage BREL report together with photographic evidence of compliance.”
Developers should also bear in mind that the BREL report and photographs are to be passed on to the homeowner:
“For new dwellings, a signed copy of the Building Regulations England Part L compliance report (BREL report) and photographic evidence of the build quality should be provided to the homeowner.”
How will this change the way we work?
We aim to keep this as simple as possible, but there are still some unknowns about this new regulatory requirement.
What happens if the photographs are of poor quality? What happens if someone forgets to take them? Will it be possible to sign the BREL report digitally?
As the real world interpretation of the new Part L materialises we will adapt our procedures to minimise your administrative burden, and ours. It applies only to building control applications made on or after 15th June this year, and it will take another 12 months, give or take, for the as-built BREL reports to start appearing.