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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
Green Star Feedback Review: Rating Tools
Date issued: 28 November 2016
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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.
Green Star Feedback Review: Rating Tools
Date issued: 28 November 2016
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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/
Green Star Feedback Review: Rating Tools
Date issued: 28 November 2016
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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.
Green Star Feedback Review: Rating Tools
Date issued: 28 November 2016
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Aspect Issue Feedback Suggested Amendment GBCA Response
Portfolio certification N/A Introduction of the portfolio certification process
has provided significant benefit to our organisation
allowing faster certification at scale. The learnings
from this should be applied more broadly.
Review why portfolio process has worked well and what can be improved and
also transferred to other aspects of certification. In particular, the increased
GBCA support resulted in greater transfer of project knowledge to the assessor
which streamlined the process.
We will seek additional feedback from project teams who
worked on portfolio projects as well as Certified
Assessors who assessed the portfolio projects to
determine what worked, what can be improved and how
learnings can contribute to other GCBA and project
processes.
Single project
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.
Green Star Feedback Review: Rating Tools
Date issued: 28 November 2016
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Aspect Issue Feedback Suggested Amendment GBCA Response
Technical support Limited We are concerned that the GBCA has limited
technical resources which results in issues often
taking a significant amount of time to resolve. This
can be an issue when they are critical to the design
or construction which needs to proceed.
Develop a business case to bring on additional technical resources. Increased
resources will allow for quicker resolution of issues, improved processes, etc.
which should translate into increased uptake and certifications.
We acknowledge that at times project teams can be
dependent on responses in order to progress critical
project items and our responsiveness is an important
issue. In order to provide support to project teams,
earlier this year, we allocated two principal Sustainability
Services staff to each registered Green Star project,
rather than one. We also use external peer reviewers as
required and have the support of, and access to, the
resources that can be made available through the GBCA
Technical Advisory Group.
The Green Star Project Manager portal has also been
updated within the last couple of months, in order to
facilitate answering technical requests from project
teams as promptly as possible. Project teams can now
not only request Technical Clarifications and CIRs, but
also submit their documentation online, update their
project records and request meetings too.
We have indicated a standard turnaround time of 10
working days to respond to technical requests such as
Technical Clarifications and CIRs. The average
turnaround time for query responses such as CIRs and
TCs is trending down, currently with 90% of all queries
completed within this timeframe.
We are continuing to work to improve the customer
experience through a new review of internal processes
and resources. We have now implemented a system to
monitor and optimise query response, and associated
KPI targets have been set. While queries range in
complexity, it is envisaged that this will continue to drive
down the average response time for queries and we will
be monitoring progress on this goal.
Volume certification The process of the volume
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.
Green Star Feedback Review: Rating Tools
Date issued: 28 November 2016
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Aspect Issue Feedback Suggested Amendment GBCA Response
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.
Green Star Feedback Review: Rating Tools
Date issued: 28 November 2016
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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.
Green Star Feedback Review: Rating Tools
Date issued: 28 November 2016
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Rating tool Issue Credit Criterion Feedback Suggested Amendment GBCA Response
All General All We are finding that the GBCA is revising tools too quickly and
this makes it difficult to stay knowledgeable on what forms part
of a rating tool
We would suggest that the GBCA consider only revising tools
every 2-3 years and between the release dates they issue
addendums to the tools only which project teams can use
We have moved away from 'addendums' (also known as
Rulings) based on feedback from industry. Feedback from
project teams is that they are finding that the constant
referencing of multiple documents was not an easy approach to
understand the rating tool.
The minor updates to the rating tool (0.1) have taken the place
of the Rulings. The intent of the minor releases is to capture all
feedback provided via communication with project teams and
formal queries. All changes are clearly marked and also
captured in the Change Log. Minor revisions are restricted to a
minimum 12 month interval to limit the frequency of change.
Major releases are planned for a minimum three year cycle to
ensure that the current highest levels of sustainability are
realised.
This is an acknowledged change in process from previous
methods of updating the rating tool. We will continue to work to
ensure that the update process is as streamlined as possible.
We recognise that the communication of changes in the minor
releases has been limited. It is planned to improve the
communication on upcoming releases, and provide education
channels for active project teams to outline how the updates
affect active projects and guidance on their use. A recently
implemented improvement with the latest minor releases has
been to include clear revision marking within credits and change
logs at the start of the Submission Guidelines and at the end of
each credit. This has resulted in a streamlined, up-to-date
document.
All General Contents, page numbering, credit numbering to be improved Credit list page needs page references; Would be beneficial if
credit naming convention was consistent across tools and
versions
The PDF versions of the Submission Guidelines do include
bookmarking to assist with navigation. We will take these
suggestions on board and ensure improved page referencing at
the next minor releases.
All General No bookmarking of submission guidelines or hyperlinking Introduce bookmarking, hyperlinking etc. The PDF versions of the Submission Guidelines do include
bookmarking to assist with navigation. We will investigate the
use of hyperlinking.
Green Star Feedback Review: Rating Tools
Date issued: 28 November 2016
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Rating tool Issue Credit Criterion Feedback Suggested Amendment GBCA Response
All General Why do we have to submit a CIR from a new tool (Interiors v1)
within the older tool (Office Interiors v1.1) …
Should be a simplified process to allow this to occur, at least for
80%+ of cases
We have developed a credit substitution matrix and instructions
document for applying New Generation rating tool principles in
Legacy projects. A complimentary query is the most
straightforward method of approving these.
It is acknowledged that some credits can be directly substituted;
however, there are some instances where there are
complexities within the substitution that need to be determined
before assessment. This ensures that the Certified Assessors
assess against the correct credit criteria.
For New Generation Green Star projects, a credit substitution
query is not required and later versions of credits can be picked
up and used. This is intended to make the latest version of all
Green Star credits more accessible.
All Innovation Challenge vs Market Transformation - should it be
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.
Green Star Feedback Review: Rating Tools
Date issued: 28 November 2016
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Rating tool Issue Credit Criterion Feedback Suggested Amendment GBCA Response
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.
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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 credit has been updated in Green Star - Communities v1.1.
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.
The credit has been updated in Green Star - Communities v1.1.
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
The credit has been updated in Green Star - Communities v1.1.
Green Star Feedback Review: Rating Tools
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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.
Green Star Feedback Review: Rating Tools
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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.
Green Star Feedback Review: Rating Tools
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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.
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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.
Green Star Feedback Review: Rating Tools
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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.
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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
consultation in November 2016.
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 –
Prescriptive Pathway
- 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 –
Prescriptive Pathway
- 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
alternative compliance.
Green Star Feedback Review: Rating Tools
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Rating tool Issue Credit Criterion Feedback Suggested Amendment GBCA Response
Green Star -
Design & As
Built
17B.4 – Sustainable
Transport –
Prescriptive Pathway
- 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
consultation in November 2016.
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.
Green Star Feedback Review: Rating Tools
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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.
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Rating tool Issue Credit Criterion Feedback Suggested Amendment GBCA Response
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.
Green Star Feedback Review: Rating Tools
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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
alternative compliance.
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.
Green Star Feedback Review: Rating Tools
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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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Aspect Topic Feedback Suggested amendment GBCA Response
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
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Aspect Topic Feedback Suggested amendment GBCA Response
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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Aspect Topic Feedback Suggested amendment GBCA Response
· 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
Noted. This will be considered in the next major
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.
Noted. This will be considered in the next major
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.
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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.
http://new.gbca.org.au/contact/
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
Green Star Feedback Review: Rating Tools
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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.
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Marketing & Communications
The following table outlines the feedback received by industry related to how Green Star is marketed.
Issue Feedback Suggested amendment GBCA Response
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
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Accreditation Program
The following table outlines the feedback received by industry related to the accreditation program (GSAP).
Issue Feedback Suggested amendment GBCA Response
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.