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Green Star

Feedback Review

Rating Tools

Green Star Feedback Review: Rating Tools

Date issued: 28 November 2016

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 cross-

walk is currently underway for the WELL Building Standard, which is intended to be published with release of the Green Star –

Design & As Built 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 ten-

day 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 – Design & As Built 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



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.

https://gbca-web.s3.amazonaws.com/media/documents/gbca-research-paper---financial-transparency-2016.pdf

http://new.gbca.org.au/green-star/certification-process/



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 2016. 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.

http://new.gbca.org.au/contact/




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

takes too long

Documentation collection and assessment process

can be drawn out which minimises marketing

opportunities for the project.

Decentralise the certification / assessment process to shorten the certification

period. I.e. GSAPs/industry experts (internal or external) could certify Green

Star as per other regulatory ESD processes. GBCA could undertake audits etc.

to ensure compliance. Potential to expand the uptake of Green Star and

maximise commerciality and competitiveness in the industry.

Independent third-party assessment is a key element of

the value proposition of Green Star certification. This is

a process that we remain fully committed to, while also

recognising the needs of our customers and therefore

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.



6


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

certification

Too costly Despite the new tool and improved processes, too

many consultants had a poor experience using

legacy tools and are still pricing in significant

additional costs for where a project is undergoing

Green Star certification.

Education campaign

Modify assessment process

Be more flexible with acceptable documentation

Consider self-accreditation for endorsed organisations.

We recognise that more work can be done to educate

industry on the benefits and cost savings of using the

new generation rating tools. The most recent project

research undertaken (Green Star Financial

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.



7


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

certification needs to be

properly defined

Having worked on a volume certification project,

the information required to make the rating a

success will fall on being able to spell out exactly

what roles are required and the documentation

attributed to each role to satisfy the volume

requirements. Not just in technical terms but also

based on the standard requirements unique to the

volume process. This level of detail will be useful

at the beginning of a project when a Client is

considering undertaking a rating of this type

A pro-forma developed by the GBCA based on experience with the tool

outlining early on the roles required within an organisation to make it work, the

documentation that is typically provided by the organisations, suggestions on

appropriate benchmarking etc. At the moment there is very little support for

organisations considering the jump to volume certification. If you can develop

this kind of supporting documentation, it gives a clear framework early on for

teams to work with. JLL is happy to work with the GBCA in communicating

what worked for the CBA volume certification process.

We are working to clarify and streamline the Volume

Certification process. We will work to provide clear

communications and welcome any input that projects are

willing to share.



8


Portfolio certification Encouraging improvements

to the average star rating of

a Portfolio Rating

GRESB is a strong driver for organisations wishing

to undertake portfolio certification. There is no

current driver to improve the average ratings of

portfolios unless internally driven.

Competition works in encouraging improvements, especially to portfolio

averages. JLL recommends considering the model of GRESB (performance

plotting on graphs) of Australian Green Star Performance Portfolios on an

annual basis. Only those portfolios that give permission will be disclosed as

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.

We are in the process of developing a report based on

anonymised performance data of certified projects,

scheduled in line with the release of Green Star -

Performance Version 1.2.

Portfolio certification The threshold of achieving a

Portfolio Rating

Currently, the threshold for achieving a Portfolio

Rating is 0 stars. While useful in encouraging the

uptake of portfolios being rated, the bar needs to

be lifted eventually to ensure improvements

continually occur.

JLL recommends having a cutoff date for 0-1 star average portfolios. This will

ensure that portfolios who have been hesitating to commit to a rating will race to

sign up before the end date and also ensure any future portfolios will be starting

from at least a 2 star average to be rated.

We note that there are building types where the existing

operational data is beyond the control of the building

owner and unavailable. In these instances, it may not be

possible for assets to achieve the required points for a

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

ratings to Green Star

The partnership between the GBCA and the IWBI

is a natural step for the Australian market. There

are some issues in what is applicable in Australia

vs the US and also the integration with a tool that

contains both design and operational criteria.

JLL suggests developing WELL Modules to integrate with existing Green Star

tools. If, for example, a Green Star Interiors rating is being pursued then only

Design based criteria from the WELL standard will be applied. If the building

then targets a Green Star Performance rating, a WELL Performance module is

applied. These modules will also reflect gaps between the Australian / US

market to save on costly and inefficient methods of testing.

We are in the final stages of alignment between Green

Star - Design & As Built and the WELL rating tools. The

next stage of the alignment is between the Green Star -

Performance and WELL rating tools.

Assessment

Process

More face to face with assessors is encouraged as

it has the potential to work well.

Continue to promote this form of engagement. Suggest meetings occur after

assessors have had a chance to review submissions prior to Round 1

comments being provided.

Despite the option being available for more than a year,

this has had little uptake from project teams.

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

portal

Relatively new but a good initiative. Default time

windows to upload need to be managed.

Open portal when project is registered, close automatically when submitted by

AP.

This function of the online portal has been implemented.

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.



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

requirements

PVC Currently for non-PVC products there is a requirement for the

an EPD, however, that should not be the only option considered

The requirement could also offer option of a third party

certification such an Ecolabel which ensures that other negative

impacts along the product's lifecycle are minimised.

We note that third-party certification such as Ecolabel can be

considered equivalent to an EPD and encouraged to be used to

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

requirements

Sustainable products EPDs are very much welcome to encourage transparency in the

industry. However, they really should be under a

"disclosure/transparency credit" rather than a "sustainable

product" credit. Say, the terminology is disregarded and they

are included in sustainable products credit as they are currently,

there needs to be more differentiation in weighting between

EPDs and Level A third party certification.

A position paper was sent to GBCA last year in this regard in

support of our view and is attached again in the email along

with this spreadsheet.

The relative weightings for the different 'Transparency and

Sustainability' initiatives were determined as part of the Green

Star - Design & As Built development process. This occurred in

close consultation with industry.

A change such as the one suggested in the position paper is

not feasible under a minor revision of the Rating Tool. This

feedback will be further considered in our next major revision.

All Compliance

requirements

Credit 11.2 Lighting engineers have expressed a lot of issues with the

measures of compliance that are listed in this credit

We would ask that the GBCA visit the requirements for credit

compliance

We have recognised this issue for surface illumination and will

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.



10


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.



11


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

renamed

Potentially reframe or rename these to Market Transformation

while still rewarding genuine Innovations separately

This suggestion to reframe or rename these categories will be a

discussion with the Innovation Technical Advisory Group.

Green Star -

Communities

Compliance

requirements

4.1 - Climate

Adaptation

The Climate Adaptation compliance requirements do not specify

that 'high' or 'very high' risks identified in the plan need to be

addressed or responded to in the project design (As it does in

Design & As Built).

For recertification, project applicants should show that the

climate risks have been attempted to be mitigated.

The credit has been updated to reflect this approach in Green

Star - Communities v1.1.

Green Star -

Communities

Technical

content

6 - Sustainability

Awareness

The Credit Criteria & Compliance Requirements states the

following:

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

Amend the documentation requirements to reflect the credit

criteria.

The credit has been updated in Green Star - Communities v1.1.

Green Star -

Communities

Compliance

requirements

6.2 - Sustainability

Education Facilities

Guidance for the sustainability education facilities are two

extremes.

I suggest that an option of including a "sustainability information

wall" inside a community facility would be sufficient to meet this

credit.

The examples listed are extremes in part to highlight the fact

that there are many different approaches. They are simply

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.



12


Green Star -

Communities

Technical

content

11 - Sustainable

Buildings

NatHERS and Silver Level Liveable Housing are two separate

initiatives

Award NatHERS and Silver Level Liveable Housing

independently of each other.

The requirement for the combination of both initiatives was

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.

Green Star -

Communities

11.2 NatHERS and

Livable Housing

Australia

The residential requirements within this credit are very difficult

to mandate and manage where the developer does not have

control over the dwelling design. Rather than recognising efforts

to improve housing it is too much of a stretch for greenfield

development.

To encourage developers to influence house design prior to

commencement of the development allow a public commitment

to reach a percentage to be awarded points. E.g. if there is a

public commitment for the project to achieve 25% LHA silver

and 7 NatHERS Stars = 1 point. This can then be measured

afterwards upon recertification.

The requirement for the combination of both initiatives was

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.

It is noted that a confirmation of commitment is already provided

in this credit with partial points available.

Green Star -

Communities

11.2 NatHERS and

Livable Housing

Australia

Sustainable Buildings Credit - If residential then NatHERS and

Liveable Buildings Australia requirements are quite strict. You

don't achieve these via Green Star

Need clarity in the technical manual that residential buildings

(e.g. MURT) CAN demonstrate compliance via the Green Star

pathway rather than NatHERS

MURT buildings are eligible to be rated using Green Star -

Design & As Built so can use the Certified Non-Residential

Buildings pathway instead of LHA and NatHERS.

Green Star -

Communities

Desired

outcome

12 - Culture,

Heritage & Identity

12.1 and 12.2 outcomes are similar, if not the same. By

developing an Interpretation Plan which provides guidance, is it

not assumed you would take the results into consideration by

acting upon these?

3 points are available for the undertaking and implementation of

an Interpretation Plan.

The credit criteria are deemed to be separate. As detailed in the

credit 12.1 represents the process related to this specific

sustainability outcome with 12.2 representing the outcome that

has resulted from that process and is reflected in the plan for

development.

Green Star -

Communities

18 – Employment

and Economic

Resilience

Economic Resilience & Employment - too specific (idealistic)

about employment industries.

Issue - the maths: If over 50% of employable people need to

be employed in Type A, and under 50% in Type B... what

happens to everyone else? It simply doesn't make sense, as

described by RPS:

Feedback from RPS Economic Study - Re: Econ Econ 1.2.

Diverse Employment: (Type A and Type B industries) - The

GBCA credit criteria stipulates that one credit is available for

employment diversity where a) at least 15% of jobs are from

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

The credits have been altered in version 1. An improved

definition of "diverse employment" needs to be clarified with a

suitable economic professional. The % calculations also need to

be reviewed, and accommodate for varying development

locations and the needs of the community. A community should

be rewarded for stimulating sustainable economic growth

relevant to its needs. Additional points if a community is taking

into account future growth industries, technologies, social

services, social enterprise, renewable energy, and business

ownership.

We have identified the Employment and Economic Resilience

credit for detailed review for the next major release. The depth

of change required was not suitable for a minor version update.



13


Green Star -

Communities

Compliance

requirements

18.1 – Increase in

Local Jobs

On a greenfield site, where retail is being included as a part of

the development, it is obvious that the development will result in

a net percentage increase in the number of jobs generated.

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.

A prescriptive pathway to be introduced for 18.1 (Increase in

local jobs) credit to be awarded if the plan for the development

is to include a retail centre.

We have identified the Employment and Economic Resilience

credit for detailed review for the next major release. The depth

of change required was not suitable for a minor version update.

Green Star -

Communities

Compliance

requirements

19.2 - Skills

Development

Programs

The Skills Development Program Compliance requirements do

not accurately reflect the desired outcomes of the credit. The

Compliance requirements have been changed for Frasers

Property (through a CIR) and should be changed in the

submission guidelines for the next Communities handbook.

Add new compliance requirements.

(See CIR submitted from Frasers Property Australia for

Edmondson Park 1860C)

The revised Compliance Requirements are now included in the

Green Star - Communities Submission Guidelines v1.1.

Green Star -

Communities

Desired

outcome

20 - Return on

Investment

Analysis of direct costs and benefits is unnecessary. This is

typically done once for one project and becomes a box ticking

exercise thereafter. Limited amount to learn from after one

project is completed.

Noted. This comment will be used to inform the next major

revision of Green Star - Communities.

Green Star -

Communities

Benchmarks 24A.1 – Stormwater

– Performance

Pathway

The integrated water cycle to maintain a 75% total annual runoff

may lead to the development to install a tank that may be

significantly oversized that may not be easily accommodated on

a site that has spatial limitations. As a result this may deliver a

perverse outcome that may require the specification of

inefficient fixtures and fittings to justify a larger tank.

Insert an alternative method of compliance where by you can

either achieve the 75% reduction OR install a rainwater tank to

achieve a target non-potable demand (E.g. 80%). Although the

community tool is not designed to rate buildings, the retention of

stormwater on site can only be justified if there is a use of it,

rather than just retaining it on site. This ensure the development

maximises the use of the resource.


The Stormwater Management criterion that was causing issues

has been withdrawn from the credit. Over the next year, a small

subgroup of Technical Advisory Group (TAG) members and

representatives from project teams that have and are working

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.

Green Star -

Communities

24A.1 – Stormwater –

Performance Pathway

75% of the total annual stormwater runoff to be evaporated or

retained within the project site is extremely difficult for QLD

projects to achieve given the significant amount of rainfall

experienced.

Remove this requirement from the minimum requirements for

the performance pathway.


Green Star -

Communities

24A.1 – Stormwater –

Performance Pathway

Stormwater - 75% of your total runoff to be retained or infiltrated

on site which relates to Greenfield development sites.

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.

See notes at left

Needs to be consistent with DAB tool




14


Green Star -

Communities

Benchmarks 24A.2 – Water

Sensitive Urban

Design – Performance

Pathway

The Water Sensitive Urban design performance pathway does

not allow the use of a recycled water solution.

Place an alternate methodology that allows the intent of the

credit to be met by a water recycling plant

The performance pathway does allow the use of recycled water.

Please refer to the Guidance for further information. If further

clarification is required, please contact the GBCA for

assistance.

Green Star -

Communities

25 – Greenhouse Gas

Strategy

In greenfield developments there is not control over the specific

house design. We are committed to influencing behaviour to

incorporate more sustainable considerations to reduce GHG

emissions for the project. It is very difficult to demonstrate

meeting this credit in its current form.

Accept a public commitment to reduce greenhouse gas

emissions within the development with detailed calculation and

reduction strategy to influence residents as proof point to

achieve the credits. Then monitor performance against these

targets as the project is recertified.

Green Star seeks best practice outcomes.

The credit seeks to encourage developers to develop

mechanisms to achieve a reduction in greenhouse gas

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.

Green Star -

Communities

Other 26B – Materials –

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 Green Star -

Communities rating tool.

Green Star -

Communities

Technical

content

30.1.3 – 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 30.1.3 explains this.

Green Star -

Communities

31 – Heat Island Effect Urban Heat Island Effect - consider an intermediate point as

50% of precinct area to meet SRI target is very difficult

Consider an intermediate point to reward partial credit to

promote industry change

A change of this kind (revision of a benchmark) to the rating tool

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 Green Star -

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.

Green Star -

Communities

33 – Innovation Reconciliation Action Plans - not part of the governance credits,

part of an innovation

Should be part of the Governance credit A change of this kind to the rating tool 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 Green Star - Communities rating tool.



15


Green Star -

Communities

Technical

content

Some points are inherent to the project site and out of the

project team's control, e.g.:

- Local food production: Council will not allow a community

garden (do not wish to maintain) and have strong specifications

regarding street trees (do not want fruit trees)

- Access to amenities: if site is too small & no amenities

nearby

It is recognised that these are important for a community.

Partial points are available to a project team Site selection and negotiation with an LPA are considered to be

matters that are within the control of the project applicant.

If an LPA is not willing to be involved with productive landscape

options there are other mechanisms that can be explored,

Where all options have been explored and discounted then the

project team could approach us with this explanation and seek

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.

Green Star -

Communities

General Green Star needs to guarantee residents have specific, tangible

elements that non-Green Star developments may not have.

Credits need to be rewritten to give consumers clear benefits.

E.g. a new credit might be 'all residents save $x on energy'

(compared to a reference case). Needs to be a clear path

between what residents will actually benefit from the

certification.

The rating tool is designed to recognise best practice outcomes

for attributes that have been identified as making a community a

sustainable place to reside. It is also noted that a Green Star -

Communities project is not always residential and that a Green

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.



16


Green Star -

Communities

Templates - template is hard to enter which becomes the

challenge in completing rather than the performance

requirement. Is it driving the right outcome...

e.g. credit 9. Healthy and Active Living requires documentation

references for all the specific elements noted in the credit even

through these are often repetition and it's difficult to explain the

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.

Streamline the templates to only ask for documentation

references where it is specifically required or where an actual

question is asked. We are finding that sometimes we just have

to say 'noted' in the document reference block because it is a

statement rather than a question that requires a document

reference.

The Submission Templates were updated for Green Star -

Communities v1.1 and in the near future we will be undertaking

formal consultation with all project teams to collaborate on how

best to approach documenting credits, i.e. are the templates the

right approach? Is there a more workable alternative?

Green Star -

Communities

Should push best practice for green field communities not just

brownfield sites

We are committed to ongoing development of the Green Star

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.

Green Star -

Communities

The ratings are designed for the market and for the benefit of

investors. How do we develop tools, particularly Community

tools that speak to the people who buy the properties and use

the precincts? Remains an issue with Apartments as well.

Our Market Engagement team is committed to working with our

members and industry on how best to communicate the

achievements to the consumer. Our new strategic plan

recognises the importance of tangible communication of the

benefits and desirability of Green Star through our customers to

consumers.

Green Star -

Communities

Resilience

As it relates to apartment design we are not convinced our

building codes and Green Star are driving us towards lasting

assets that will house Australians in the decades to come. In

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

Our Market Transformation team is committed to ongoing

development of the Green Star rating system and establishing

the most appropriate approach for Adaptation and Resilience.

Industry involvement in this initiative is welcomed.

Green Star -

Design & As

Built

Submission

templates

All We are finding that the GBCA submission templates are time

consuming to complete and could be simplified for a number of

credits such as Credit 12 and 11

Please simply these submission forms so that project teams do

not need to list the projects but that they can just submit their

own tracking sheets

We recognise that schedules and other tables demonstrating

compliance generated from the project team could be used in

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.



17


Green Star -

Design & As

Built

Technical

content

10.3 - Acoustic

Separation

It is not clear if separation refers to separation between units or

between rooms for multi-unit residential dwellings.

Clarify whether separation refers to separation between units or

between rooms for multi-unit residential dwellings in guidelines.

The 'enclosed space' is based on the boundary of the

apartment i.e. between apartments. This will be clarified in the

v1.2 update.

Green Star -

Design & As

Built

10.3 - Acoustic

Separation

Acoustics for Residential - the standard for acoustic separation

is poorer than the NCC… Office standard applied to residential

Ensure criteria for non-office building types are appropriate and

promoting beyond code practice

We have recognised this issue for residential projects and will

correct it with Version 1.2. There will be criteria specific to

residential projects introduced. This will be peer reviewed by

acoustic specialists to confirm the residential requirements are

indeed best practice.

Green Star -

Design & As

Built

11.2 – Surface

Illuminance

Surface Illumination - very prescriptive of light level on surfaces,

lighting designers not sure of how to design for it. Drives direct /

indirect light fittings as a start. Intent is OK, but use of surface

illumination problematic as a criteria

Perhaps look to WELL as an example where a qualitative

statement from a lighting professional is sufficient.

We have recognised this issue for surface illumination and will

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.

Green Star -

Design & As

Built

11.2 – Surface

Illuminance

Surface Illumination Residential - prescribed as a wall-washing

or a wall mounted fitting so not sure how this meets the intent

As above suggest a statement from lighting designer to confirm

how lighting and surfaces improve uniformity of lighting to give

visual interest.

As above

Green Star -

Design & As

Built

12.1 - Daylight Combine Glare & Daylight credits into one to avoid projects

achieving daylight credits with too much localised daylight

(glare) or a good daylighting solution leading to no daylight

credits being achieved. While the glare control credit must be

achieved to enable daylight points to be achieved, internal

blinds can be used to achieve the glare control credit, however

there is no requirement to account for the loss of daylight that

results when blinds are drawn to minimise glare. This could

result in Green Star rewarding projects for daylight that will have

a poor daylight outcome given that blinds are drawn for

significant periods to minimise glare.

Account for blind use in daylight autonomy calculations. This

could be done either through simulating blind use or by having

an upper illuminance level as part of the daylight autonomy

calculations that would be consistent with direct sunlight glare.

While we do not prescribe how to model, it is an expectation

that anticipated blind use would be considered in the model.

This will be added to the Guidance section in the next v1.2

minor release.

Green Star -

Design & As

Built

Technical

content

13.1 - Paints,

Adhesives, Sealants

and Carpets

It seems odd that "all other flooring products are excluded" from

the indoor pollutant credit. As example would be Vinyl in a

kitchen that opens out onto an open plan office should be

assessed for VOC

Delete that requirement. The VOC requirements are currently specific to carpets. This

may vary for different flooring types requiring different

benchmarks.

This is noted and we are planning to further investigate

potential requirements for other flooring types.



18


Green Star -

Design & As

Built

14 – Thermal

Comfort

Thermal comfort – the credit guidance alludes to accounting for

shortwave radiation on thermal comfort; however there are no

requirements to include this. The credit should incentivise if not

require accounting for shortwave effects to promote the

transition towards a holistic thermal comfort assessment. While

glare will govern blind use it is still important to account for the

shortwave effects due to:

1) diffuse radiation becoming significant with some spaces and

glass types;

2) where blinds are not provided, an absorptive blind could lead

to a compounded longwave radiant temperature not otherwise

picked up in the modelling; and,

3) roller blinds typically allowing a component of light

(shortwave radiation) to transmit thus affecting shortwave

radiation.

ASHRAE 55-2013 (and in time ISO 7730) is proposing an

amendment with specific requirements around accounting for

shortwave radiation. Green Star should align with this and

require adoption. A transitional arrangement may be needed to

allow software providers to respond.

We will review any future changes to ASHRAE 55-2013 and

incorporate specific requirements, where appropriate, for future

revisions of Green Star - Design & As Built.

We encourage industry to continue to provide commentary on

any future revisions of standards used in the Green Star Rating

tools, and/or emerging opportunities to use new standards.

Green Star -

Design & As

Built

15 - Greenhouse

Gas Emissions

Multi-Unit Residential - lifts, DHW, and appliances make up a

significant portion of residential energy consumption, however

the references used are currently close to best practice so

significant improvements cannot be made reducing points that

can be achieved.

Either exclude or make the reference requirements less

onerous, they currently represent best practice rather than

minimum performance.

We note that there has been significant amount of feedback

regarding residential projects using this pathway. This is

currently being investigated within the Greenhouse Gas

Emissions Subgroup.

Green Star -

Design & As

Built

15 - Greenhouse

Gas Emissions

Hotel - as above but to a lesser extent As above.

Green Star -

Design & As

Built

15 - Greenhouse

Gas Emissions

Office DAB - new tool has homogenous loads for energy

calculations. The lack of load diversity while arguably a minor

issue for energy calculations on most projects, is probably more

important for thermal comfort calculations.

Consider equipment and occupant load diversity for thermal

comfort calculations as a minimum. Perhaps we can discuss,

we just want to ensure systems have the ability to modulate at a

zone level for a wide range of loads. Perhaps this can be

addressed via a statement from the mechanical designer rather

than a thermal model.

We note that alternatives to homogenous loads may be

suggested at any time, as outlined throughout the calculator

guide.

We are available for specific discussion where desired.

Green Star -

Design & As

Built

15 - Greenhouse

Gas Emissions

Offsite Renewables - should be longer than 10 years. We acknowledge the tension between the desired outcome and

the difficulty of a long term commitment for offsite renewables.

The timeframes for the use of offsite renewables is currently a

subject of review by the Greenhouse Gas Emissions Technical

Advisory Group.

The recommendations of the group will be released for public

consultation in November 2016.



19


Green Star -

Design & As

Built

Technical

content

15B – GHG

Emissions Reduction

– NatHERS –

Building Sealing

This credit does not specify the number of units to be tested for

residential developments.

Recommend that 10-20% of units are tested for apartments, not

100%.

We have currently formed an industry sub-group on building air

tightness testing in Green Star. The group has focused on

providing clear guidance and practicable requirements to

ensure the testing is not too onerous.

Requirements around the area to be tested has been discussed

with a view to accept sample area testing. The

recommendations of the group will be released for public


The feedback received will be used to update the building air

tightness testing requirements in the rating tool, including the

Greenhouse Gas Emissions credit.

Green Star -

Design & As

Built

Technical

content

17 - Sustainable

Transport

The benchmark for sustainable transport does not apply to

industrial facilitates as they are often located in regions where

there is limited public transport connectivity, but well connected

to major arterial roads.

Expand sustainable transport definition to reflect logistic

transport that considered efficient road design to ensure that

large trucks have easy access to major roads to reduce idle

times to major ports and other interchanges.

We recognise that while the Sustainable Transport calculator is

suited to most building types, there are some building types,

such as industrial facilities, where the commuters may not be

the main benefactors for sustainable transport initiatives. We

encourage industry collaboration to determine what the relevant

environmental metrics and benchmarks should be used for

projects of this type, where logistics are the focus of the

buildings functionality.

We welcome any project teams approach on this via a technical

query.

Green Star -

Design & As

Built

Compliance

requirements

17B.3 – Sustainable

Transport –


- Low Emission

Vehicle Infrastructure

This credit has poor outcomes for multi-unit resi. The GBCA need to recognise provision of GPO to each space. Currently, this is best approached via a CIR to demonstrate

alternative compliance.

We are available for further discussions on this issue.

Green Star -

Design & As

Built

Benchmarks 17B.3 – Sustainable

Transport –


- Low Emission

Vehicle Infrastructure

too high to be implemented on a small project with a small office

space

Have a mix of EV charge stations and EV ready infrastructure We acknowledge that the benchmarks for electric vehicle

infrastructure may not be appropriate for all project types, such

as small offices.

Currently, this is best approached via a CIR to demonstrate




20


Green Star -

Design & As

Built

17B.4 – Sustainable

Transport –


- Active Transport

Facilities

Definition around ‘regular building occupants’ in the DAB tool

for determining bike parking spaces - open to interpretation.

Ultimately we need to be providing what we feel our market

needs, but if that is more than what some projects are providing

to meet Green Star then does that put us at a disadvantage to

competitors.

The Green Star - Design & As Built ‘Sustainable Transport’

credit recognises the inherent variability between projects. This

is especially true when determining occupant numbers for a

variety of different building types. Accordingly, the project team

is deemed to have the best available information to calculate

the number of regular occupants.

We do acknowledge that variability will arise between projects.

However, the credit seeks to ensure that for whatever number

of regular occupants are determined, best practice levels of

transport facilities are provided.

We accept that this is a departure from Legacy rating tools

providing prescriptive numbers for determining cyclist facilities

allocation and is open to further feedback on an appropriate

methodology which would apply to a wide range of building

types.

Green Star -

Design & As

Built

19 – Life Cycle

Impacts

Exclude operational energy from LCA assessment as it

currently disincentivises materials and supplier engagement

initiatives and double counts ENE points.

Continue EN15978 compliant while of life LCA however reward

Green Star points based on cumulative reductions across A1-

A5 modules as long as it is demonstrated that there is no

burden shifting of impacts to other life cycle stages. This would

avoid double counting of operational energy efficiency and truly

incentive change in our materials selections / supply chain.

We have currently formed an industry sub-group to address this

specific topic. The group is seeking to develop an approach

which reduces double-counting of the greenhouse gas

emissions impacts of operational energy use. This will renew

the focus on the aim of the LCA credit.

The recommendations of the group will be released for public


Green Star -

Design & As

Built

25 - Heat Island

Effect

Urban Heat Island Effect - v1.1 of the submission guidelines

enables PV solar thermal panels to be considered as reducing

the heat island effect. As these become hot they do not meet

the intent and do contribute to the heat island effect.

This is a challenging issue as we want to encourage urban heat

island and on-site renewables to be addressed. We feel the

GBCA should form a view and make this clear via a Technical

Clarification rather than leaving it to individual projects to submit

CIRs thus potentially introducing inconsistency between ratings.

We acknowledge the issue of competing sustainability

outcomes, and the current determination is that PV panels are

deemed a compliant material for the purposes of this credit,

given their other holistic benefits.

However, it is recognised that while PV panels provide

worthwhile sustainability benefits, they potentially should not be

classed as a positive influence on heat island effect mitigation,

but rather as not applicable. We are currently investigating a

proposal to exclude PV panels from the total project area

calculations. Industry feedback on this approach is welcomed.

This guidance will be included in the future revision of Green

Star - Design & As Built v1.2 and Green Star - Communities.



21


Green Star -

Interiors

Compliance

requirements

5.0 – Metering and

Monitoring –

Metering

Requirement for independent energy and especially water

meters for small fit outs impractical for stores where sole water

usage is often only for tea/coffee, and is therefore immaterial to

overall portfolio water use.

Where metering shared with other tenants in a shopping centre

etc. are invoices for utilities sufficient?

The Green Star - Interiors rating tool currently has provisions

throughout for small fitouts (less than 500sqm). Utility meters

are an acceptable method to demonstrate compliance with the

credit and listed within criteria 5.0.3, and 5.1.2.

We will refine the guidance and definitions sections of the

Metering credit to clearly exclude immaterial water loads in the

next minor revision of Green Star - Interiors v1.2.

Green Star -

Interiors

8.1 – Indoor Air

Quality - Ventilation

System Attributes

Ease of maintenance - Access to both sides of components

within AHUs and downstream components required on one

project. On another project it was just the AHU so inconsistent.

Too much open to interpretation

Clarification should be provided as not practical to access both

sides of all components within ductwork downstream of AHUs.

While it is not practical, it is also not necessary as components

downstream of AHUs are not considered moisture or debris

generating components and the airstream is filtered and

therefore considered to be clean. Components downstream of

AHUs therefore do not require frequent maintenance to prevent

contamination of the air stream.

Access to both sides of cooling coils, AHU filters and

humidifiers within AHUs should therefore be sufficient to meet

the intent of this credit in most projects.

The requirement for access from both sides of all components

within ductwork downstream of AHU's has been peer reviewed

and it was determined that some downstream components may

be excluded on the basis that access for maintenance is

available.

Examples of components suitable for exclusion are VAV boxes,

volume control dampers, turning vanes, swirl diffusers, electric

duct heaters, and on floor heating coils. This guidance will be

included in the future revision of Green Star - Interiors v1.2 and

Green Star - Design and As Built v1.2.

Green Star -

Interiors

16D - Greenhouse

Gas Emissions –

Reference Fitout

Pathway

No benchmarks for equipment for energy so nearly impossible

to create a reference building. Reference ends up = to design

thus diluted credits that are active / accessible. This is a

significant issue for the majority of tenancies where equipment

energy is a significant portion of energy consumption.

Provide more guidance on benchmarks for reference building or

establish benchmark equipment densities to reward workplaces

that are going printer less etc.

The Energy Consumption and Greenhouse Gas Emissions

Calculator Guide provides some guidance around the

development of appropriate benchmarks for reference projects.

We encourage project teams to propose alternative approaches

which demonstrate an improvement on current practice.

Green Star -

Interiors

Compliance

requirements

16D - Greenhouse

Gas Emissions –

Reference Fitout

Pathway

For Interiors projects that cannot achieve 4.5 star NABERS

Energy we feel there should be an option to undertake a

reference fitout assessment against a benchmark project.

Currently the reference option looks at pumps, lifts, air

conditioning fans, ventilation fans and these are typically

supplied by base building not fitouts and as such this calculator

appears to be tailored for retail interior projects or base building

projects not commercial office projects.

Further we are not sure 10% improvement on NCC Part J

applies except to supplementary and lighting systems only and

this is confusing for project teams to benchmark against for

fitouts

We suggest that the Reference fitout calculator be updated to

reflect fitout services such as appliances, ITC equipment,

Personal Equipment, supplementary HVAC systems etc and

move away from services that are base building.

For the 16C NABERS Pathway, the Conditional Requirement

stands at 4.5 stars. Where this cannot be achieved, any other

applicable pathway should be targeted, including the 16D

Reference Fitout Pathway.

The calculator guide outlines the modelling requirements for an

Interiors project (reference and proposed). For any energy

demand items not addressed in the calculator guide, project

teams are encouraged to submit a technical query outlining

their modelling approach.

This is an area of development for Green Star - Interiors v1.2.



22


Green Star -

Interiors

Other 18A - Potable Water

– Performance

Pathway

The Performance calculator is impractical for fitout projects. We

do not see how cooling tower water, fire test systems and pools

are relevant to a fitout.

We believe the performance water calculator needs to be

amended to remove these items and it should only assess

appliances, fixtures, fittings

As of the July 2015 release of the Potable Water Calculator, all

items with the exception of Sanitation and white goods are by

default, not included in the calculator for Green Star - Interiors

projects. Potable water consumption in the reference fitout is

determined by the items selected within the checklist section of

the calculator.

Green Star -

Interiors

21D – Sustainable

Products – Third

Party Certification

Little tacit guidance on what qualifies as 3rd party certification

for materials, Level A, B, C. You have to search deep within the

website to find materials third party guidance information.

This information should be embedded in the materials

calculator, either via a link to the page in the website or a

detailed table within the calculator itself showing Third Party

schemes relative to Level A, B and C.

We recognise that third party guidance information is not easily

accessible on our website, and is endeavoring to alleviate this.

The guidance for the 3rd party certification for materials will be

included in the future revision of Green Star - Interiors v1.2.



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Costs feedback

The following table outlines the feedback received by industry regarding the Cost of Green Star.

Issue Feedback Suggested amendment GBCA Response

Costs of achieving a rating The new DAB tool and volume certification has resulted in

significant reductions in sustainability consultant and GBCA

fees however other consultants (services, architects, project

managers) are still pricing in significant additional fees to

achieve a rating. This is resulting in some ratings not

proceeding as the design/consultant costs are outweighing

the costs of the building initiatives themselves.

1. More active marketing and targeted presentations at

appropriate forums of the changes

2. Make documentation requirements even less prescriptive -

be accepting of a wider range of standard project

documentation and perhaps stat decs.

3. Change assessment process to include a site visit to

validate some outcomes on site without requiring it to be

produced in a submission - e.g. lux levels, air quality, end of

trip facilities, solar panels, etc

1. We are currently working internally to create new

engagement and education resources available to the

industry.

2. The documentation requirements are intended to be as

flexible as possible, to enable project teams submit existing

documentation. We recognise that this diverges significantly

from Green Star Legacy tools, and is working towards

further market education.

3. The proposed assessment process will be reviewed

internally. While this process exists in the Certification

Agreement documents, often building owners are hesitant to

adopt this methodology, and may result in additional

certification costs.

Costs of achieving an credit electric vehicles - market not ready Reduce the 5% down, especially for industrial developments We acknowledge that the benchmarks for electric vehicle

infrastructure may not be appropriate for all project types,

including industrial developments.

Currently, this is best approached via a CIR to demonstrate


Other A barrier we've experienced is not knowing how to price GS

consultancy fees appropriately as consultants. If GS is now

reaching a point where it should no longer command a

premium in construction how do we reflect this in design

fees?

Could this form part of the GS foundation course or a

separate webinar? "How to deliver a GS project without

pricing yourself out of the job"…..perhaps?

We are currently working internally to create new

engagement and education resources available to the

industry to become better informed on all aspects of a

Green Star rating.

A Financial transparency document outlining the costs of

typical Green Star projects has been developed by us and is

available online.



24

Sustainability Outcomes

The following table outlines the feedback received by industry regarding the outcomes the rating system is leading a project towards.

Sustainability Outcome Issue Feedback Suggested amendment GBCA Response

Negative Ratings Firstly I may have this wrong for GS so ignore if I do - there's

a lot of talk around ratings systems and their

designed/modelled ratings and their actual performance. If

this is the case for GS then how do we address it?

Passive House and the LBC address this by withholding ratings until

confirmed calculations and performance data is available, only then are

projects formally certified. Is this a model for GS - certified after 1 year of

operations with +70% occupation, then 3 years thereafter performance

ratings can be applied for?

Currently a mechanism to address the

designed/modelled ratings and their actual

performance for projects is being reviewed. The

best solution is for projects to undertake both a

Green Star - Design & As Built rating and a

Green Star - Performance Rating, as this is the

most holistic approach.



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Future Directions

The following table outlines the feedback received by industry regarding the future development of Green Star.

Aspect Topic Feedback Suggested amendment GBCA Response

New ideas Innovation Challenge Battery Storage could be included as an innovation challenge Include as an innovation challenge. The use of energy storage, and its role in the

building industry is currently being discussed in

the Greenhouse Gas Emissions Technical

Advisory Group.

Future priority Sustainable Outcomes Green Star should align more closely with WELL Building

Standard from a documentation perspective but potentially

assessment also. There is a lot of overlap between the tools

which provides an opportunity for both the GBCA and IWBI to

learn from each other to ensure increase uptake and

sustainability outcomes in Aust.

Green Star to WELL pathway to be developed allowing points to be

automatically traded between the tools Assessment processes to be

aligned where possible

We have been collaborating with other rating

programs to agree upon ‘cross-walks’. This

enables 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’s outcomes contributing towards

Green Star.

These agreed upon ‘cross-walks’ for WELL will

be published in the version 1.2 release of the

Green Star - Design & As Built Submission

Guidelines.

Future priority Sustainable Outcomes Alignment with tools beyond 6 star - e.g. Living Building

Challenge

As above.

The next phase of international rating tool

alignment will include alignment between WELL

and Green Star - Performance for the operational

aspects of existing buildings, as well as alignment

with Living Building Challenge and Passive

House.

Opportunity for

improvements

Other Greater use of Precinx tool in Green Star DAB and

Communities. If required, GSDAB should define the necessary

assumptions and protocols that need to be inputted into Precinx

to ensure consistent use of the tool. Precinx is now licensed by

most major developers and if can be used for a greater range of

credits will significantly reduce the time and costs associated

with certification and allow greater focus on actual building

initiatives.

Precinx protocol for Green Star The use of the Precinx tool and its alignment with

Green Star will need to be reviewed for a protocol

or guidelines to be established. Industry input to

this process is encouraged.

Leading practice Innovation Challenge Include an innovation challenge to include the design for

disability for children.

Not applicable This is currently being developed as part of a new

Innovation Challenge.



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Current challenge Innovation Challenge GBCA to publish financial transparency documentation

submitted for projects

This report is publicly available on our website

and intended to be updated on an annual basis.

Sustainable Outcomes Integration with WELL + LBC - how will the recently signed

MOU's with the IWBI and LFIA align with GS? Will Passive

House go a similar way?

Clear messages from the GBCA on how points will be mutually awarded

and pathways accepted/required for multiple ratings

We are currently working with Passive House and

LFIA to align the respective rating tools with

Green Star - Design & As Built.

Sustainable Outcomes GS has been fantastic at improving the environmental

performance and outcomes for buildings and now communities.

However social requirements are now becoming more and

more in demand and part of the "sustainability" aims of projects.

The inclusion of the WELL standard as move towards

addressing some of the social issues. How does GS address

other elements of the social parts of sustainability (if it wants

to)?

Start to consider a "social" category that could look at credits such as;

ageing in place/equity/demographic change/human interaction/etc

We recognise the importance of a social category

in the Green Star rating tools, and a move to

broader holistic sustainability is an element of our

new Strategic Plan. While Green Star -

Communities has credits focusing on the social

aspects of a community, all future versions of

Green Star are intended to have integrated social

sustainability outcomes.

Categories Passive Design - Is there a way within the energy category that

can fully reward passively designed buildings with now

mechanical requirements? Rewards to

orientation/massing/building fabric design that

minimises/eliminates the need for active heating/cooling?

Passive Design pathway in the energy category supported by energy

modelling?

Currently the reference building pathway awards

points for passive design through the use of the

intermediate and proposed building models.

This feedback will be considered in the next

major revision of the Green Star Rating Tools.

- Other Beyond comment on the tools as they stand, we also had a

think about the areas we would like to see Green Star drive

change around so beyond the tools and credits as they exist

today. Note some of these the GBCA are already addressing

through some of the innovation challenges or via other.

· Urban Heat Island - good that Green Star has brought this onto the

agenda

Noted with thanks.

· 6 Stars - ensuring it continues to recognise World Leadership We are proposing the addition of minimum

achievements in Greenhouse Gas emissions for

buildings targetting a 4, 5 or 6 star rating.

We aim to continually improve benchmarks to

align with current World Leadership. The next

major version of the Rating Tools is an

opportunity for us to collaborate with industry on

setting increasingly ambitious targets to ensure

genuine world leadership.

· Ensure we incentivise innovation and not just market transformation We note that both small-step innovation and

major transformative initiatives are desirable, and

will continue to advance both agendas.

· Market Transformation credits - LCA, Building Air Tightness testing etc

important to bring about industry change

Noted. Both of these categories will be

addressed in the November 2016 consultation

papers, as we wish to promote deeper industry

https://gbca-web.s3.amazonaws.com/media/documents/gbca-research-paper---financial-transparency-2016.pdf



27


impact with these initiatives. Industry is

encouraged to provide feedback through this

process.

· Driving change around supply chain - manufacturing and end of life

issues, social impact issues (see below)…

We acknowledge that more work can and should

be done in this area. We welcome industry

feedback and engagement on appropriate future

Rating Tool mechanisms to address these and

related topics.

· Social Issues within Supply Chain - Living Building Challenge 'Just'.

Also 'Declare' for health issues

We are working with organisations such as LFIA

to develop 'cross-walks' between different rating

tools, in order to maximise opportunity for benefit

from existing schemes.

· Carbon Neutral Certification - NCOS for building products The use of Carbon Neutral Certification, and its

role in the building industry is currently discussed

in the Greenhouse Gas Emissions Technical

Advisory Group.

We encourage industry engagement on the

appetite and potential mechanisms for

recognition of carbon neutral certification of

building products.

· Carbon Neutral Certification - of buildings in operation we support

GBCA's advocacy

Noted with thanks. We are working with the

Department of Environment and Energy and

NABERS to develop a buildings-based carbon

neutral standard.

The use of Carbon Neutral Certification is an

acceptable way to demonstrate reductions in

Greenhouse Gas Emissions in the Green Star -

Performance Rating tool

· Extension of LCA - Building Environmental Product Disclosures in time

…

Noted. Our view is that it will take time before

this is a viable exercise, given that a critical mass

of building product EPDs are not yet available.

· Communities - driving green corridors or connecting new & existing

green spaces etc.

Noted. This will be considered in the next major

revision of the Green Star - Communities Rating

Tool.



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· Retail - make retail volume type approach part of the main tool under

DAB given retail tenants are 2/3 of the solution … So extending credits

to include greater tenant engagement


revision of the Green Star - Design and As Built

Rating Tool.

· Facilitating WELL Ratings An agreed ‘cross-walk’ for WELL will be

published in the version 1.2 release of the Green

Star - Design & As Built Submission Guidelines.

· Weather files - beyond the TRY and RMY weather files, should there

be an incentive / requirement to test performance under extreme

weather sequences.


revision of the Green Star - Design and As Built

Rating Tool.

· Resilience - requires Medium and High risks from CCAR risk

assessment to be addressed so perhaps OK for now. Industry still

learning in this area

This is valuable feedback. While the industry

matures, we will be looking to introduce higher

benchmarks for resilience.

· Resilience - revisit the risk assessment in operation This is currently being developed as a new

Innovation Challenge.

· Affordability - there is no definition around it in Australia. No checks on

who is actually investing in the properties, more affordable product can

still be snaffled up by overseas investors. KWH may be OK but first time

home buyers not addressed … Industry discussion, not just for Green

Star to resolve

We are interested in participating in industry

discussions on this topic and exploring whether

future revisions of the Green Star Rating Tools

can be used to facilitate developments in this

important area.



29

User Experience, Resources and Services

The following table outlines the feedback received by industry related to the experience of using Green Star and associated services.

Aspect Issue Feedback Suggested amendment GBCA Response

Resources Content In many cases, the GBCA has not property updated documents on

the GBCA website for Communities. For example, a submission

template was filled out that still had the requirement to submit the

submission on a USB and sending the USB to the GBCA by post.

This was clarified that this was not needed by the GBCA anymore.

Update content on the website as soon as changes are made. Alternatively,

if a change is made to an official document, this change should be

communicated to all project applicants asap.

Noted. The new website was launched in July

2016. Updated content is available as soon as

changes are made. Additionally, registered

projects have access to all files in the project

manager portal, which is updated when new

content is available.

We will ensure that when changes are made to

official documents, project applicants are informed

as a matter of priority.

Where specific feedback can be provided with regard to the navigation of the website, feedback is requested at the following link.


Resources Availability Technology in the form of 'Applications' for phones / iPad Development of a GBCA App to facilitate real time updates to criteria and

Tool versions to assist project teams in having information on hand

whenever they're around their phone or iPad

We are embarking on a new project to investigate

future digitally-based solutions to improve the user

experience.

Recognised Provider Other We would like to discuss some of the challenges around the

Recognised Provider Status that are emerging for us as a builder.

One issue is that as a builder our client's provide us with consultant

statements with no report substantiating the claimed performance

and credits and then we are asked to take the risk position in a

DAB context. So we end up having to potentially complete

increased due diligence on our side.

Our 'Recognised Provider' program provides an

alternative pathway in the preparation and delivery

of credit documentation. The process involves the

assessment of assurance and quality control from

'Recognised Providers.'

We are currently developing a framework and

information package for interested parties.

All parties wishing to discuss the application of

Recognised Provider solutions are encouraged to

contact us for further input and discussions.

Guides Straight forward in general once the format is understood. GSAP

foundation course + exam helps embed this

Noted.

Product Certification

Schemes

I'm a bit sceptical of 3rd party certification. Is there alternatives that

are more transparent and stringent that the GBCA can use?

How about the new ISO standard for sustainable procurement (currently

under review and still to be released) and a series of prerequisites/targets

that product EPD's must meet. EPD's are great at identifying impacts of

A Technical Advisory Group has been established

to focus on product certification schemes to

provide direction on a simplified approach to




30

different products, the next step might be identifying desirable targets within

EPD's relatable to points awarded.

product certification scheme recognition in the

rating tools.

EPDs are an emerging tool and once a critical

mass of building product EPDs are available, we

intend to investigate how they can be used to

greatest effect in advancing the sustainability of the

built environment.

We welcome industry engagement on the most

appropriate mechanisms to recognise holistically

sustainable products.



31

Marketing & Communications

The following table outlines the feedback received by industry related to how Green Star is marketed.


Ancillary information Green Star Communities needs to guarantee residents have

specific, tangible elements that non-Green Star developments

may not have.

Credits need to be rewritten to give consumers clear benefits.

E.g. a new credit might be 'all residents save $x on energy'

(compared to a reference case). Needs to be a clear path

between what residents will actually benefit from the

certification.

The rating tool is designed recognise best practice outcomes for

attributes that have been identified as making a community a

sustainable place to reside. It is also noted that a project is not

always residential and that a Green 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.



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Research papers More please! An online portal of case studies + research papers would be a

fantastic resource to help address how others have overcome

challenges previously. This is in line with my GC presentation,

an on-line portal where industry could access latest research

and innovations would seriously help accelerate what we are

doing as an industry in sustainability - the model could be

similar to how uni libraries are shared on line with access to

massive research databases - and industry equivalent would be

a powerful tool!

With 1300+ Green Star certified projects we have rich data on

the sustainable property development in Australia. We intend to

catalogue and mine this information and make it available for

industry to educate the built environment on true best

practice. This will build on the work we did on the Value of

Green Star (energy, waste and water) in 2013 to include indoor

environment quality, management, transport and materials. A

series of industry sponsored reports will showcase best practice

from our past to help industry increase our impact in the future.

The online portal is a great idea. Green Star case studies have

been collated on the new look website:

http://new.gbca.org.au/showcase/ .

We also have a central place for research - the Research

section on our website

http://new.gbca.org.au/initiatives/research/ . We are building on

this, with plans to include more statistics and research papers

as we create them. We are also part of a research working

group within ASBEC to identify and share research across the

industry.

Access to sponsorship funding to complete this work will be key

to our ability to provide this resource. We welcome any

approach from industry to aid in the establishment of funds to

accelerate the timeline of this work.

Case studies More please! Same as above - A Case study template could be a great way

to standardise information and then set them up on an online

database for reference. Free access to Uni students -

subscription to others? Possibly partner with Uni's or other

organisations (PCA?) on this (and point above)?

As above

http://new.gbca.org.au/showcase/

http://new.gbca.org.au/initiatives/research/



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Accreditation Program

The following table outlines the feedback received by industry related to the accreditation program (GSAP).


CPD The CPD section needs to be clarified, it currently reads' 'As a

GSAP you’re required to accrue 15 CPD points in a 12 month

CPD enrolment period*. This must include a minimum of 5

Green Star points. The remainder can be earned through Green

Star or Sustainable Development points.'' however, 14 points

seem to be sufficient as per screenshot.

This appears to be an IT glitch that may have been specific to

the user who provided the feedback. This has been raised

internally and our IT Department are working on rectification.

CPD Performance CPD points currently expire after 12 months. Performance CPD points should be valid for 3 years as per

current rating validity. It is up to GBCA to decide how many

points are available per building, 20 or less.

One of our strategic goals for 2016-2019 is to launch a new

professional development program. As part of this, project point

allocation for Green Star - Performance projects will be

reviewed, along with project point allocation for other rating

tools. Preliminary consultation with the Green Star Steering

Committee has touched on this, however more broad

engagement should be expected in the new year with a chance

for industry to provide their feedback before we provide

guidance.

CPD It is unclear on whether a GSAP with multiple qualifications (e.g.

Communities & Performance) is required to do 15 CDP points

or more.

Clarification on number of CPD points required if certified for

multiple GSAP types (e.g. Communities & Performance)

It should be clarified that a GSAP with multiple qualifications is

only required to maintain 15 points per year, as opposed to 30

or 45 if multiple qualifications are held. This is feedback will be

incorporated into our policy and ongoing communications to

provide more clarify.

CPD CPD - not really guaranteeing better, more skilled APs.

Good thing is that CPD doesn't have to be stream specific now

Perhaps have tiers of CPD where the highest tier is actually

about extending professionalism as opposed to attending a

bunch of tours which won't necessarily extend / develop leading

professionals

Part of the intention of launching of the new professional

development program is to better understand how the CPD

program can be used as a method of improving the skill, quality

and outcomes of existing GSAP's. This will be taken into

consideration in the launch of the new professional

development program.



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Other Future Green Leaders Program Providing a more structured program for this could be very

beneficial in helping students negotiate the first few years of

their careers.

A mentoring program (similar to/in partnership with the PCA)

could be a massive benefit to ambitious young professionals.

Would an internship program in conjunction with major

developers/consultants/etc be worth exploring?

The Future Green Leader Advisory Group has recently formed

and involves 7 of our brightest and most inspiring young

sustainability leaders. The aim of the Advisory Group is to

determine the best strategy to better engage and support other

emerging professionals in this space. There is no better way to

do this than by having people who have similar experiences,

age and are like minded. These great suggestions will be

passed onto the Advisory Group to be discussed and potentially

be included in their goal and directions. Ideas such as these

and other big & bold ideas have been put forward already by

the group members. We will endeavour to keep you and the

rest of the industry abreast of the ambitions and achievements

of the group.

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