RE: ENVIRONMENTAL ACTION STRATEGY AND ACTION PLAN

Transcription

1 City of Sydney GPO Box 1591 SYDNEY NSW 2001 Via 17 August 2016 Dear Sir/Madam RE: ENVIRONMENTAL ACTION STRATEGY AND ACTION PLAN The Green Building Council of Australia (GBCA) commends the City of Sydney (CoS) on the Environmental Action Strategy and Action Plan (Action Plan). The Action Plan demonstrates strong environmental leadership and provides a clear direction which CoS, industry and key stakeholders can assist to cutting greenhouse gas emissions whilst bolstering capacity for climate adaptation and resilience. Since its inception in 2002, the GBCA has worked towards inspiring, influencing and empowering the property and construction industry by driving the adoption of sustainable building and community practices. To effectively respond to rapid changes facing our cities and towns in the context of globalisation, resilience and adaptation, technological advances and shifting social demands, the mandate of the GBCA has extended and evolved beyond green buildings to also address the broader challenge of catalysing a sustainable cities movement. As a valued member of the GBCA, we appreciate the opportunity to provide comment as part of the public consultation. Comments from the GBCA are outlined below. 1. The GBCA commends the City of Sydney on the proposed expectations for excellence in environmental performance in new buildings The GBCA understands that it is not just government that can lead by example and take responsibility; industry must also lead the way. There has been confusion amongst industry that the CoS proposed expectations for excellence in environmental performance in new buildings (p, 15), is being mandated. The GBCA understands that this is not the case and supports the CoS proposed expectation, however, we recommend CoS clarify this to see the Action Plan more clearly identify that CoS expectations for excellence in environmental performance in new buildings (as of 2016) is an aspirational outcome, and Green Star and the other measurement references are not being mandated within the Action Plan. The GBCA would recommend reference to Green Star on page 15 of the Action Plan be amended to reflect the below table.

2 GBCA recommended amendments to page 15 of the Action Plan Development Type Aspirational Benchmark Aspirational Target Residential Green Star certified rating Commercial Office (Premium) Green Star certified rating Commercial Office (Non- Premium Green Star certified rating Retail (Shopping Centres) Green Star certified rating 5 Star Green Star or higher: Green Star - Design & As Built rating. 6 Star Green Star Design & As Built rating. 5 Star Green Star or higher: Green Star - Design & As Built rating. 5 Star Green Star or higher: Green Star - Design & As Built rating. By applying Green Star certified rating as the aspirational benchmark, this avoids confusion that equivalency is a desired outcome by CoS. The GBCA acknowledges that business as usual will not assist CoS in achieving the ambitious environmental targets that have been set in both this Action Plan and Sustainable Sydney The Value of Green Star report (2013), looked to quantify the overall impact of the Green Star rating system on greenhouse gas emissions, operational energy usage, operational water consumption and construction and demolition waste. The study compared data from 428 Green Star-certified projects with buildings that just met average or minimum practice standards. I have enclosed a copy of the Value of Green Star: A Decade of Environmental Benefits, Research Key Findings (2013) report for further information. The report found that on average, Green Star-certified buildings: produce 62 per cent fewer greenhouse gas emissions than average Australian buildings use 66 per cent electricity than average Australian buildings use 51 per cent less potable water than if they had been built to minimum industry requirements. The higher the Green Star rating, the greater the environmental savings across all key areas greenhouse gas emissions, energy use, water consumption and construction and demolition waste.

3 2. The GBCA recommends that Green Star be the most appropriate rating tool for hotels and serviced apartments in the City of Sydney. The GBCA notes that section three of the Action Plan references international rating tools (LEED and Earthcheck) as aspirational benchmarks for hotels and serviced apartments in the local government area. The GBCA strongly recommends that Green Star be the preferred aspirational benchmark for these developments as the Australian The Green Star rating system covers nine categories (Energy, Water, Management, Transport, Land Use and Ecology, Emissions, Indoor Environment Quality, Materials plus Innovation. The Green Star rating tools have been developed by the Australian industry and locally adapted to suit the Australian market. There is no alternative that is as robust as the independent third-party assessment that is the basis for Green Star-certification. The outcomes of a certified rating may be as follows: Best Practice (4 Star rating), Australian Excellence (5 Star rating) and World Leadership (6 Star rating). All Green Star certified projects produce sustainability outcomes that are typically much better than minimum legislative requirements. For instance, a 4 Star Green Star rating will always be at least 10 per cent better than a building that simply meets code requirements from an energy perspective. In line with the GBCA s strategic priorities and proposed revisions to and Green Star Interiors, additional emphasis is being placed on the reduction of greenhouse gas emissions for Green Star projects. The proposed revisions will introduce minimum greenhouse gas emissions thresholds in order to achieve higher-level Green Star ratings (5 and 6 Star). Proposed minimum points thresholds are listed below: Green Star rating Minimum Points in GHG Emissions Credit Improvement over BCA 4 Star 1 (Conditional Requirement) 10 per cent 5 Star 3 25 per cent 6 Star 6 40 per cent The thresholds must be met through on-site solutions (efficiency or on-site generation). Off-site solutions (such as district scale solutions or Green Power) will not be recognised for these thresholds. This proposed change guarantees that Green Star rated buildings are significantly improving on NCC requirements. As benchmarks increase over time, Green Star rated buildings will continue to excel in energy and emissions and water efficiency. Furthermore, leading sustainability indices such as the Global Real Estate Sustainability Benchmark (GRESB) which has ranked Australia s real estate market as the global green leader for five years straight recognises Green Star ratings as the best measure of sustainability outcomes in our property industry. Currently within the CoS, there are nine Green Star-certified Multi Unit Residential projects, with a further 11 projects registered, including the ICC Hotel. These projects include: Anandara and Alexander, Barangaroo: 5 Star Green Star Multi Unit Residential Design East Village Residential, Zetland: 4 Star Green Star Multi Unit Residential Design The Quay, Haymarket: 4 Star Green Star Multi Unit Residential Design

4 Redfern Housing Development Project, Redfern: 5 Star Green Star Multi Unit Residential (Pilot) No. 1 Central Park, Chippendale: 5 Star Green Star Multi Unit Residential ICC Hotel, Haymarket: targeting a rating

5 3. Green Star Performance can assist inform the market and drive upgrades for residential apartment buildings. The Action Plan identifies that the CoS will advocate for a credible independent performance benchmark, such as NABERS rating tool, to inform the market and drive upgrades for residential apartment buildings. The GBCA supports the expansion of NABERS Energy; however, Green Star Performance appropriately addresses this issue for high-rise apartment buildings within the city that have substantial common areas. The Green Star Performance rating tool assesses the operational performance of existing buildings across nine impact categories. The rating tool enables building owners and managers to identify pathways to improve the environmental and financial sustainability of their asset(s) over time. The rating tool awards certification from 1 Star Green Star through to 6 Star Green Star (with a three-year re-certification process). The Green Star Performance Energy category rewards building owners implementing strategies and taking actions to measure and reduce a building s operational energy use, below that of a comparable standard practice building. Such reductions are directly related to reduced greenhouse gas emissions, lower overall energy demand as well as reductions in operating costs for building owners and occupants. Given the high volume of new high-rise apartments expected to be built in the city, Green Star Performance provides a significant opportunity to secure long-term environmental performance, as well as lower running costs for strata managers and occupants through encouraging commitment to Green Star Performance.

6 4. The GBCA is ideally placed to help connect and inform industry stakeholders with government. As the GBCA has more than 700 member organisations, including major developers, professional services firms, major banks and super funds and product manufacturers and suppliers. With 10 per cent of members from government at a local, state and federal level, it is ideally placed to help connect and inform industry stakeholders with government. The GBCA recently collaborated with the Australian Sustainable Built Environment Council (ASBEC), Australia s peak body for sustainability, on the development of the Low Carbon, High Performance report. The report finds that Australia s built environment sector can reach zero carbon by 2050, deliver healthier and more productive cities, and save more than $20 billion using technologies that exist today. Australia and the international community adopted the ambitious Paris agreement to decarbonise the global economy and to limit the impact of climate change. The ASBEC report is intended to provide policy makers with an outline of the potential for the Australian built environment sector to make a major contribution to net zero emissions targets by The built environment can also tackle other national priorities including improving energy productivity, supporting innovation, making efficient use of current and future infrastructure, and creating healthier, more liveable cities. To support industry and government with this task, the GBCA is taking concrete steps to facilitate the uptake of net zero buildings. The GBCA has been working with NABERS and the Department of Environment to adapt the Australian Government s Carbon Neutral Standard for buildings and precincts. The Advancing Net Zero project, a collaboration between World Green Building Council and green building councils in Brazil, Canada, Germany, India, Netherlands, South Africa and Sweden is the next step towards a commitment to recognise buildings, fitouts, and communities that achieve net zero, or even deliver positive outcomes in terms of energy, carbon and water. The GBCA is also working with the Clean Energy Finance Corporation to provide mechanisms for measuring GHG emissions reduction to non-nabers eligible projects. Furthermore, in 2015, the GBCA was commissioned by the Australian Government s Department of Industry Innovation and Science to develop a pathway document for mid-tier commercial office buildings to tackle the energy productivity of up to 80,000 buildings around Australia. Commercial buildings account for about 10 per cent of the nation s overall energy consumption, with buildings being responsible for 23 per cent of Australia s greenhouse gas emissions. The project aimed to gain a greater understanding of the mid-tier commercial office-building sector, including the key stakeholders, the barriers to uptake of energy efficiency initiatives and the opportunities to drive change. The subsequent pathway document presented a number of actions that could be used to check progress against the overall goal. The actions are: 1- Develop a robust and trusted evidence base 2- Build a compelling and quantified business case for energy efficiency upgrades 3- Create a shift in awareness, knowledge and behaviour 4- Develop and identify tools to promote improved energy performance 5- Establish representative bodies and network 6- Promote innovative financing mechanisms. Prior to the federal election, the Turnbull Government announced that the Commercial Building Disclosure (CBD) Program threshold would be reduced from 2,000sqm to 1,000sqm. This policy will see the energy efficiency ratings for an additional 1,000 commercial buildings disclosed at the time of sale or lease. Considering that our buildings are responsible for 23 per cent of greenhouse gas emissions, mandatory disclosure will encourage building owners to explore the range of services, resources and technologies that can deliver building upgrades. With more than 335 Green Star Performance certified projects across Australia; the rating tool is assisting industry and government to reduce greenhouse gas emissions from our buildings.

7 The GBCA commends the City of Sydney on the Action Plan as it provides strong direction towards reducing the city s environmental impact, in alignment with broader global efforts to reduce greenhouse emissions and improve capacity for climate adaptation and resilience. Please do not hesitate to contact me on , or luke.farr@gbca.org.au for further information. Yours sincerely Luke Farr Manager - Advocacy luke.farr@gbca.org.au