Green Star Feedback Review Rating Tools

Transcription

1 Green Star Feedback Review Rating Tools

2 Executive Summary The Green Building Council of Australia (GBCA) values the feedback of members and other stakeholders as we continue to evolve the Green Star rating system. In early 2016, we asked industry for feedback on the Green Star certification process and the new generation rating tools. This Green Star Feedback Review Paper responds to 12 submissions gathered during this process. This public feedback report will also inform briefing documents for the Green Star Steering Committee, which will assist the GBCA with further improvements to Green Star, the certification process and our education offerings. While the feedback received was highly varied, some common themes emerged: International rating tool alignment Stakeholders want Green Star to complement international rating tools. The GBCA has been collaborating with other rating programs to agree upon cross-walks areas of alignment between rating tools which will enable projects to pursue dual ratings where verified outcomes can contribute to achieving an additional rating. This may involve Green Star outcomes contributing towards another rating; or another rating tool s outcomes contributing towards a Green Star rating. A crosswalk is currently underway for the WELL Building Standard, which is intended to be published with release of the Green Star v1.2 Submission Guidelines. Cross-walks are also in development for Living Building Challenge and PassiveHaus Australia. Pace of change Conflicting feedback was received regarding the pace of change of Green Star rating tools, with concerns expressed that revisions can happen too quickly, and that revisions are not occurring frequently enough. We understand it is important that our customers feel comfortable with the content of the rating tools without worrying about constant changes. We also understand that customers want the latest determinations from queries so that additional guidance and pathways can be maximised. Currently, technical/tactical (minor) revisions aim to improve the clarity and use of the rating tools. These revisions occur no more than once each year. Strategic (major) revisions are on a minimum three-year cycle. Coinciding with the latest minor release, clear revision marking within credits and change logs at the start of the Submission Guidelines and at the end of each credit have delivered a streamlined, up-to-date document. The GBCA recognises that communication regarding minor releases requires ongoing improvement, and we work closely with our education team to ensure our stakeholders understand how updates affect active projects. The GBCA will continue to work to optimise this process. Time to resolve queries Concerns have been raised that the GBCA has limited resources which can result in extended timeframes for the resolution of queries. We recognise this can be a challenge to project teams when the query is mission critical. We are working hard to improve the experience of our customers. We currently strive to answer all queries within a maximum tenday time frame and have implemented a system to monitor and optimise query responses, and associated KPI targets have been set. While queries range in complexity, it is envisaged that this will drive down the average response time for queries and we will be monitoring our progress. Submission templates Green Star users have found that submission templates require ancillary information that at times is duplicated, or the submission template prompt is irrelevant to the required information to demonstrate compliance with a credit. Additionally, users are unsure of how to accurately complete submission templates. Submission templates are a main component of the new generation Green Star rating tools. With the release of Green Star v1.2, the GBCA will create a webinar to help customers best use the templates for their submissions. In addition, we are adjusting our systems so that documents attached in other areas of the submission can be referenced and not attached again. Cost of Green Star Feedback from industry has indicated that, at times, there is a wide range of costs associated with achieving Green Star certification, such as the modelling of systems, time and additional documentation requirements. Reducing these costs continues to be an area of focus for our team. Submission costs have come down considerably since the introduction of the new 2

3 generation rating tools, as a result of changes including the introduction of the optional Design Review, which replaces Design ratings; the move away from prescriptive documentation requirements to a more flexible system; and the introduction of Volume and Portfolio certification models to provide a streamlined approach to projects with similar characteristics. The GBCA now tracks costs through the Financial Transparency Innovation Credit, and has released our findings in a research paper. While this is intended to be used only as a guide, the findings reveal that the cost of Green Star implementation is a small component of overall project costs. This report is publicly available on our website and will be updated on an annual basis. We understand there is more work to be done and this is why we are creating additional education resources to ensure GSAPs can keep up-to-date with changes to documentation and assessment practices. We will also continue to introduce more flexible practices and streamlined documentation requirements to eliminate duplication where possible. Volume certification Industry has requested clarification on how the Volume certification process works. The GBCA has developed a document which outlines the process, which can be accessed online. We encourage project teams to work in partnership with us. Technical workshops can aid clarity on the process and the expected outcomes for specific projects. Education and engagement While no specific feedback was received relating to education and engagement on the rating tools themselves, we have identified some opportunities to improve the user experience of Green Star. Areas of opportunity include: further education for existing GSAPs; more focused courses and workshops based on industry requirements, category type, certification and practical application of Green Star; updating the Green Star foundation courses, including the content and delivery methods; expanding the use of case studies of certified Green Star projects; and enhanced communication around the releases of the rating tools. As part of the GBCA's strategic review to broaden market transformation, we will launch a new professional development program. It is expected that this will commence in 2017 and will require broad market engagement including those currently in the Green Star Continuing Professional Development Program, as well as those previously enrolled. The GBCA would like to thank all stakeholders for taking time to provide their feedback and insights into their experiences with the Green Star rating tools. Many of the items of feedback have already influenced the content of the rating tools and processes, and others are being saved into an action register for further consideration and implementation as the opportunity arises. The feedback provided by both individuals and organisations working with us is vital to future development of Green Star and a sustainable future for us all. 3

4 General Feedback The following table outlines general feedback received from industry. Issue Feedback Suggested Amendment GBCA Response Extent of Documentation required in New Tools We do not believe that for the new tools the volume of required documentation is reducing. We believe in some cases it is getting greater We believe the GBCA should rethink the standard cover page details as the volume of work to fill in these items is just as time-intensive as producing our own short report. The GBCA should move to online submission of tick the box and signing forms with contact details of individuals like LEED. We also do not think unnecessary explanations of what projects did is necessary such as "how did you comply with the low VOC credits". This explanation is unnecessary. Submissions should move to what materials were installed and providing only up to 20% VOC data sheets and receipts The Submission Template is intended to be a standardised document which project teams use to explain to the Assessor their methodology for achieving compliance. Prompts are only intended where this is a Green Star requirement that needs to be addressed or responded to. Feedback on time required to fill in the template has been mixed, with some projects seeing significant reductions in the time it takes to do so, vs. others that don't believe the templates save time. Some of this is based on changing expectations as to what information is needed to satisfy the assessment. Additional education and guidance will be provided. We do appreciate that some prompts may be considered redundant. With each minor rating tool revision, the Submission Templates are reviewed and refined. We will also rethink the submission process as part of upcoming work on improving the customer experience. This will include consideration of a more digitally-based approach. This will allow us to simplify some of the data collection requirements. With regard to only providing 20% of VOC data sheets and receipts, we have looked at exploring partial submissions for distinct credits. The worked to date indicates that such a change can reduce cost, it also significantly reduces the stringency and auditability of the rating. More work will be done for the next major release. Number of Queries Required We feel the number of clarifications required to the GBCA has increased with the release of the new tools due to credit criteria in the new tools being unclear or unachievable. We suggest the GBCA issue continually revisions to each credit when it is identified that there may be an omission or issue with the details noted. We believe this should be issued as addendums to the tools to prevent project teams from having to complete clarifications for each project With regard to the number of questions, these have been falling on a total basis, even when excluding for the legacy rating tools. However, we will continue to work to reduce the need for queries as part of upcoming work on improving the customer experience. As for releasing revisions for each credit as needed, previous experience suggests that causes more confusion and frustration. As such, based on feedback provided by industry, revisions are limited to minor releases on a minimum 12 month interval. Logo Older logo (& quotes) are still used in a number of active GBCA marketing & communications. Update logo in material which is still being issued. Future revisions of the Rating tools will ensure that the most recent organisation logos and branding are used. General Website has improved but still has some areas that could be more 'navigable'. e.g. The certification section says you need to inform your case manager of your intention to submit using the Submission Notification Form but there is no link to the form and it s difficult to find where that form lives which we eventually found. This has been addressed with the new website launched in July We are moving towards more online functionality. Where specific feedback can be provided with regard to the navigation of the website, feedback is requested at the following link. 4

5 Certification process feedback The following table outlines the feedback received by industry regarding the Green Star Certification Process. Aspect Issue Feedback Suggested Amendment GBCA Response Assessment process Design Review Submission We believe the Design review submission needs to be reworked to make it beneficial to project teams and provide more than just a marketing benefit for clients We believe the Design review submission needs to be reworked to Design Review credits like the LEED system. Design credits are submitted at Design and As-built credits issued post PC like the LEED rating system. Submitting forms stating a project will comply with the criteria with no evidence is more time-consuming than helpful and leads to no benefit to any party. Currently the Design review stage as communicated by the GBCA could actually be undertaken at the time of registration whereby the GBCA asks that the project identify which points they propose to target. The Design Review stage is a non-mandatory aspect of our rating system. It aims to provide certainty to a future buyer or tenant that a commitment exists to tackle specific issues within the rating tool. Submitting at the 'Design' stage aims to assist projects seeking a label, or reducing their risk. They can submit as little, or as much information as possible to do. For example, a project team may choose to submit a light submission if they are confident of their strategies, or they may choose to submit more detailed designs if they would like more feedback. It is up to the project team to make use of the 'Design Review' process as they see fit. The Market Communications team will be working to develop clear, concise communications on the benefits and purpose of the Design Review. Assessment process The certification process Documentation collection and assessment process Decentralise the certification / assessment process to shorten the certification Independent third-party assessment is a key element of takes too long can be drawn out which minimises marketing period. I.e. GSAPs/industry experts (internal or external) could certify Green the value proposition of Green Star certification. This is opportunities for the project. Star as per other regulatory ESD processes. GBCA could undertake audits etc. a process that we remain fully committed to, while also to ensure compliance. Potential to expand the uptake of Green Star and recognising the needs of our customers and therefore maximise commerciality and competitiveness in the industry. the imperative to streamline the process. We continue to work to improve Assessment turnaround times, as an extended process can cause undue stress on project teams. We have seen ongoing improvements in turnaround times due to the staged assessment process as well as reduced requirements for the Design Review. Further, with a streamlined Design Review process, project teams are able to market projects much earlier in the development stage. Other initiatives such as 'Recognised Provider' aim to streamline the certification process at the service level, and we will continue to explore the opportunity, to decentralise the certification process as much as possible. 5

6 Aspect Issue Feedback Suggested Amendment GBCA Response Portfolio certification N/A Introduction of the portfolio certification process has provided significant benefit to our organisation allowing faster certification at scale. The learnings from this should be applied more broadly. Review why portfolio process has worked well and what can be improved and also transferred to other aspects of certification. In particular, the increased GBCA support resulted in greater transfer of project knowledge to the assessor which streamlined the process. We will seek additional feedback from project teams who worked on portfolio projects as well as Certified Assessors who assessed the portfolio projects to determine what worked, what can be improved and how learnings can contribute to other GCBA and project processes. Single project Too costly Despite the new tool and improved processes, too Education campaign We recognise that more work can be done to educate certification many consultants had a poor experience using Modify assessment process industry on the benefits and cost savings of using the legacy tools and are still pricing in significant Be more flexible with acceptable documentation new generation rating tools. The most recent project additional costs for where a project is undergoing Consider self-accreditation for endorsed organisations. research undertaken (Green Star Financial Green Star certification. Transparency) outlines the cost of documenting and implementing Green Star, which we encourage applicants to review to better understand the costs associated with Green Star that are over and above standard practice. We note that the assessment process has been modified significantly for New Generation rating tools, and flexibility in acceptable documentation has been incorporated. Please refer to the 'Recognised Provider' program for accreditation of organisations' internal processes. We will be creating additional education resources to ensure GSAPs can keep up to date with changes to documentation and assessment practices. We will also continue to introduce flexible practices and streamlined documentation requirements to eliminate duplicated documents as far as possible. Volume certification GBCA clarity We have been working on trying to get clarity with how the finer details of volume certification process will work for some time. This is still an ongoing process however is close to resolution. Despite the potential benefits being significant, in the meantime we have incurred significant additional costs in consultant fees and time. The volume certification approach required more GBCA resources to be resolved quicker and more effectively. We are working to clarify and streamline the Volume Certification process. We will work to provide clear communications around the Volume Certification process. 6

7 Aspect Issue Feedback Suggested Amendment GBCA Response Technical support Limited We are concerned that the GBCA has limited technical resources which results in issues often taking a significant amount of time to resolve. This can be an issue when they are critical to the design or construction which needs to proceed. Develop a business case to bring on additional technical resources. Increased resources will allow for quicker resolution of issues, improved processes, etc. which should translate into increased uptake and certifications. We acknowledge that at times project teams can be dependent on responses in order to progress critical project items and our responsiveness is an important issue. In order to provide support to project teams, earlier this year, we allocated two principal Sustainability Services staff to each registered Green Star project, rather than one. We also use external peer reviewers as required and have the support of, and access to, the resources that can be made available through the GBCA Technical Advisory Group. The Green Star Project Manager portal has also been updated within the last couple of months, in order to facilitate answering technical requests from project teams as promptly as possible. Project teams can now not only request Technical Clarifications and CIRs, but also submit their documentation online, update their project records and request meetings too. We have indicated a standard turnaround time of 10 working days to respond to technical requests such as Technical Clarifications and CIRs. The average turnaround time for query responses such as CIRs and TCs is trending down, currently with 90% of all queries completed within this timeframe. We are continuing to work to improve the customer experience through a new review of internal processes and resources. We have now implemented a system to monitor and optimise query response, and associated KPI targets have been set. While queries range in complexity, it is envisaged that this will continue to drive down the average response time for queries and we will be monitoring progress on this goal. Volume certification The process of the volume Having worked on a volume certification project, A pro-forma developed by the GBCA based on experience with the tool We are working to clarify and streamline the Volume certification needs to be the information required to make the rating a outlining early on the roles required within an organisation to make it work, the Certification process. We will work to provide clear properly defined success will fall on being able to spell out exactly documentation that is typically provided by the organisations, suggestions on communications and welcome any input that projects are what roles are required and the documentation appropriate benchmarking etc. At the moment there is very little support for willing to share. attributed to each role to satisfy the volume organisations considering the jump to volume certification. If you can develop requirements. Not just in technical terms but also this kind of supporting documentation, it gives a clear framework early on for based on the standard requirements unique to the teams to work with. JLL is happy to work with the GBCA in communicating volume process. This level of detail will be useful what worked for the CBA volume certification process. at the beginning of a project when a Client is considering undertaking a rating of this type 7

8 Aspect Issue Feedback Suggested Amendment GBCA Response Portfolio certification Encouraging improvements GRESB is a strong driver for organisations wishing Competition works in encouraging improvements, especially to portfolio We are in the process of developing a report based on to the average star rating of to undertake portfolio certification. There is no averages. JLL recommends considering the model of GRESB (performance anonymised performance data of certified projects, a Portfolio Rating current driver to improve the average ratings of plotting on graphs) of Australian Green Star Performance Portfolios on an scheduled in line with the release of portfolios unless internally driven. annual basis. Only those portfolios that give permission will be disclosed as Performance Version 1.2. part of this exercise. The idea being that the top performing portfolios who give permission to disclose their rating will leave the remaining an incentive to achieve a better outcome the following year. Portfolio certification The threshold of achieving a Currently, the threshold for achieving a Portfolio JLL recommends having a cutoff date for 0-1 star average portfolios. This will We note that there are building types where the existing Portfolio Rating Rating is 0 stars. While useful in encouraging the ensure that portfolios who have been hesitating to commit to a rating will race to operational data is beyond the control of the building uptake of portfolios being rated, the bar needs to sign up before the end date and also ensure any future portfolios will be starting owner and unavailable. In these instances, it may not be be lifted eventually to ensure improvements from at least a 2 star average to be rated. possible for assets to achieve the required points for a continually occur. rating. The overall concern of raising the bar for portfolios is noted, and will be subject of a long term engagement activity and advocacy from us. Other The integration of WELL The partnership between the GBCA and the IWBI JLL suggests developing WELL Modules to integrate with existing Green Star We are in the final stages of alignment between Green ratings to Green Star is a natural step for the Australian market. There tools. If, for example, a Green Star Interiors rating is being pursued then only Star - and the WELL rating tools. The are some issues in what is applicable in Australia Design based criteria from the WELL standard will be applied. If the building next stage of the alignment is between the vs the US and also the integration with a tool that then targets a Green Star Performance rating, a WELL Performance module is Performance and WELL rating tools. contains both design and operational criteria. applied. These modules will also reflect gaps between the Australian / US market to save on costly and inefficient methods of testing. Assessment More face to face with assessors is encouraged as Continue to promote this form of engagement. Suggest meetings occur after Despite the option being available for more than a year, Process it has the potential to work well. assessors have had a chance to review submissions prior to Round 1 this has had little uptake from project teams. comments being provided. We will continue to work to provide clear communications around the project team and Assessor interaction service available and facilitated by the GBCA. On-line submission Relatively new but a good initiative. Default time Open portal when project is registered, close automatically when submitted by This function of the online portal has been implemented. portal windows to upload need to be managed. AP. Other Accessibility Green Star has been a fantastic tool for strong institution, govt and/or developers. How is this extended to and made more accessible for smaller inexperienced teams/clients? Is there a formal "first timer" pathway/program that could be provided to support the ratings tools that is almost a "hand in hand" for new teams/clients? This way it helps embed the skills and within these organisations. The foundation courses are great for individuals (I've just reviewed these as part of the skills advisory) but something more formal for organisations might be worth exploring? We will work to provide learning opportunities for new stakeholders of the Green Star suite of tools. 8

9 Rating Tools The following table outlines the feedback received by industry regarding the technical content within all, or each of the Green Star rating tools. Rating tool Issue Credit Criterion Feedback Suggested Amendment GBCA Response All Documentation PVC Currently for non-pvc products there is a requirement for the The requirement could also offer option of a third party We note that third-party certification such as Ecolabel can be requirements an EPD, however, that should not be the only option considered certification such an Ecolabel which ensures that other negative considered equivalent to an EPD and encouraged to be used to impacts along the product's lifecycle are minimised. demonstrate compliance. A Technical Advisory Group has been established to focus on product certification schemes to provide direction on a simplified approach to product certification scheme recognition in the rating tools. All Compliance Sustainable products EPDs are very much welcome to encourage transparency in the A position paper was sent to GBCA last year in this regard in The relative weightings for the different 'Transparency and requirements industry. However, they really should be under a support of our view and is attached again in the along Sustainability' initiatives were determined as part of the Green "disclosure/transparency credit" rather than a "sustainable with this spreadsheet. Star - development process. This occurred in product" credit. Say, the terminology is disregarded and they close consultation with industry. are included in sustainable products credit as they are currently, there needs to be more differentiation in weighting between A change such as the one suggested in the position paper is EPDs and Level A third party certification. not feasible under a minor revision of the Rating Tool. This feedback will be further considered in our next major revision. All Compliance Credit 11.2 Lighting engineers have expressed a lot of issues with the We would ask that the GBCA visit the requirements for credit We have recognised this issue for surface illumination and will requirements measures of compliance that are listed in this credit compliance investigate appropriate pathways for demonstrating compliance in the future. In the short term, we encourage the use of evidence based documentation to provide an alternative pathway through a technical query. These developments can help to inform the future direction of the credit. 9

10 Rating tool Issue Credit Criterion Feedback Suggested Amendment GBCA Response All General All We are finding that the GBCA is revising tools too quickly and this makes it difficult to stay knowledgeable on what forms part of a rating tool We would suggest that the GBCA consider only revising tools every 2-3 years and between the release dates they issue addendums to the tools only which project teams can use We have moved away from 'addendums' (also known as Rulings) based on feedback from industry. Feedback from project teams is that they are finding that the constant referencing of multiple documents was not an easy approach to understand the rating tool. The minor updates to the rating tool (0.1) have taken the place of the Rulings. The intent of the minor releases is to capture all feedback provided via communication with project teams and formal queries. All changes are clearly marked and also captured in the Change Log. Minor revisions are restricted to a minimum 12 month interval to limit the frequency of change. Major releases are planned for a minimum three year cycle to ensure that the current highest levels of sustainability are realised. This is an acknowledged change in process from previous methods of updating the rating tool. We will continue to work to ensure that the update process is as streamlined as possible. We recognise that the communication of changes in the minor releases has been limited. It is planned to improve the communication on upcoming releases, and provide education channels for active project teams to outline how the updates affect active projects and guidance on their use. A recently implemented improvement with the latest minor releases has been to include clear revision marking within credits and change logs at the start of the Submission Guidelines and at the end of each credit. This has resulted in a streamlined, up-to-date document. All General Contents, page numbering, credit numbering to be improved Credit list page needs page references; Would be beneficial if credit naming convention was consistent across tools and versions The PDF versions of the Submission Guidelines do include bookmarking to assist with navigation. We will take these suggestions on board and ensure improved page referencing at the next minor releases. All General No bookmarking of submission guidelines or hyperlinking Introduce bookmarking, hyperlinking etc. The PDF versions of the Submission Guidelines do include bookmarking to assist with navigation. We will investigate the use of hyperlinking. 10

11 Rating tool Issue Credit Criterion Feedback Suggested Amendment GBCA Response All General Why do we have to submit a CIR from a new tool (Interiors v1) within the older tool (Office Interiors v1.1) Should be a simplified process to allow this to occur, at least for 80%+ of cases We have developed a credit substitution matrix and instructions document for applying New Generation rating tool principles in Legacy projects. A complimentary query is the most straightforward method of approving these. It is acknowledged that some credits can be directly substituted; however, there are some instances where there are complexities within the substitution that need to be determined before assessment. This ensures that the Certified Assessors assess against the correct credit criteria. For New Generation Green Star projects, a credit substitution query is not required and later versions of credits can be picked up and used. This is intended to make the latest version of all Green Star credits more accessible. All Innovation Challenge vs Market Transformation - should it be Potentially reframe or rename these to Market Transformation This suggestion to reframe or rename these categories will be a renamed while still rewarding genuine Innovations separately discussion with the Innovation Technical Advisory Group. Compliance Climate The Climate Adaptation compliance requirements do not specify For recertification, project applicants should show that the The credit has been updated to reflect this approach in Green Communities requirements Adaptation that 'high' or 'very high' risks identified in the plan need to be climate risks have been attempted to be mitigated. Star - Communities v1.1. addressed or responded to in the project design (As it does in ). Technical 6 - Sustainability The Credit Criteria & Compliance Requirements states the Amend the documentation requirements to reflect the credit The credit has been updated in Communities v1.1. Communities content Awareness following: criteria. 6.1 Community User's Guide 6.2 Sustainability Education Facilities The Documentation Requirements states the following: 6.1 Sustainability Education Facilities 6.2 Community User's Guide Compliance Sustainability Guidance for the sustainability education facilities are two I suggest that an option of including a "sustainability information The examples listed are extremes in part to highlight the fact Communities requirements Education Facilities extremes. wall" inside a community facility would be sufficient to meet this that there are many different approaches. They are simply credit. examples. It is not intended that the Guidance section for each credit will list available options, but rather illustrate the diversity of approaches that may be considered. We are considering future communication methods to inform industry of good practices while not implying that there is a preference or limitation to what can be done, or providing specific design guidance. 11

12 Rating tool Issue Credit Criterion Feedback Suggested Amendment GBCA Response Technical 11 - Sustainable NatHERS and Silver Level Liveable Housing are two separate Award NatHERS and Silver Level Liveable Housing The requirement for the combination of both initiatives was Communities content Buildings initiatives independently of each other. identified as evidence of a more holistic outcome for individual dwellings that is comparable to buildings that have been through a Green Star certification or equivalent NatHERS and The residential requirements within this credit are very difficult To encourage developers to influence house design prior to The requirement for the combination of both initiatives was Communities Livable Housing to mandate and manage where the developer does not have commencement of the development allow a public commitment identified as evidence of a more holistic outcome for individual Australia control over the dwelling design. Rather than recognising efforts to reach a percentage to be awarded points. E.g. if there is a dwellings that is comparable to buildings that have been to improve housing it is too much of a stretch for greenfield public commitment for the project to achieve 25% LHA silver through a Green Star certification or equivalent. development. and 7 NatHERS Stars = 1 point. This can then be measured afterwards upon recertification. It is noted that a confirmation of commitment is already provided in this credit with partial points available NatHERS and Sustainable Buildings Credit - If residential then NatHERS and Need clarity in the technical manual that residential buildings MURT buildings are eligible to be rated using Communities Livable Housing Liveable Buildings Australia requirements are quite strict. You (e.g. MURT) CAN demonstrate compliance via the Green Star so can use the Certified Non-Residential Australia don't achieve these via Green Star pathway rather than NatHERS Buildings pathway instead of LHA and NatHERS. Desired 12 - Culture, 12.1 and 12.2 outcomes are similar, if not the same. By 3 points are available for the undertaking and implementation of The credit criteria are deemed to be separate. As detailed in the Communities outcome Heritage & Identity developing an Interpretation Plan which provides guidance, is it an Interpretation Plan. credit 12.1 represents the process related to this specific not assumed you would take the results into consideration by sustainability outcome with 12.2 representing the outcome that acting upon these? has resulted from that process and is reflected in the plan for development. 18 Employment Economic Resilience & Employment - too specific (idealistic) The credits have been altered in version 1. An improved We have identified the Employment and Economic Resilience Communities and Economic about employment industries. definition of "diverse employment" needs to be clarified with a credit for detailed review for the next major release. The depth Resilience Issue - the maths: If over 50% of employable people need to suitable economic professional. The % calculations also need to of change required was not suitable for a minor version update. be employed in Type A, and under 50% in Type B... what be reviewed, and accommodate for varying development happens to everyone else? It simply doesn't make sense, as locations and the needs of the community. A community should described by RPS: be rewarded for stimulating sustainable economic growth Feedback from RPS Economic Study - Re: Econ Econ 1.2. relevant to its needs. Additional points if a community is taking Diverse Employment: (Type A and Type B industries) - The into account future growth industries, technologies, social GBCA credit criteria stipulates that one credit is available for services, social enterprise, renewable energy, and business employment diversity where a) at least 15% of jobs are from ownership. Type A industry sectors and b) Type B jobs do not constitute more than 50% of total jobs. For a large site this would require significant government investment and commitment. However the private enterprise is not rewarded for providing over and above the number of jobs. (if over 50% are employed in these industries they are penalised). Note: The definition of jobs by "GBCA Type" is too constrained, with little to no clear intent described. Type A jobs refer to those in public service, administration, education and welfare 12

13 Rating tool Issue Credit Criterion Feedback Suggested Amendment GBCA Response Compliance 18.1 Increase in On a greenfield site, where retail is being included as a part of A prescriptive pathway to be introduced for 18.1 (Increase in We have identified the Employment and Economic Resilience Communities requirements Local Jobs the development, it is obvious that the development will result in local jobs) credit to be awarded if the plan for the development credit for detailed review for the next major release. The depth a net percentage increase in the number of jobs generated. is to include a retail centre. of change required was not suitable for a minor version update. Where the benchmark is no jobs (from a green field site) is compared to a community with a retail component. It seems silly to pay a consultant to tell us the obvious. Compliance Skills The Skills Development Program Compliance requirements do Add new compliance requirements. The revised Compliance Requirements are now included in the Communities requirements Development not accurately reflect the desired outcomes of the credit. The (See CIR submitted from Frasers Property Australia for Communities Submission Guidelines v1.1. Programs Compliance requirements have been changed for Frasers Edmondson Park 1860C) Property (through a CIR) and should be changed in the submission guidelines for the next Communities handbook. Desired 20 - Return on Analysis of direct costs and benefits is unnecessary. This is Noted. This comment will be used to inform the next major Communities outcome Investment typically done once for one project and becomes a box ticking revision of Communities. exercise thereafter. Limited amount to learn from after one project is completed. Benchmarks 24A.1 Stormwater The integrated water cycle to maintain a 75% total annual runoff Insert an alternative method of compliance where by you can The credit has been updated in Communities v1.1. Communities Performance may lead to the development to install a tank that may be either achieve the 75% reduction OR install a rainwater tank to Pathway significantly oversized that may not be easily accommodated on achieve a target non-potable demand (E.g. 80%). Although the The Stormwater Management criterion that was causing issues a site that has spatial limitations. As a result this may deliver a community tool is not designed to rate buildings, the retention of has been withdrawn from the credit. Over the next year, a small perverse outcome that may require the specification of stormwater on site can only be justified if there is a use of it, subgroup of Technical Advisory Group (TAG) members and inefficient fixtures and fittings to justify a larger tank. rather than just retaining it on site. This ensure the development representatives from project teams that have and are working maximises the use of the resource. on Green Star Communities projects and who specialize in Water Sensitive Urban Design (WSUD) / Hydrological Engineering will be invited to develop an updated / alternative approach that reflects both best practice and current documentation methods. 24A.1 Stormwater 75% of the total annual stormwater runoff to be evaporated or Remove this requirement from the minimum requirements for The credit has been updated in Communities v1.1. Communities Performance Pathway retained within the project site is extremely difficult for QLD the performance pathway. projects to achieve given the significant amount of rainfall experienced. 24A.1 Stormwater Stormwater - 75% of your total runoff to be retained or infiltrated See notes at left The credit has been updated in Communities v1.1. Communities Performance Pathway on site which relates to Greenfield development sites. Needs to be consistent with DAB tool Regenerated sites typically will have less runoff than what we had previously due to increased landscaping. This exceeds the requirement and could just be demonstrated through areas and runoff coefficients rather than stormwater storage and infiltration volume. We typically exceed requirement but have to go through a lot of work to demonstrate that. Needs to be consistent with DAB tool. 13

14 Rating tool Issue Credit Criterion Feedback Suggested Amendment GBCA Response Benchmarks 24A.2 Water The Water Sensitive Urban design performance pathway does Place an alternate methodology that allows the intent of the The performance pathway does allow the use of recycled water. Communities Sensitive Urban not allow the use of a recycled water solution. credit to be met by a water recycling plant Please refer to the Guidance for further information. If further Design Performance clarification is required, please contact the GBCA for Pathway assistance. 25 Greenhouse Gas In greenfield developments there is not control over the specific Accept a public commitment to reduce greenhouse gas Green Star seeks best practice outcomes. Communities Strategy house design. We are committed to influencing behaviour to emissions within the development with detailed calculation and incorporate more sustainable considerations to reduce GHG reduction strategy to influence residents as proof point to The credit seeks to encourage developers to develop emissions for the project. It is very difficult to demonstrate achieve the credits. Then monitor performance against these mechanisms to achieve a reduction in greenhouse gas meeting this credit in its current form. targets as the project is recertified. emissions through their ownership/responsibility over the plan for development they have control/influence/mechanisms that can be used to help with this. It is noted that a confirmation of commitment is already provided in this credit with partial points available. Other 26B Materials Communities Prescriptive Pathway The number of points for complying with materials do not align with the work required to document this, especially if one or two materials are targeted. 1 point should be available for each complying material. A change in the number of points allocated to a credit criteria is classified as a strategic update. As such it can only be considered as part of a Major update. This feedback has been noted to inform the next Major update of the Communities rating tool. Technical Communities content Construction and Demolition Waste Calculation of Points The method to calculate partial points is not straightforward. Be clearer on the workings for calculating partial points. 0.5 of a point is achieved for 60% reduction with the remaining 0.5 point available on a sliding scale between 60% and 100% reduction. This reflects that fact that you cannot achieve points until you get to a 60% reduction. The example at explains this. 31 Heat Island Effect Urban Heat Island Effect - consider an intermediate point as Consider an intermediate point to reward partial credit to A change of this kind (revision of a benchmark) to the rating tool Communities 50% of precinct area to meet SRI target is very difficult promote industry change is classified as a strategic update and can only be considered as part of a Major update. As such this feedback has been noted to inform the next Major update of the Communities rating tool. It is noted that this feedback is not reflected in the amount of projects that have targeted and achieved this credit to date. 33 Innovation Reconciliation Action Plans - not part of the governance credits, Should be part of the Governance credit A change of this kind to the rating tool is classified as a strategic Communities part of an innovation update and can only be considered as part of a Major update. As such this feedback has been noted to inform the next Major update of the Communities rating tool. 14

15 Rating tool Issue Credit Criterion Feedback Suggested Amendment GBCA Response Technical Some points are inherent to the project site and out of the Partial points are available to a project team Site selection and negotiation with an LPA are considered to be Communities content project team's control, e.g.: matters that are within the control of the project applicant. - Local food production: Council will not allow a community garden (do not wish to maintain) and have strong specifications If an LPA is not willing to be involved with productive landscape regarding street trees (do not want fruit trees) options there are other mechanisms that can be explored, - Access to amenities: if site is too small & no amenities Where all options have been explored and discounted then the nearby project team could approach us with this explanation and seek It is recognised that these are important for a community. an alternative resolution. In the selection of a site with no amenities nearby and no ability/feasibility to provide them the outcome of that plan for development is a site which will not provide its project occupants with the type of access to amenities that is considered to represent best practice. General Green Star needs to guarantee residents have specific, tangible Credits need to be rewritten to give consumers clear benefits. The rating tool is designed to recognise best practice outcomes Communities elements that non-green Star developments may not have. E.g. a new credit might be 'all residents save $x on energy' for attributes that have been identified as making a community a (compared to a reference case). Needs to be a clear path sustainable place to reside. It is also noted that a between what residents will actually benefit from the Communities project is not always residential and that a Green certification. Star - Communities rating does not rate the buildings within the project site. It is important that the rating tool while being robust is not overly prescriptive in the way in which projects can demonstrate compliance with the best practice sustainability outcomes sought. It is noted that this does not stop a project applicant from defining in more detail what the rating means for their occupants with regard to savings in energy etc. in accordance with the design approach they have taken. However, the value to the market of having a minimum set of requirements or expectations that can be attributed to a Green Star Community is understood and this will be further considered in the development of the next major revision of all Green Star Rating Tools. 15

16 Rating tool Issue Credit Criterion Feedback Suggested Amendment GBCA Response Templates - template is hard to enter which becomes the Streamline the templates to only ask for documentation The Submission Templates were updated for Communities challenge in completing rather than the performance references where it is specifically required or where an actual Communities v1.1 and in the near future we will be undertaking requirement. Is it driving the right outcome... question is asked. We are finding that sometimes we just have formal consultation with all project teams to collaborate on how e.g. credit 9. Healthy and Active Living requires documentation to say 'noted' in the document reference block because it is a best to approach documenting credits, i.e. are the templates the references for all the specific elements noted in the credit even statement rather than a question that requires a document right approach? Is there a more workable alternative? through these are often repetition and it's difficult to explain the reference. same thing in multiple way. In addition many credits ask for a documentation reference at the start of a requirement but then go on to ask for specific references for each element - i.e. repetition that isn't required. Should push best practice for green field communities not just We are committed to ongoing development of the Green Star Communities brownfield sites rating system and the appropriate approach having regard to the differences between Brownfield and Greenfield development sites. Specific stakeholder input on the establishment of appropriate standards and benchmarks is welcomed. The ratings are designed for the market and for the benefit of Our Market Engagement team is committed to working with our Communities investors. How do we develop tools, particularly Community members and industry on how best to communicate the tools that speak to the people who buy the properties and use achievements to the consumer. Our new strategic plan the precincts? Remains an issue with Apartments as well. recognises the importance of tangible communication of the benefits and desirability of Green Star through our customers to consumers. Resilience Our Market Transformation team is committed to ongoing Communities As it relates to apartment design we are not convinced our development of the Green Star rating system and establishing building codes and Green Star are driving us towards lasting the most appropriate approach for Adaptation and Resilience. assets that will house Australians in the decades to come. In Industry involvement in this initiative is welcomed. our industry the view currently rules leading to a lot of glass with apartment product being sold to off shore investors but housing local Australians. Under increasingly frequent heat wave conditions we don t feel the tools are strong enough in rewarding or incentivising more resilient design. We only have to look to the Chicago, and European heat waves in the past ten years to understand the social cost of lives lost. The GBCA and Green Star aren t going to solve this in isolation, but we need to be incentivising / encouraging it, getting it more firmly on the agenda Submission All We are finding that the GBCA submission templates are time Please simply these submission forms so that project teams do We recognise that schedules and other tables demonstrating templates consuming to complete and could be simplified for a number of not need to list the projects but that they can just submit their compliance generated from the project team could be used in credits such as Credit 12 and 11 own tracking sheets place of the tables provided in the Submission Template. This additional flexibility will be included in the Version 1.2 update of the rating tool. 16