LCA Stakeholder feedback report final by Green Building Council of Australia

Life Cycle Assessment in Green Star Discussion Paper 2 Stakeholder Feedback Report April 2014

Contents Introduction ........................................................................................................................................................................................... 3 Summary of feedback ........................................................................................................................................................................... 3 The ‘Environmental Product Declarations’ credit................................................................................................................................... 3 Rationale for the Reference Case Criteria........................................................................................................................................... 16 Scope .................................................................................................................................................................................................. 24 System Boundary ................................................................................................................................................................................ 28 Functional Unit ................................................................................................................................................................................. 35 Impact Categories ........................................................................................................................................................................... 38 Data Sources ................................................................................................................................................................................... 44 The ‘Materials Life Cycle Impacts’ credit reference case criteria benchmarking ................................................................................. 48 LCA Practitioner .............................................................................................................................................................................. 51 Implementation and review .............................................................................................................................................................. 54 General Feedback ............................................................................................................................................................................... 55 Appendix A .......................................................................................................................................................................................... 57

Life Cycle Assessment in Green Star Stakeholder Feedback Report

Introduction In September 2013, the Green Building Council of Australia (GBCA) released the Life Cycle Assessment in Green Star Discussion Paper 2, inviting industry feedback on how Life Cycle Assessment (LCA) could be introduced within the Green Star rating system. An overview of the feedback received and the outcomes of incorporating LCA into Green Star rating tools, are presented in this Stakeholder Feedback Report. For a list the organisations who submitted feedback, see Appendix A of this report. This Stakeholder Feedback Report should be read in conjunction with the following documents (download via http://www.gbca.org.au/green-star/materials-category/discussion-paper-life-cycle-assessment-in-green-star/): 

Life Cycle Assessment in Green Star Discussion Paper (2012)

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Life Cycle Assessment in Green Star Discussion Paper 2 (September 2013)

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Life Cycle Assessment in Green Star Stakeholder Feedback Report (2013)

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Green Star Environmental Product Declarations Draft Credit (2013)

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Green Star Materials Life Cycle Impacts Draft Credit (2013).

Summary of Feedback The following section lists the specific questions posed in the Lifecycle Assessment in Green Star Discussion Paper 2, followed by a summary of the feedback received and a response from the GBCA where required, including an outline of any changes made to credits on the basis of this feedback.

The ‘Environmental Product Declarations’ credit Do you agree that the approach taken within the credit will encourage the use of Environmental Product Declarations (EPD) by Green Star projects?

Feedback: EPD’s are being used overseas and are somewhat unknown here day to day. We have invested heavily in the UL EPD process and have a number of products assessed. With regard to discussing these EPD’s with architects, designers and builders. Do we need to submit these to the GBCA technical team for review first or if they meet the requirements stipulated in the EPD guidelines and are an approved third party organisation can we then distribute direct to the market/project? Feedback: Health Product Declarations (HPD’s) should also be included in the Green Star system. It will foster a transparent materials economy rewarding those who disclose and empowering project teams to make informed decisions as to the human health impacts of their buildings, for both occupants and those involved in manufacturing. 3

Life Cycle Assessment in Green Star Stakeholder Feedback Report

HPD’s have recently been included in LEED v4. I believe it is only through the leadership of organisations such as the GBCA that we will see the transformational shifts the property sector can, and should, deliver. Feedback: Yes definitely, because Green Star is very influential with the Commercial buildings market BUT: Promoting the use of EPD’s is only a good thing if the EPD’s themselves are being produced and compliance verified on a robust and consistent basis for functionally very similar products and relevant to the Australian environment and market context. Unfortunately this is not the case internationally and certainly not yet in Australia. Subramanian et al examined a large number of EPD’s for five different product categories: milk/dairy (two PCRs), horticultural products (three PCRs), wood–particleboard (two PCRs), and laundry detergents (four PCRs). They report that ‘Lack of global harmonization between PCRs or sector guidance documents has led to the development of duplicate PCRs for the same products. Differences in the general requirements (e.g., product category definition, reporting format) and LCA methodology (e.g., system boundaries, inventory analysis, allocation rules, etc.) diminish the comparability of product claims.’ They conclude that ‘disparity between PCRs ranged from broad differences in scope, system boundaries, and impacts addressed (e.g., multi-impact vs. carbon footprint only) to specific differences of technical elements. The differences primarily reflected the different purposes of the PCR (e.g., label/report), the different standards they were based on (e.g., ISO 14025/PAS 2050), the use of different product categorization systems, or simply the result of being developed independently. Differing degrees of specificity and terminology between PCRs allowed for varied interpretation—at times making direct comparison difficult.’ Subramanian V, Ingwersen W, Hensler C, Collie H; “Comparing product category rules from different programs: learned outcomes towards global alignment; The International Journal of Life Cycle Assessment, August 2012, Volume 17, Issue 7, pp 892-903 Although well intentioned, as written I fear that the current approach will stimulate the generation of even more inconsistent and misleading information and disadvantage domestic producers. Feedback: Yes, this is a good approach but will take time for manufacturers to develop EPD's. There needs to be caution here. To have comparative EPD's requires matching Functional Unit, Technical Performance, Impact Assessment methodology, Product Category Rules, System Boundary, etc. Refer ISO 14025, 6.7.2. Feedback: We agree that the current approach taken in the “Environmental Product Declarations” (EPD) credit is a feasible approach that will encourage the use of EPDs in Green Star projects. Edge Environment believes, and has already seen signs that the EPD credit will result in increased industry capacity to benchmark products and materials through the use of such declarations. It will simplify the undertaking of whole-of-building, whole-of-life life cycle assessments. However, for effectiveness and long-term credibility, it is crucial that EPDs are created against consistent and meaningful Product Category Rules (PCR). The GBCA should engage with Australian EPD schemes, especially if there will be more than one, to advocate for consistent PCRs for building products from an industry and whole building perspective. These should include meaningful definitions and rules for product categories, system boundary, functional unit, impact category sections and life cycle data modelling (e.g. background data). Note that ALCAS has signed a MoU with the International EPD System, which hopefully will achieve international harmonization. However, this may also limit the opportunity for the Australian market to develop or adapt PCRs to suit the Green Star rating tool. Feedback: It is agreed that the credit will encourage the use of EPD’s within the market, however the approach taken by Green Star may also have dire consequences if EPD’s are not carefully considered and selected. The promotion of EPD’s in the Australian Market could be misleading and detrimental to the market as competing EPD’s from different international sources may have 4

Life Cycle Assessment in Green Star Stakeholder Feedback Report

differing PCR’s and may not suit the Australian local conditions/market. Also with a lack of direction when selecting differing EPD’s the true environmental impacts may be miss-interpreted. Feedback: Note that this requirement on its own is unlikely to be sufficient to ensure that the data published in EPD from multiple EPD schemes in Australia are consistent and comparable. Comparability would be further improved by referencing specific standards that the scheme needs to comply with. The forthcoming ALCAS/LCANZ Australasian EPD Scheme will align with EN15804, with adjustments for any parts of the standard that are not relevant in an Aus/NZ context. ISO21930 is the equivalent international standard, which is currently undergoing a process of revision by ISO so that it is closer to EN15804. Establishment of multiple EPD schemes across Australia, all working to different interpretations of standards and therefore producing EPD that are not comparable, should be avoided as it will not benefit product manufacturers or users of EPD. Would be worth looking at what is going on with the European Construction Organisation (ECO) – this is a European initiative to bring better alignment to European EPD schemes for construction products. There may be outputs, or forthcoming outputs, that could help with defining compliance criteria for EPD schemes to improve comparability which might be useful here. Feedback: We are extremely concerned that this approach has the potential to overlook the actual intention of LCA if there is no reference to the quality of the environmental performance to be achieved by the products selected with EPDs. As currently drafted, it would appear possible for a proponent to nominate a single building material (element) that makes up this proportion of the contract value, identify the relevant EPD for that product and then achieve the credit. This appears possible with no reference to the actual performance of the product being considered and whether it delivers some environment benefit over and above ‘business as usual’. Feedback: Without a clear and consistent methodology for the development of EPD’s there could be no credible use of the Environmental Product Declarations Credit as there would be no comparison to decide on environmental preferability. Further to this unless Australian methodologies and local conditions to compare the environmental preferability are used no product could credibly claim to be beneficial. Feedback: We agree that the proposed approach will encourage the use of EPDs. We stress the importance and preference of using Type I ecolabels over EPDs. Type I ecolabels identify environmentally preferable products based on life cycle, cradle to grave, considerations while an EPD only provides a statement of the environmental impacts and not an indication of an environmentally sustainable product. We therefore support the GBCA’s initiative to promote EPDs as part of Green Star provided that the science behind them and the procedures used by accrediting organisations are robust and transparent and that EPDs are not seen as a substitute for Product Certification Schemes. EPDs are often based on a cradle to gate rather than cradle to grave approach which potentially results in the greatest impacts of a product being omitted. As it may not be possible for a manufacturer to establish the end‐of‐life fate of the products, various end‐oflife scenarios should be modelled and included in the EPD for the product to qualify for the full points. EPDs for items with shorter expected life such as interior products should be required to include end‐of‐life scenarios. EPDs for fitout items should further be required to have a Product Stewardship Contract in place in accordance with the requirements for product certification schemes. Feedback: The use of Environmental Product Declarations, as is practiced in a number of jurisdictions internationally, is a fundamental tool in the assessment of the life cycle impacts of buildings. There does need to be firm and clear guidelines for their implementation and the proposed criteria set out in the Paper appear appropriate.

Life Cycle Assessment in Green Star Stakeholder Feedback Report

As a guide for users, reference could be made to the recent set of draft Standards produced by National Standards – “NS 11500 series - Labelling and declaration of environmental attributes of building products—Design assessment tools for product selection— General requirements” to assist users in working with a contemporary and local set of guidelines. These draft standards have been prepared with input from a range of local stakeholders, including the GBCA who is an observer in this process. The basis of these Standards has been the international set of Standards referred to in the credit – the ISO 14000 series, EN 15804 and ISO 21930. Feedback: Yes, we believe that this is a positive move that will help improving the availability and disclosure of building material environmental impacts. Feedback: We believe that the approach taken will encourage the use of EPDs by Green Star projects. We foresee an increasing uptake of EPDs by building material manufacturers. This EPD credit will support the Green Building Council of Australia’s objective of transforming the Australian building market to better environmental outcomes. Feedback: FWPA welcomes the approach proposed by the GBCA in encouraging the development and utilisation of environmental product declarations (EPD’s) and supports the GBCA position that the use of the credit should result in increased industry capacity to benchmark products and materials using EPDs, and simplify the undertaking of whole-of-building, whole-of-life life cycle assessments.

GBCA Response The aim of the current 'Environmental Product Declarations' credit is to promote the use of EPDs in order to generate publically accessible cradle-to-gate data, not the comparability of products on the basis of EPDs. If in the future the credit changes to award points based on product performance, facilitated by EPDs comparisons, the credit will need to include guidance on what EPDs can form the basis of this comparison and how. If comparability of EPDs does not become possible in the future, the credit may never evolve in this manner. Considering the current lack of product specific LCA data available in Australia, data dissemination is seen as an important first step and catalyst for greater use of LCA in Green Star rating tools. At this stage the comparison of products on an EPD basis is less important than conducting a whole-of-building/whole-of-life LCA using publically available product cradle-to-gate data published in EPDs. Unfortunately the current EPD schemes operating internationally, do not have an harmonised approach and we hope that future processes, such as the European Construction Organisation initiative and EN 15804, will bring greater harmonisation to EPD schemes. Likewise within the Australian market, we hope that any EPD schemes established here would take a harmonised approach and would provide such feedback to the relevant organisations. Reaching a situation where several incompatible EPD schemes operate in Australia will be detrimental to the value that EPDs may have in future. However, if this situation does eventuate, this will not influence the aim of the initial version of this credit, which is to promote data dissemination. The existence of the 'Environmental Product Declarations' credit is not currently meant as a replacement for the Green Star 'Furniture', 'Flooring' or 'Assemblies' credits. If in the future the credit does require a comparative assessment of products on the basis of EPDs, and if the scope of acceptable EPDs is expanded to cradle-to-grave, it is likely that this comparison will provide a more holistic outcome when compared with product certification to pass/fail standard. Any prospects of reaching this are currently speculative, as it is likely to be several years before such an approach can be even contemplated.

Life Cycle Assessment in Green Star Stakeholder Feedback Report

There are several organisations in Australia that are producing or planning to develop LCA related standards, as well as product category rules and various LCA related guidelines. The GBCA cannot be drawn to reference or endorse any of these at present without a clear justification. In an effort to encourage a harmonised methodology for EPDs in Australia, endorsing any one standard or guideline may delay the use of EPDs and whole-of-life LCA approach. In the draft 'Environmental Product Declarations' credit we have taken the approach of listing the requirements of an EPD, where these are met the EPD is compliant. It is expected that Green Star users will be able to perform this task without any issues. As the credit is used, the GBCA will monitor feedback from Green Star users and if needed will consider another approach, for example listing EPD schemes that issue compliant EPDs on the GBCA website. The GCBA would like to avoid listing EPD schemes, as we want to build the capacity of Green Star users in reviewing and extracting information from an EPD. If the GBCA listed relevant schemes, it is less likely Green Star users will review the EPD documentation in detail and will not build confidence in extracting information from this document. Health Product Declarations will be considered as part of the development of Green Star - Design and As Built, see http://www.gbca.org.au/green-star/green-star-2014/design-as-built/

Do you agree with the initial benchmarks and points available: 4% (1 point) and 8% (2 points)?

Feedback: Yes, given the market is only just starting to develop EPD's. Is the % of contract value the appropriate measure. Should this include fabrication, transport and installation as well as material value? Feedback: We propose more ambitious benchmarks, higher than 4 and 8%, are used to create a bigger incentive for EPDs and Australian LCI data to be developed and further the inclusion of a mechanism allowing for the benchmarks to be further increased over time to ensure continuous improvement. Feedback: A percentage basis of contract value may see product being specified based on the fact that they have an EPD, and make up a certain percentage of the contract value rather than the real allocation of a “Sustainability Gain”. This will also have perverse outcome that products selected may decrease performance of some building elements to purely provide the EPD. By choosing to allocate points based on EPD allocations by % of Contract value also has a major risk of putting immense pressure on product and material suppliers as they are forced to compete with products with EPD’s from other countries rather than specifies searching for a truly sustainable product sourced with environmental preferability in mind, based on Australian requirements. Feedback: We agree, in principle, with the benchmarks and points available. Ideally, the benchmark and points should be based on percentage of project embodied environmental impact rather than value. For the purposes of encouraging take up of EPDs by Green Star projects, we suggest that the benchmark and points should be based on the number of product categories covered by EPDs for the project, rather than by project value. It seems the demand for building product EPDs could wane once the main high value products (e.g. concrete and steel) have EPDs. Therefore, there may not be any strong drivers via the ‘Environmental Product Declarations’ credit to produce EPDs for lower value products.

Life Cycle Assessment in Green Star Stakeholder Feedback Report

Feedback: These initial targets and available points appear reasonable. Feedback: This approach seems appropriate. We should clarify that eTool has not been directly involved with the production of EPDs, nor attempted to quantify the implications of these cost set points. Two scenarios present potential shortfalls with the current set points: 

Some materials sectors are likely to be targeted for EPDs. Particularly those that generally have a large contribution to the total costs of the building (e.g. structural steel, concrete and glazing). This may lead to an initial burst of EPD activity and then a plateau once a critical mass of high use materials have undergone EPDs and it becomes easy to meet this criteria.

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Some materials manufacturers are advantaged (they will get far greater value from the expense of an EPD as more Green Star projects will directly benefit from it and hence favour their product).

Notwithstanding this, it is appropriate the credits are established in this manner as high use products are likely to be contributing most significantly to the environmental impacts of the project construction. Feedback: We agree that an initial low benchmark is reasonable in the Australian context as the availability of materials with an EPD is limited. Feedback: ALCAS thinks that the current market conditions warrant a low entry level. As EPDs become more readily available, the benchmarks will have to be revised (upwards) to stimulate the use of EPDs beyond a few basic materials. Feedback: The initial benchmarks and points available for the credit appear to be appropriate recognising the low levels of EPDs currently available in the Australian market.

GBCA response The use of benchmarks within the 'Environmental Product Declarations' credit, set as a percentage of the project contract value, is desirable because it is simple for Green Star project teams to calculate. Additionally, in general the higher the cost of the material as a percentage of the contact value, the greater the contribution this material represents in the total materials flow in the project. This benchmark type has been used in several Green Star credits and in most cases has proved workable. Projects are also given the opportunity to suggest an alternative benchmarking method more suitable for their circumstances, by using the Credit Interpretation Request (CIR) process. Project contract value is defined within the credit as the dollar value that will be required to complete the works for the entire Green Star rated project, including site works, for example landscaping and external paving. The following must be excluded when using the project contract value for calculations: 

Demolition works;

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Consultants, design fees, project management fees;

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Works outside the site area; and

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Buildings or areas within the site that are not being assessed for purposes of Green Star.

Life Cycle Assessment in Green Star Stakeholder Feedback Report

The benchmarks for the credit may change over time based on the availability of EPDs. At the initial implementation stage, low benchmarks reflect the low number of EPDs available for products in Australia. The GBCA will continuously evaluate the use of the credit and where needed, benchmarks will change to encourage increased EPD uptake. It is correct that the performance of products with EPDs is not addressed as part of the credit, only the existence of an EPD is considered at this point in time. However, the ‘Environmental Product Declarations’ credit is only one credit within the rating tool, and as such Green Star project teams will be looking for products that not only have an EPD but also satisfy the sustainability requirements of other credits. Other Green Star credits address the environmental performance of the products or material and include the 'Furniture', 'Assemblies', 'Flooring', 'PVC', 'Concrete', 'Timber' and 'Steel' credits. The aim of the 'Environmental Product Declarations' credit is the generation of life cycle data for products and to increase the use of LCA in Australia. Therefore the approach taken by the credit is seen as appropriate to achieve these outcomes. Percentage of embodied impact could theoretically be a great benchmark, but the methodology for calculating this right now is not widely understood. Rewarding reductions in embodied and operational impacts from a life cycle perspective is the aim of the 'Materials Life Cycle Impact' credit, not the 'Environmental Product Declarations' credit.

Do you agree with the prioritisation of product specific EPDs over industry wide EPDs?

Feedback: I believe that only product specific EPD’s should be encouraged because only these can fulfil the basic requirements of functional equivalence in an LCA based comparison. Furthermore, there should be a rigorous technical and stakeholder engagement process over how the functional unit is defined for the product specific EPD’s. Industry wide EPD’s cannot fulfil these basic requirements and should not be rewarded at all. Feedback: Yes, allows a stepping stone approach to the introduction of EPD's Feedback: We agree with the prioritisation of product specific EPDs over industry wide EPDs and proposes differentiation in terms of points awarded. This would help promote the development of an EPD capacity in Australia based on product and Australia specific information rather than on Australianised European manufacturing and emission profiles which may not be a true representation of Australian manufacturing practices. Feedback: The Use of Product specific EPD’s is a good step as this will allow product differentiation based on environmental preferability. Industry wide EPD’s should be seen as a suitable evidence of performance given that the manufacturer is able to suitably demonstrate inclusion in this industry and that the EPD is appropriate to the product. Feedback: We support the approach to differentiate between the use of industry-wide EPDs and product specific EPDs. Feedback: Yes. This is appropriate. It is excellent to encourage both industry bodies to develop data, and individual manufacturers. Industry body data may eventually feed into AusLCI or BP LCI. Individual manufacturers‟ data is ideal, particularly when making direct comparisons between other similar products.

Life Cycle Assessment in Green Star Stakeholder Feedback Report

Feedback: The differentiation between industry wide and product specific EPDs is important and the prioritisation of product specific EPDs is reasonable due to their higher accuracy. Feedback: In order to stimulate transparency, We think the prioritisation of product specific EPDs over industry wide EPDs is reasonable. The weighting of the prioritisation is debatable (as it is a subjective issue), but we don't object to the current weighting where industry EPDs are counted at half the weight of product specific EPDs. Feedback: Yes, product specific EPDs should be given priority as they provide greater transparency and improve the ability to assess competing products. To simplify the calculation and potential confusion we would however suggest doubling these percentages (8% for 1 point and 16% for 2 points) to reflect the total product cost. Unless there is something we are unaware of then halving the product cost as part of the calculation seems to add unnecessary complexity to the calculation for no apparent benefit. Feedback: The inclusion of both ‘industry wide’ as well as ‘product specific’ EPD’s is also welcomed as an excellent initiative in encouraging and assisting with the initial development of sectoral EPD activity and is strongly supported. Whilst the reasoning for prioritisation of product specific over industry wide in terms of more accurate comparisons between products options is understood this approach could be seen to arguably favour sectors with fewer and usually bigger players; the timber sector by comparison comprises a large number of smaller companies with a more restricted capacity to develop EPD’s. It is suggested that with the initial introduction that equal points should be considered and this then be reviewed at a later date. Feedback: We don’t agree with the prioritisation of product specific EPDs over industry wide EPDs at this stage of development in Australia. It appears industry wide EPDs have a very important role to play. By providing equal preference for industry wide EPDs, there will be clearer incentives and drivers for stakeholders to work together in a coordinated and cost-effective manner to develop adapted and practical PCRs and EPDs to represent all producers. By preferring product specific EPDs, there will be less impediment for industry wide collaboration to develop and adapt the required PCRs. In our experience, this is often the bottleneck for the implementation EPDs. Feedback: The use of EPDs is in its infancy in Australia. This credit provides encouragement for a wider range of building products to be described in terms of their environmental performance. The Green Star proposal provides encouragement for the preparation of industry wide EPDs in the first instance. Once the process is understood at all levels, from manufacturer to practitioner, there will be a move to product-specific EPDs. Whilst it is recognised that product specific EPDs would be preferable in the longer term, the reality is that in both Australian and internationally, there is not a sufficient critical mass of product specific EPDs to make this practical. Therefore the combined use of both industry wide and product specific EPDs is supported.

GBCA response At this early stage of EPD use in Australia, we believe it is important to reward both industry wide EPDs and product specific EPDs. Industry wide EPDs are simpler for products suppliers to produce and offer an 'entry level’ EPD. This should ease the pressure on suppliers to produce EPDs and allow them more time to produce product specific EPDs. Whilst we understand the concerns raised here, we are ourselves concerned with overstretching the implementation timeline for the credit. If at first the credit awarded equal weighting to industry wide and product specific EPDs and then at some point in future this was changed to differentiate between the two, precious time would have been lost and marginal benefits gained (in LCA data dissemination). Given some stakeholder support for differentiating product specific and industry wide EPDs (as above) this differentiation will be part of the credit.

Life Cycle Assessment in Green Star Stakeholder Feedback Report

Do you have any comments or suggestions for improvements to the ‘Environmental Product Declarations’ credit’s compliance requirements?

Feedback: Establishing a single consistent consensus agreed methodology was the principal objective and outcome of the BPIC LCI project. I am surprised that GBCA have chosen to ignore this work in favour of EPD’s from overseas on an inconsistent basis that is not adapted to Australian conditions or markets. At present, the effect of these credits will be to promote the use of imported products, because only these can be supplied from recognised conformance assessment bodies at present. It the required EPD’s needed to be consistent with the BP LCI Methodology requirements or at least the AusLCI Methodology Guidelines this would make the EPD requirements much more robust, reliable and Australia relevant and Australia would show leadership internationally. National Standards is working to engage industry stakeholders and produce standards and Product Category baseline Reports which rigorously study how functional units (and performance baselines) are set for specific product EPD’s. I would commend GBCA considering adoption of the functional units from this work to greatly enhance the rigour and Australian relevance of these credits. Feedback: I would suggest that the GBCA look strongly at the work of the BPIC (Building Product Innovation Council) and the BP LCI (Building Product Life Cycle Inventory). The BP LCI project was undertaken by members of the Building Products Industry and worked on developing an industry agreed Methodology. The use of this methodology would ensure that Green Star would be working on Australian relevant data. National Standards is also working with industry bodies and stakeholders to develop PCR’s which would be set for Australian conditions and requirements for specific Product EPD’s. Use of the BP LCI Methodology and the Industry agreed PCR’s would be beneficial when basing the compliance rather than requesting only EPD’’s based on any (possibly conflicting) international source. Feedback: The documentation needs to highlight what standards the EPD is compliant with. Why give an option of ISO 21930 the aim should be EN 15804 with a push to have Standards Australia adopt the standard thus making it an Australian Standard and therefore more readily available to Australian industry. It should be clear that additional impact categories are also compliant. Feedback: We agree that the approach taken with the EPD credit will encourage the use of EPDs. We recognise that the provision of industry and company specific EPDs is a key part of this as the market adjusts to what will surely be an increase in demand for EPDs. However, in order to assist the availability and credibility of EPDs in the marketplace, EN15804 needs to be adopted as an Australian standard. Feedback: We agree with the points available for the credit but proposes one additional point is awarded where products (or a percentage of products / product value) are also certified by a GBCA‐recognised product certification scheme. This would encourage the use of EPDs and also increase the demand for environmentally preferable products. Due to the limited scope of products covered by the GBCA, all products certified by GBCA‐recognised product certification schemes should be recognised assuming standards are developed based on a life cycle approach and are publically and freely available online for download by stakeholders. The draft EPD credit requires EPDs to have been independently audited and peer reviewed by a third party. We propose the peer review should be undertaken by a LCA professional independent of both the product manufacturer and the consultant/organisation undertaking the LCA behind the EPD. We propose all EPDs used as part of Green Star submission should be publically available on manufacturers’ websites. 11

Life Cycle Assessment in Green Star Stakeholder Feedback Report

Feedback: It is not clear why EPDs would need to be reviewed by Green Star users & Assessors? How are they supposed to review the EPDs? If reliable schemes are suggested by the GBCA, then EPDs sourced from these schemes should not need any ‘review’ process as they meet the credit criteria. It would, in fact, be useful if GBCA created a formal source or directory of compliant EPDs as they become known and available for construction materials/products in the context of the Green Star rating system in Australia. Feedback: ALCAS have recently announced they will be adopting the Environdec EPD system product category rules for Australia. This is excellent news for the following reasons: 

Most existing EPD program operators in Europe are aligning to the ECO EPD product category rules for all their construction products so any product registered by a participating program operator will be comparable.

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Environdec is one of these program operators so it's a particularly suitable choice for construction materials.

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The ECO EPD system is fast becoming recognised as the international standard for construction products and is likely to be adopted internationally.

We recommend adoption of the ECO EPD system program operators as the common standard, or at least the preferred standard, which is reflected in the credit allocation. This will ensure manufacturers are guided towards a system that will be internationally recognised and will help designers make comparisons between products when assessing EPDs in association with a Green Star project. We suggest the following to improve on the current credit: 

Align the environmental indicators from the ‘Materials Life Cycle Impacts’ credit with the ‘Environmental Product Declarations’ credit.

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ALCAS has signed an MoU with the International EPD System. In effect this requires EPDs for building materials to comply with EN15804. We would appreciate if this could be highlighted in the credit description.

Feedback: There is a need to establish a rigorous set of guidelines for LCA in the Australian market. The EPD credit provides some scope around this in the context of a voluntary rating tool which is supported. However, BPIC is keen to see the use of LCA in the broader context over time. To this end, has already established a consistent agreed methodology suitable, and supported by, the Australian building materials suppliers and a significant sector of LCA practitioners. BPIC would strongly recommend that the credit’s compliance requirements reference the BPIC methodology and database in both the compliance requirements and guidance. An important, and unique, feature of the BPIC dataset is that it reports data in an Australian context. EPDs sourced from overseas sources will be based on data pertinent to countries other than Australia. While this may be valid, we would put the case that where local data exists for the production of EPDs, it should be used and applied in preference to international data. Feedback: In terms of the initial benchmarks and points available, the proposed approach may not provide enough incentive to target points in this credit, and adequately incentivize industry-wide adoption of EPDs. Most Green Star projects look at weighted points and ‘bang for buck’ (i.e. cost/effort per weighted point) so if this credit sits in the Materials category, the weighted points available will be quite low compared to points available in more heavily weighted categories. Furthermore, a sliding scale should be considered to encourage all levels of effort and exploration made in this area, especially at this inception phase of EPD adoption in Australia. Providing a first step at 4% will prevent projects that make the effort to explore EPDs and get say 1-2% from getting any points at all. This is likely to prevent many projects from looking seriously at the credit. Providing a ceiling of 8% is likely to limit the amount of effort that the industry puts into this area, so perhaps an innovation point for going beyond the Green Star benchmark could be introduced, much like the LEED innovation criteria for exemplary performance. Green Star could reward initial explorations 12

Life Cycle Assessment in Green Star Stakeholder Feedback Report

so that the industry becomes familiar with the concept of EPDs; this is likely to result in more rapid take-up of this credit and result in faster and greater market penetration, especially if a ceiling is avoided. Feedback: The credit requires EN 15804 or ISO 21930 to be used. ISO 21930:2007 refers directly to ISO 14025 and can be described as a 'Building Product' level extension of ISO 14025. EN 15804:2011 is a much more detailed and directive standard especially in relation to reporting of The Product Stages and its relevant Information Modules and particularly in how co-product allocation should occur it is very explicit- where 21930 is virtually silent except to refer back to ISO 14040. It is not a 21930 equivalent. It is however intended that 21930 is to be aligned with EN 15804 in time. Currently alignment of ISO 21930:2007 with the content of EN 15804 has been started in ISO/TC59/SC1- it is at 10.99 'New project approved' stage and is a long way from finalisation. see http://www.iso.org/iso/home/store/catalogue_tc/catalogue_detail.htm?csnumber=61694. Hence any references to mandating EN 15804 should not include ISO 21930. EN 15804 includes substantially increased compliance detail and is only relatively recently introduced. The vast majority of EPDs in the Market (including GreenTag's EPD pipeline) will be 14025 compliant. Hence if 15804 is mandated at this stage there will be a paucity of EPD data available and the Innovation Challenge credits will likely not be effectively able to be implemented for a number of years- probably at least 2-3 years. It may even be more given the US has not to my knowledge indicated its inclination to follow 15804 at this stage whereas most US companies are currently reporting to 14025. Feedback: we supported the transitional use of ISO 14025 for 2-5 years with the staged implementation of EN 15804 or its ISO successor so while 15804 would be recognised from the outset there would be a defined sunset period for 14025 EPDs. I reiterate this suggestion. In the section 'Documenting LCA results' for Buildings there is a reference also to ISO 21930 - this is incorrect as 29130 is the standards for EPD of Building Products. ISO 21931 is the Standard that relates to declarations for Buildings. This standard would then need to be included in the 'Guidance Standards' section.

GBCA response The credit does not seek to only support overseas made products; the credit aims to promote the use of EPDs in general. However it is recognised that no EPD schemes are currently established in Australia. Ideally, the Australian LCA industry should strive to achieve an Australian EPD scheme, or at least one set of guidelines, standards and rules that all Australian EPD schemes should use. The European experience with EPDs over the past decades provides good lessons. Currently Europeans are working to harmonise EPD approaches from across the continent, and EN 15804 referenced by the credit is one such example. This may lead to ISO 14025 and its varying interpretations becoming superseded. Choosing to endorse any EPD guidelines or standards could be detrimental to the credit aim of increased use of EPDs in Australia. References to ISO 21930 have been removed from the credit criteria. The revised credit will reference ISO 14025 and EN 15804. There seems to be some consensus that EN 15804 should be adopted as an Australian standard. The impact category requirements of the credit may be clarified in future with the intention to require at least the same impact as required by EN 15804 so that whole-of-building LCA data requirements are provided by EPDs. See feedback related to the â&#x20AC;&#x2DC;Materials Life Cycle Impactâ&#x20AC;&#x2122; credit below.

Life Cycle Assessment in Green Star Stakeholder Feedback Report

The ‘Environmental Product Declarations’ credit will operate alongside the existing ‘Furniture’, ‘Assemblies’ and ‘Flooring’ credits. Green Star project teams are likely to choose products that will satisfy both sets of credits, meaning they are both certified to GBCA recognised product certification schemes and have an EPD. With time and when wide uptake of EPDs in Australia is achieved, there may be opportunities to use EPDs to compare competing products and choose products that are preferable. If this comparison is made on a cradle-to-grave basis, this may provide a superior alternative to product certification schemes. The requirements for LCA peer reviews are described in ISO 14044 and reference to these requirements are included in the text of the credit, to ensure appropriate peer review requirements are followed. The main advantage of asking Green Star users to review an EPD is to increase their understanding of how data can be extracted from EPDs, which will prepare Green Star users for any future use of EPDs in product comparison . If the GBCA listed the schemes which issue compliant EPDs, we feel it is unlikely the EPDs will be read and understood. The requirements for a compliant EPD are very simple and often form the basis of the cover page of EPDs. At present there are some Green Star users already using the credit and they have provided feedback confirming the EPD meets the requirements is simple. With time if the need arises and based on user experience we may list compliant EPD schemes on the GBCA website. The ECO EPD system is an example of EPD system that is needed internationally, one system that fits in with all countries, meaning EPDs are more comparable. It is encouraging that the EPD system considered for Australia will be operating in accordance with the ECO EPD system. At this early stage we prefer not to limit relevant EPD schemes, we want to create momentum in EPD use now, not delay this for future. Choosing which data to use in Australian produced EPDs is the task of those establishing EPD schemes in Australia. It is understood that the use of Australian data is preferred to overseas data in any LCA work undertaken in Australia, whether as part of an EPD or as part of a whole-of-building LCA. It is proposed that in the initial implementation of the credit, it will form part of the Innovation Challenges within the Green Star Innovation category. This provides a very strong incentive for use of the credit. After a period of time and with wide use of the credit by Green Star project teams it is anticipated that the credit will become part of the Green Star Materials category. At such stage, the point allocation will be designed as to ensure enough incentive for the use of the credit still exists.

Life Cycle Assessment in Green Star Stakeholder Feedback Report

After reviewing the requirements for determining the compliance of an EPD with the credit, are you confident that you would be able to quickly and conclusively determine EPDs that are compliant with the credit and those that are not? For examples of EPDs please visit: http://www.environdec.com/en/EPD-Search/ or http://bau-umwelt.de/hp481/Environmental-Product-Declarations-EPD.htm. Feedback: Because there is no consistency in EPDâ&#x20AC;&#x2122;s internationally, I donâ&#x20AC;&#x2122;t believe that anyone could claim that they could determine compliance of an EPD on a credible basis. Feedback: A list of available EPD schemes and their compliance status would add value (as an appendix or regularly updated info page on a website). Feedback: The Discussion Paper suggests that EPDs must be sourced from schemes that meet certain criteria such as audits of EPDs, third party peer-review, cradle to gate scope at a minimum, etc. It would be useful if GBCA could provide a list of schemes that would be recognized as trusted sources of EPDs. This would facilitate the users of EPDs and as well as producers, particularly in view of the fact an Australian EPD scheme does not yet exist. Feedback: Yes. The requirements are not arduous and most product category rules that exist for construction materials already comply. Feedback: Yes, the description is clear. Feedback: The requirements that an EPD be issued by a scheme which is independently audited, applies cradle-to-gate scope as a minimum and has been peer reviewed by a third party is supported and should be readily discernible . However it is suggested that a close alignment with the BPIC methodology be considered as a means of ensuring a clear and consistent comparison of EPDs. Feedback: The requirements for determining the compliance of an EPD are clear and as such there should be a high level of confidence that a compliant EPD should be able to be quickly and conclusively determined.

GBCA Response: The requirements of an EPD as detailed in the credit should be met by many EPD schemes, these include compliance with standards, boundary considered and peer review. Green Star users are not conducting a comparative assessment using EPD, they just verify that EPDs contain these requirements. In response to feedback, as listed above, the credit now only references ISO 14025 and EN 15804. Listing of EPD schemes will be considered with time, if it becomes apparent that Green Star users are unable to review an EPD and determine compliance. We want to build capacity to review EPDs and extract information from these documents. Green Star projects using the 'Environmental Product Declaration' credit have already communicated to the GBCA that they have confidence is in reviewing EPDs.

Life Cycle Assessment in Green Star Stakeholder Feedback Report

Rationale for the Reference Case Criteria Do you agree that the requirement for project teams to develop their own reference cases is an adequate and appropriate interim solution until such time as a prescribed reference case can be developed? Feedback: The prescriptive requirements expressed in the innovation challenge, if followed completely and entirely would present an assessment and peer review cost of $20,000 or more – which is not plausible. Feedback: I am very pleased that GBCA have taken the bold steps to introduce whole building LCA credits into Green Star and wish to support this initiative as much as I can. I understand pragmatically why this approach has been adopted, but it would not have been my preferred approach because it is expensive and time consuming (assessing and documenting two designs), open to considerable abuse (because the reference project is so open to interpretation) and for this reason also likely to lead to problems and controversy determining compliance. In addition, this approach constrains design team innovation, because many of the key design decisions (massing, form, orientation etc.) are likely to also be wrapped into the reference as well as the actual design.

Feedback: Agree this is possible however there needs to be a process to ensure there is no over inflation of the benefits relative to the business as usual case. Feedback: At this point in time it is appropriate for project teams to develop their own reference cases, however the reference cases developed should be carefully monitored to view trends in the data submitted, and how this may be open to abuse. Once the GBCA has developed standard reference case projects the self-developed reference case should be removed due to its possibility to be misused. The self-developed reference case should only be allowed in special circumstances and should require a special review for abnormal circumstances. Feedback: We agree generally that project teams should develop their own reference cases. However, we do not believe that it is best to base this on an existing separate reference case project. The reason for this is outlined below in an extract from our response to the GBCA’s initial Discussion Paper; “Using a standard practice reference case for each building typology is extremely difficult in practice. This is because there can be a large range of variability between buildings and often this is driven by factors outside of the designer or builder’s control. We would suggest a different modelling approach that mirrors the way energy modelling for the Public Buildings Pilot and Industrial Tool are undertaken. In this approach the reference case is the proposed building, modelled assuming a minimum BCA compliance level and then compared to the proposed building with its as built mix of materials and inclusions. The reference case needs to be based on the proposed building to be constructed, not a hypothetical or similar building typology. In this way a reference case is formulated based on the actual project building and takes into consideration its unique circumstances. Building design will not only be a response to low environmental impact, it is also a response to tenant requirements, aesthetics, site location, site conditions, planning constraints and budget etc. Because of this it will always be difficult to define a meaningful and reliable reference case for every project. For example: 

Incorporating inter-tenancy stairs in a structural design will increase band thicknesses and therefore concrete and reinforcing provision in the structure, when compared with a design devoid of this feature; 16

Life Cycle Assessment in Green Star Stakeholder Feedback Report



Open floor plates with large cantilevered slabs provide great tenant flexibility and future adaptability, but can increase structural impact over a cellular office space with tighter slender column grid;



A double skin facade on a commercial high rise provides protection to external blind systems, improved acoustic performance and the ability to operate mixed mode spaces where wind conditions would otherwise make this difficult, however, they have a significant increase in embodied impact due to the additional materials required;



Underlying rock strata, ground conditions and proximity to costal tidal zones can significantly effect the substructural requirements of buildings. The reference case should be based on a project that is subject to the same external influences, market drivers, location and unique architectural characteristics.” We would strongly suggest that it is better for the “Actual Reference Case” to be based on the project at a particular stage in design development “e.g. Contract Price” and then compared to the final as-built constructed design.

The design process is an iterative one which constantly re-evaluates design materials quantities and costs. Early in every project a costing exercise is undertaken whereby quantities of standard materials are ascribed to every item in the building. This in effect provides an ideal reference case or point in time at which the process of optimising material selection and overall building design begins. There are also clear design development milestones within each project at which point the designs are compared. These milestones lend themselves perfectly to evaluation using Life Cycle Assessment (LCA) and as a way to measure design improvements and identify opportunities to reduce environmental impact. Furthermore, we need to understand the implications of emerging BIM technology that will bypass more traditional approaches to LCA for buildings. The increasing use of BIM in building design is enabling rapid LCA of project designs right from concept stage through to delivery. Lend Lease is using this technology on a number of projects and believes that this approach is more effective in delivering significant environmental benefits as it can provide close to real-time feedback to designers and specifies and has the potential to better integrate sustainability with the whole design development process. While we agree that attempting to benchmark your project against an historic set of similar buildings is an interesting exercise, it ultimately leads to the investment of significant effort in selecting the most appropriate baseline building rather than focusing attention on how the current design can be optimised and improved upon in the first instance. In short this approach means that significant emphasis is placed on interrogating the accuracy of the baseline rather than focussing on optimising the project design. Lend Lease, has investigated and used both methods on a number of projects including Barangaroo. After much consideration and experience we have come to realise that what we are suggesting is the most streamlined and effective approach that can deliver tangible environmental improvements. Feedback: Albeit supportive of the cradle-to-grave approach outlined in the Materials Life Cycle Impacts Credit, we foresee a number of challenges with the proposed ‘reference case’. Principally our concern resides with the lack of governance around the reference case process. In order to prevent the inflation of results by way of comparing the actual design materials life cycle impacts and those to a lower durability quality for example, strong third-party governance is required. Additionally, we suggest GBCA considers the difficulty in completing this exercise whereby a building is effectively designed twice. Therefore, it is suggested that the GBCA develop a range of options to award credit based on material life cycle performance or improvements and test with industry. Criteria for these options might include: ‘difficulty to do’ and ‘outcome’. In any case, we suggest credits are awarded for having collected materials life cycle impacts for a building and in the medium term, assess performance standards. In the longer term the GBCA suggests reference buildings will be available for comparison to cover the multitude of variations required. However, again we are unsure if this is practical. For example a building in Sydney founded on sandstone will fare better than one in Melbourne founded on silt and therefore not be a fair comparison. A four storey building in a business park will fare

Life Cycle Assessment in Green Star Stakeholder Feedback Report

better than a 40 storey building in the CBD. Multistorey car parks will fare better than multistorey archive buildings. There are countless permutations of reference buildings that would need to be developed. Feedback: Notwithstanding the Specific Guidance notes provided in the credit, the use of a ‘hypothetical’ reference case as the Standard Practice Reference Case for the assessment, to be defined by the project designers/developers, is potentially problematic; it leaves the door open to all sorts of derivations and interpretations of a reference case. Feedback: We understand that no matter what approach the GBCA chooses, there will be pros and cons. The current pathway is workable. Periodic evaluation is a must. In more detail: Yes, we believe that project teams are well placed to define their own reference cases. There is some risk in that the reference cases might be defined too conservatively, thereby making it easy to achieve the improvements without too much additional effort. However, at this stage we believe that it is more important that project teams get experience in defining reference cases, rather than try to eliminate all possible shortcomings. This will provide the necessary experience to improve the guidelines for defining reference cases in credit updates. Were possible, the reference case definition should be linked to other established GBCA policies, such as: Minimal requirements for operational energy performance Reference concrete compositions (http://www.gbca.org.au/green-star/materials-category/revised-green-star-concretecredit/34008.htm). Feedback: A prescribed reference case will take a considerable period of time to be developed and agreed. Hence, an interim measure of a bespoke reference building for each project would appear to be the only viable alternative. However, we would caution that such a provision will require strict and rigorous review to ensure that gaming of outcomes cannot occur. The selection of the benchmark may be reasonably arbitrary, provided it reflects a practical form of construction; although once selected and specified in the standard, it should not be changed. If the benchmark is too liberal, most practical construction will “look good”. If the benchmark is too conservative, most practical construction will “look bad”. However, irrespective of whether the benchmark is liberal or conservative, the relativities between the various target systems and products will remain the same. In other words, the selection of the benchmark does not affect the apparent comparison of one system or product to another. Feedback: Yes it is agreed that as an interim case the project teams should be required to develop their own reference cases. The GBCA’ proposal to offer two approaches a ‘standard practice reference case’ and an ‘actual reference case’ is also supported. Close attention needs to be paid to ensure projects however do not ‘game’ in regards their comparative analysis by overstating or understating particular material use in the reference building to improve their comparison case. It is recognised however that initial shortcomings such as this will be identified and improved upon as more projects are undertaken and collective experience is gained. In regards to the proposal that the GBCA team develop over time a prescribed reference case, to remove the need for project teams to develop individual references cases for each project, it is suggested that this development should include the participation of broader industry stakeholders active in this area.

Life Cycle Assessment in Green Star Stakeholder Feedback Report

Feedback: The GBCA announcement for LCA in Green Star is fantastic news for LCA practitioners and the environment. Is there a risk that "gaming" the credits will put the long term implementation of the credits at risk? I've had a pretty good look at the credits and read EN15978 pretty carefully. I'm confident that a compliant LCA should certainly be comparable between studies. It is possible though that inappropriate reference buildings are chosen that inflate the improvements of the case building. This is something I'm keen to see avoided. With that in mind I thought I'd put together some notes on starting points for reference building assumptions. For energy calculations the GBCA have a "Standard Practice Benchmark" defined within each rating tool. I believe for offices this is equivalent to a NABERs 4 star rating. For energy use I think this is a great starting point. Feedback: The definition of a suitable reference case can be complex and open to interpretation, which can make this a difficult exercise. Our research includes the development of reference buildings, based on real buildings, for New Zealand although we are at a very early stage and have no results yet. Feedback: Yes. There is risk of “gaming”, however, if a critical mass of reference cases are developed, this risk will be mitigated in the future. The following outlines some shortfalls we have found with this method to date: 

Good design is somewhat disadvantaged by obtaining the standard practice reference case through modelling the same geometry with BCA compliant fabric, mechanical services, electrical systems etc.



Poor design relies more heavily on upgraded building fabric and services to perform at an acceptable level for Green Star, therefore modelling the building without these high spec features will result in a large energy gain.



Good design relies more heavily on geometry and appropriate consideration of building functionality, therefore changing fabric or services will have a smaller effect on energy consumption, even if high spec systems are used in the Green Star design.

We have found this with one of the Green Star projects we are currently working on. Moving to BCA compliant services and building fabric resulted in a very small net increase in energy consumption (the BCA compliant building model would very nearly rate NABERS 5 Star). It has been surprisingly difficult to find actual reference cases due to the following factors: 

A limited number of “average” performing buildings has been constructed by tier one construction companies, so the pool of buildings with readily available documentation is limited, particularly in some cities, for some companies.



When buildings are identified, obtaining the required documentation including actual energy performance can be difficult due to third parties.



Buildings of a scale that typically represent Green Star projects are usually leased long term, and hence NABERS ratings and associated documentation on actual energy use may be expired and unavailable.

Feedback: The development of references cases by the project team is very work intensive. We think the GBCA could develop a database with reference buildings based on the initial projects going through this process. In the interim we suggest a similar approach as with EPDs, if a whole of building whole of life LCA is done, points should be awarded regardless of performance. EPDs will over time then feed into this approach.

Life Cycle Assessment in Green Star Stakeholder Feedback Report

We are not sure if the comparison to a case study adds value in particular if impact categories with a high uncertainty (human toxicity) must be included. Are credits only awarded if the LCA of the actual building is compared to a reference case study (not very clear)? Comparability between projects is not given with this approach as different project will define different reference case studies and therefore will achieve a different reduction. Taking the reduction as an evaluation measure of the project is therefore questionable and comparability not given even between similar projects. Feedback: I'm not actually an LCA practitioner but come from a background in commercial buildings. The need for locking down a definitive reference building method is actually a big issue in the industry as a whole and is an issue that we come across in areas even outside of LCA. Definitely locking down a standard industry-accepted reference method is prudent. This appears to be more of an issue in commercial buildings due to the fact that we don't have a national regulatory framework that is based on an absolute scale like NatHERS. The commercial equivalent of NatHERS for compliance, the so-called BCA Section J "JV3" method, for carrying out a modelling-based "engineered solution" for a commercial building relies on a reference building method rather than a absolute scale such as NatHERS. That said, NABERS has been semi-regulatory for a while since mandatory disclosure was introduced for commercial premises over 2000sqm, so there is a growing database of commercial energy benchmarks to go off, but still nowhere near as comprehensive as it is for residential. It is somewhat easier to develop a benchmark reference case for operational energy due to this database and picking a nominal average would not be too challenging. However, developing a reference case for building form, construction methodology and materials is a major challenge. The BCA Section J has dealt with this issue by requiring that the "reference building" used in the JV3 analysis has the same building envelope and form as the proposed building except that BCA minimum compliant materials are replaced. This is an ok start, however it creates big issues when you have a well designed building to start with as its hard to squeeze additional performance out of a building that starts from a good point... thus unfairly penalising good design in a way! I suppose off the top of my head what I would like to see is: A standardised benchmark commercial building which is always the reference case for every LCA analysis which would consist of: a) Operational energy performance and internal heat gains as determined from statistical analysis of the CPD mandatory disclosure database b) A "regular" building form with no surrounding buildings. A rectangular office building with concrete slabs, central core and curtain glazing accounts for probably about 85% of office building stock. c) An accepted "standard" construction method which gives slab thicknesses, rebar, footings, etc. etc. d) The reference building would have to be almost a full design that is derived based on consultation with structural, mechanical, electrical and architectural professionals in the industry. It would be a bare-bones design that is representative of say 90% of commercial building stock. e) The design could be easy stretched and skewed to account for various types of building sizes and floor areas 2) The LCA analysis would likely have to still model the reference building as well as the proposed building in order to eliminate the errors that might arise across various software platforms and tools Alternatively you could just carry out a massive study using a standardized building as outlined in (1) above and then just develop industry-standard benchmark "rates" for various impact categories based on square-meter rates. Just some ideas but yes the issue of reference buildings is not simple and certainly not a resolved issue in the industry!

Life Cycle Assessment in Green Star Stakeholder Feedback Report

Feedback: Without a reference case example it is impossible for us to make a value comment on the potential effectiveness of the proposal. Suggest a reference case be developed and then we can test for the impact sensitivities. Feedback: We would not recommend the reference building approach but rather award points on the basis of direct absolute Ecopoint / (m2 GFA) thresholds at different levels for different levels of credit. However we understand the current constraints and that the use of reference cases offers an immediate solution.

GBCA Response The costs estimated raised in stakeholder feedback have been noted. The GBCA has yet to receive actual cost / benefit information from project teams, but will be seeking feedback from those using the credit as an Innovation Challenge. It is acknowledged that the requirements of the 'Materials Life Cycle Impact' credit are prescriptive, asthey include specific LCA methodology requirements. However this is seen as a necessity, otherwise the data collated from Green Star projects will not be consistent and the aim of the credit to encourage data dissemination may not be achieved. In comparison to the current assessment of materials within the Materials category, the 'Materials Life Cycle Impacts' credit is more holistic and less prescriptive. The credit requires both the engineer and architect for the project to sign declarations confirming that the hypothetical standard practice reference case is a true representation of contemporary design and construction practices. In conjunction with proposed changes to the credit outlined in this document, this should ensure the reference case is realistic and reduce the opportunity for 'gaming'. We strongly believe that the advantages of introducing a reference case comparison model in the credit outweigh the possible issues. We accept this is likely to present many challenges but believe that over time and with further clarification where required, an acceptable process for reference case will be developed. It is also important to point out that this uncertainty is not a deviation from ISO 14040 or ISO 14044. In comparison with the current Materials category accepting this uncertainty delivers a far more holistic outcome, not a prescriptive one, which is the aim of using LCA. The use of a reference case is common practice in other Green Star credits, the Building Code of Australia (Section J), NABERS as well as other framework and rating tools. Including the concept of reference case criteria in the 'Materials Life Cycle Impacts' credit will increase the capacity within the industry to undertake reference case comparisons for a range of buildings in the near future. This is an important outcome that the credit seeks to achieve, in addition to reducing the environmental impact and increasing data dissemination. The GBCA intends to monitor trends in collated data and develop advice as needed, in an effort to improve the information available on the reference case. In the future, as more and more projects use LCA-based credits, it may be possible for the GBCA to use collated data to create a prescribed reference case. This prescribed reference case would then take the place of a project created reference case. Before using any data the GBCA will map and discount any outlying data. This data will be made available publically to assist practitioners in conducting LCA. A prescribed reference case may only be a better solution than one created by the project team once a large amount of project data has been collated. Until such time, asking project teams to develop a reference case is more accurate than a reference case prescribed on the basis of limited data, despite any uncertainty. At an individual project level, it does not matter how one project's LCA results compare with another's since Green Star certification is awarded to an individual building or fitout, it is the relative LCA performance of this the one project that matters. Once a large amount of LCA data is collated, comparability with a prescribed reference case would be possible, only then would a prescribed reference case 21

Life Cycle Assessment in Green Star Stakeholder Feedback Report

be superior to a project created one. Changes to the credit criteria require the hypothetical standard practice reference case to be created based on equivalent tenant requirements, aesthetics, site location, site conditions, planning constraints and BCA minimum requirements to name a few. The Green Star experience to date has shown many projects have achieved significant energy reductions when compared to a BCA compliant reference case, this can be seen in data released as part of the The Value of Green Star: A Decade of Environmental Benefits. The proposed updates to credit criteria also include benchmarks based on the Green Star 'Greenhouse Gas' credit and the 'Concrete' credit. This removes some of the ambiguity and opportunity for 'gaming' of the reference case, which is a concern of many stakeholders. With regards to Building Information Modeling (BIM), it can be anticipated that LCA-based processes incorporated into BIM could be developed in a manner that provides for the Green Star credit requirements and could generate the required documentation needed for peer review and Green Star project submission. Along with other streamlined LCA tools, this could simplify the application of the credit and significantly reduce costs. The credit will continue to reward comparison against an actual reference case. This option is preferable because we can collate two sets of LCA data sets for actual buildings, one being the reference case and the other the actual project. This may speed the development of a prescribed reference case. On this subject and in response to concerns of how realistic the creation of this prescribed reference case will be, we anticipate that complex projects will not be able to use a prescribed reference case but that more conventional designed project will be able to use a prescribed reference case based on similar projects for which the GBCA have received data. Complex projects, for example mixed use projects, may continue to use a project developed reference case for some time, even if prescribed reference cases have been developed for the credit. The Reference Case criteria of the draft credit have been combined in one criterion, this means the actual reference case option remain to be used where data for an actual building or fitout is available, but this option is equal in reward to the standard practice reference case option. This change acknowledges the likelihood of projects finding data for an actual reference case.. Changes have been made to the credit to include reward for conducting a whole-of-building whole-of-life LCA for the project, without the need for creating a comparative reference case. The number of points available for this option is lower relative to the reward on offer for a comparative assessment to a reference case.

Do you have any comments, feedback or suggestions for improvement for the ‘Materials Life Cycle Impacts’ draft credit’s compliance requirements regarding the establishment of a reference case? Feedback: Please clarify if GBCA intends to itself become a conformance assessment body under ISO14025 if it is referring to these guidelines as Product Category Rules?

Life Cycle Assessment in Green Star Stakeholder Feedback Report

Feedback: A comparison to an ‘Actual Reference Case’ is not necessarily better than a ‘Standard Practice Reference Case’ as it is unlikely a building identical to the proposed design is available. This means percentage reductions are established against buildings that are not necessarily comparable. As LCAs of buildings by their nature can provide very different result based on quantities and certain assumptions made, this may result in uncertainties exceeding the five percent allowed impact increase and potentially even the 20 and 25 percent reductions targeted. By comparing to a ‘Standard Practice Reference Case’ the layout and size etc. are identical while benefits are modelled based on the actual design/material choice innovations proposed. Feedback: We understand that GBCA does not have the resources to define reference cases but perhaps an approach whereby the Standard Practice reference case uses agreed weighted averages of actual practice for common materials and applications could be developed up front by the GBCA. For instance, in the case of window profiles, the reference case might assume 85% Aluminium + 10% wood + 5% PVC, rather than a single material. Feedback: Our preference for the standard reference case is to provide greater guidance. Feedback: Credit distribution is not very transparent. Definition of the reference case study is not very clear from my non-building expert perspective. Feedback: It may be appropriate to nominate that the form of construction selected as the benchmark is one that meets the ‘deemed to satisfy’ provisions of the National Construction Code BCA Volume One and BCA Volume, hence avoiding any potential variations arising from alternative solutions in a building. Feedback: Although we recommend that the GBCA mitigate that project teams allowance for creativity in purposely developing high impact reference cases to make their actual project appear to perform well. We recognize that this necessary control likely will result in considerable costs and contention in documenting and appraising both the reference and actual design and then to appraise both the reference and actual for the award of credit. In addition, for consistent assessment, presumably GBCA will need to standardise many design and specifications aspects between the reference and actual designs. This may be a constraint to design team ingenuity. The more aspects that are standardised, the less the gaming and the more consistent the assessment between projects, but also the greater the constraint on design innovation. We would suggest the GBCA consider developing a Materials calculator, similar to the ISCA Materials calculator for consistent modelling purposes.

GBCA Response The credit requires the reference case building to be designed by the project architect and engineer and signed off by them as representing standard practice. These professionals should be able to confidently determine the mix of materials that make 'standard practice'. We wish to avoid prescribing what materials represent 'standard practice' in different applications, as this may become too complicated and may constrain design solutions. LCA practitioners do not necessarily need building experience, although this would clearly be an advantage. Changes have been made to better define the reference case, including providing more guidelines on how the reference case is to be developed and a definition of whole-of-building. Some of these changes have been influenced by stakeholder submissions listed in this document and by the experience of projects currently undertaking LCA in accordance with the credit and those who have already submitted this credit for Green Star assessment. The GBCA does not intend to become a conformance assessment body, the terminology in the credit has been changed to 23

Life Cycle Assessment in Green Star Stakeholder Feedback Report

clarify this. The point allocation for the actual and standard practice reference cases have been equalled. based on feedback related to an acceptable margin of error, this has been increased to 10%. LCA practitioners have confirmed this is a realistic expectation, unlike the proposed 5%.

Scope Is the EN 15978 definition of ‘whole-of-building’ appropriate for use here? If not, what alternative definitions could be used and why? Feedback: I could not find a definition of ‘whole of building’ anywhere in ISO15978, but the collected work does indeed describe whole buildings over their full lifespan and including end-of life. Feedback: EN 15978 does not appear to have a specific definition , however if referring to the context of the entire document it seems appropriate. Feedback: Whilst EN 15978 doesn’t actually have a formal definition for ‘whole-of-building’ it is assumed the above question refers to Section 7.5 ‘The Building Model’, which defines the physical characteristics of the building to be measured and the purpose for which this information is needed. If so, then the requirements of EN 15978 certainly appear adequate. It is assumed and would be expected though that when physical characteristic of different elements are described they will be comprehensive and complete. For instance for concrete frame elements that all steel reinforcement is included (or steel permanent formwork if used), or for brick or block work elements the binding mortar is included. Feedback: 'Whole Building' needs a definition included in the document not just a reference to an ISO standard- these cost typically hundreds of $ each and the cost impost on the industry of just referring to standards is substantial. I also support the concept of using a conceptual QS 'Bill of Quantities' approach although the level of detail of these can be very variable - I would recommend qualifying it by requiring whatever is included in the building assessment must also be included in the base case and specifying the sections as a minimum that must be included. Feedback: We agree with proposed scope definition. Feedback: The use of whole of building is supported by the Australian Window Association however we note that this should explicitly cover whole of building, whole of life, Cradle to Grave assessment. We would recommend the use of the draft National Standard 110000: Labelling and declaration of environmental attributes of building products General requirements “Whole of life” is defined as “A temporal boundary of the product or service LCA, that accounts for the harvest/extraction, manufacture, transport, construction, demolition, reuse, reprocess, remanufacture, recycle and end-of-life of a building product, and for the building industry, where appropriate, accounts for their effect on the in-service performance of the buildings or structures that use them.” Feedback: The EN 15978 definition of whole building, while comprehensive is considered far too onerous, particularly for the introduction of a credit which is still in its infancy. Lend Lease would advocate for an approach which is guided by and follows the general principles of this standard however is more pragmatic and simpler in its application. Based on experience, we disagree with the assertion that increasing the scope to account for all material inputs to a building does not significantly increase the assessment effort. It stands to reason that the greater number of building components and elements that are included in the model will increase the effort required to both quantify and calculate their respective impacts. Lend Lease would strongly suggest an approach that targets the: 24

Life Cycle Assessment in Green Star Stakeholder Feedback Report



Largest key impact materials / elements of any building; and



Building materials / elements where there is the greatest ability and least friction to positively influence specification and design decisions.

Lend Lease believes it is appropriate to start small with a limited scope with a plan to slowly introduce more materials / building elements over time. In this way the GBCA are likely to have greater credit uptake, reduce complexity and potentially deliver more significant environmental benefits within our industry. We suggest that the following materials / elements be considered for initial inclusion in the credit: 

Substructure;

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Superstructure;

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Façade (cladding and windows);

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Internal walls;

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Floors including floor finishes; and



Ceilings (suspended and set ceilings).

Our reasons for initially limiting assessment to these areas are that they: 

Often represent close to or more than 80% of a building’s impact;



Are relatively easy and cost effective to quantify and benchmark;

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Are typically large works packages undertaken by a limited number of subcontractors (This simplifies and increases the level of influence and engagement needed to deliver improved environmental outcomes);



Are significant in quantity and cost, allowing for greater sustainability priority / leverage during procurement and tendering processes; and



Comprise of fewer subassemblies and components and typically have less complex supply chains and sourcing arrangements. This makes it more likely to deliver improved sustainability outcomes as projects can negotiate with a single supplier rather than needing to engage numerous and often disparate suppliers.

We recognise that other building components such as mechanical, electrical, fire and ICT services when combined can also have a significant impact. These are however challenging for a number of reasons as they are typically comprised of multiple work packages split between a range of supply and place subcontracts, making it particularly time consuming to influence or challenge the specification of these materials. For example: A HVAC system will often comprise of separate suppliers for fans, chillers, pipes, heat exchangers, ducts, insulation, cooling towers, air handling units, diffusers, grills, switchboards, chilled beams etc. While as a system these impacts maybe worth

Life Cycle Assessment in Green Star Stakeholder Feedback Report

quantifying, in practice it is significantly harder to influence any meaningful environmental benefit across this myriad of components and suppliers. In summary, Lend Lease believes there is merit in first addressing those significant areas where there is the greatest opportunity to influence and deliver tangible environmental improvements. Including all building elements, while admirable, in our opinion will simply add cost without much environmental benefit and at the expense of focusing efforts on the major opportunities for improvement. Feedback: eTools position is that whole of building, whole of life LCA is essential for ensuring no perverse outcomes arise from decisions made based on the LCA study. EN15978 is the international standard for measuring the environmental sustainability of buildings. It is certainly the most appropriate choice. eTool believe the scope of EN15978 is somewhat curtailed in regards to operational energy consumption as it only considers: 

Heating



Domestic hot water supply



Air conditioning



Ventilation



Lighting



Auxiliary energy for pumps, control and automation

Notable exclusions include: 

Vertical transport

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Plug loads (such as office work stations)



Servers



UPS systems

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Miscellaneous energy

The scope set by EN15978 is consistent with European attitudes regarding building related energy use and follows from EN15603. European designers will often name a building as zero energy‟ or zero carbon‟ if it produces enough renewable onsite energy to deal with the items addressed in EN15978. This is likely drawn from a policy standpoint, where regulations are targeted at specific areas of the economy. For example, architects and engineers need to improve building energy use, and computer manufacturers need to improve computer efficiency. While this is a very intuitive approach, it fails to address the key role that property developers play in influencing all areas of energy use. For example: 

Fitting out buildings with high efficiency appliances (particularly easy to implement in residential developments). 26

Life Cycle Assessment in Green Star Stakeholder Feedback Report



Integrated fit-outs of office buildings with high efficiency equipment (in partnership



Tenancy agreements that stipulate energy consumption limits per occupant hour.



Highly visible energy monitoring displays to reward tenants with the lowest power use, and online dashboards to educate all tenants where they stand versus average and good performance.

Similarly, building designers can subtly influence the exclusions listed above. Some examples include: 

Providing viable and convenient alternatives to mechanical vertical transport for able-bodied occupants.



Intelligent UPS systems that do not contribute significant heat loads to the building and don't rely on continual electricity supply for top-up charging (e.g. standby generators with assisted flywheels for cut in delays).



Wiring design that aids night-time and weekend shutdown of non-critical circuits.

For the reasons mentioned above, eTool will continue to report on true whole of building energy consumption: all energy that is consumed within the building envelope. For EN15978 compliant reports we will curtail our normal scope in order that we comply with the standard. eTool will also lobby CEN to include voluntary modules of other energy use (“non-building related”). If the GBCA wanted to increase the scope to true whole of building whole of life it would be quite a straightforward clarification to state EN15978 in addition to other building energy use. The term ‘whole-of-building’ is not used in EN 15978. ‘Whole life cycle’ would be the appropriate term if you refer to EN 15978. Also when defining the system boundary it would be recommendable to follow the modularity principle (EN 15978 Section 7.3). This would increase comparability of lifecycle stages between studies. Feedback: In general, we consider the EN 15978 definition of ‘whole-of-building’ appropriate. However, we do expect differences in interpretation of this definition. In practice, project teams might have to stray from the generic definition of system boundaries due to constraints in resources and data limitations. This can be acceptable if appropriately justified. Especially since aspects of the building life cycle will be completed using scenarios rather than actual data. The issue of system boundaries can be further clarified in the next update of the credit based on the evaluation of the innovation challenge. Feedback: In general, we consider the EN 15978 definition of ‘whole-of-building’ appropriate. However, we expect differences in interpretation of this definition. In practice, project teams might have to stray from the generic definition of system boundaries due to constraints in resources and data availability. This can be acceptable if appropriately justified. Especially since aspects of the building life cycle will be completed using scenarios rather than actual data. The issue of system boundaries can be further clarified in the next update of the credit based on the evaluation of the innovation challenge. Feedback: BPIC has always supported a ‘whole of life, whole of building’ approach to life cycle assessment. Therefore we support Green Star using "Whole-of-building, Whole-of-life, Cradle-to-grave, Benchmarked Life Cycle Assessments” that include all phases of the building product cycle, including raw materials, manufacture, transport, construction, operational effect and reuse. In other words, the both embodied characteristics and operational characteristics are included in the considerations. The draft National Standard 11000: Labelling and declaration of environmental attributes of building products—General requirements “Whole of life” is defined as “A temporal boundary of the product or service LCA, that accounts for the harvest/extraction, manufacture, transport, construction, demolition, reuse, reprocess, remanufacture, recycle and end-of-life of a building product, and for the building industry, where appropriate, accounts for their effect on the in-service performance of the buildings or structures that use them.”

Life Cycle Assessment in Green Star Stakeholder Feedback Report

GBCA Response The intention of the definition was in the context of the entire standard. We have clarified this within the credit language. The EN 15978 scope does encompass the complete and constructed element so that mortar, reinforcing steel and other components of assembled elements are included. The EN 15978 standard provides a very similar scope to the cradle-to-grave assessment in the draft National Standard 110000: Labelling and declaration of environmental attributes of building products - General requirements. Referencing duplicate information does not aid the interpretation of the credit for users and referring to one standard, EN 15978, greatly simplifies the use of the credit. The scope of inclusions and exclusions as per EN 15978 does allow some flexibility by describing cut-offs. In LCA in general the LCA practitioner is able to report on the accuracy of the result taking into account some limitations, including difficulty in material quantification within assemblies such as HVAC. As long as these assumptions do not influence the outcome to a great extent, and this is justified by the practitioner and agreed by the peer reviewer, this outcome is valid. The perception that whole-of-building includes 100% of material flows is wrong, EN 15978 takes into account the difficulty in reaching this level of material quantification. In the Life Cycle Assessment in Green Star Discussion Paper One we proposed a limited scope, however this proposal was unpopular with stakeholders. Concern was raised that limiting the scope is contrary to the basic foundations of LCA, as limiting the scope could result in misleading outcomes which are out of context. LCA practitioners and tool providers will build capacity to undertake LCA in compliance with the credit, with time we expect many of the difficulties, including those detailed here, will be better understood and streamlined. We understand there are limitations to EN 15978, at this stage we do not wish to expand on the scope of this standard as capacity to undertake assessment using this standard is still limited in Australia. In future the credit may expand the scope to address exclusions in EN 15978.

System Boundary Is EN15978 an appropriate reference for building life cycle stages and scenarios?

Feedback: Including assumptions about operational impacts results in double counting, particularly in recycling, this is contrary to ISO 14040 and 14044. The credit scope should be limited to cradle to grave. This will also reduce the cost and could serve as the first step for the credit before changes are made and scope expanded to end-of-life. Feedback: EN15978 includes operational energy and water, and in my experience this is a vital inclusion, because an embodied only assessment promotes the wrong decisions for example: Double-glazed windows, insulation and appropriately placed shading add to the embodied impacts but may save many times their additional embodied impacts from savings in operational energy in cooled and heated buildings. 28

Life Cycle Assessment in Green Star Stakeholder Feedback Report

Additional floor and wall thicknesses embody more materials, but may increase thermal mass and in climates with large diurnal temperature change may again save operational energy Solar PV and water systems embody more materials impacts, but save on grid supplied energy Water harvesting and storage systems embody more materials but save on reticulated water impacts and infrastructure The LCA based credits for which we are commenting here are limited to materials impacts only (because energy, renewable energy and water saving are addressed by other Green Star credits). This may be appropriate for the overall rating of a building, but enroute it will be very hard for design teams to see and understand these tradeoffs. The ENVEST® design tool does reveal tradeoffs to the design team as they make every decision. Design teams that are not using a tool like ENVEST® may be encouraged in their quest for credits within just the materials section, to inadvertently make the wrong trade-off decisions. GBCA also need to be careful to ensure that the balance of credits between materials and energy performance does not inadvertently reward the wrong trade-off. This will be a complex evaluation because it will vary greatly with climate zone. Feedback: EN 15978 includes consideration of both operational and embodied energy. It is important that the analysis of a building over its life cycle include the effects of building materials in manufacture, construction, the lifetime of performance, and the end-oflife. All of these stages, when considered as a whole, can identify superior scenarios in building material choice. Feedback: I believe that scenarios for life cycle assessment must be strongly considered for the Australian market before any decision can be made regarding their application. It is also important that the analysis of any building cover operational, embodied, and end-of-life stages of the life cycle. Feedback: Yes, this is generally appropriate however we would suggest a more practical approach to the inclusion of life cycle stages as part of the assessment. For example, we would encourage the GBCA to focus primarily on the following life cycle stages: 

Product stage A 1-3;



Construction Stage A 4-5; and



End of Life Stage C 1-4.

Adopting an assessment of these life cycle stages would reduce the assessment burden for projects while avoiding duplication and overlap with the objectives for the GBCAs energy and water credits and other typical construction industry practices. We believe that there is limited benefit in including the following aspects of the use stage, as defined by EN15987, for the following reasons: 

Use Stage impacts (B6 and B7) are already accounted for as part of the energy and water credits within Green Star, NABERs as well as Section J BCA requirements;



Use Stage impacts (B1) have limited available data and are particularly onerous to quantify. We note that other approaches would be more effective at driving reductions for these impacts e.g. Red Stick lists;

Life Cycle Assessment in Green Star Stakeholder Feedback Report



Use Stage impacts (B2-B4) covering Maintenance, Repair and Replacement stages are typically dictated by a myriad of fit for purpose and aesthetic considerations as part of the building design and materials specification process. Lend Lease believes that quantification of these impacts is very unlikely to alter material selection outcomes and will simply add cost and complexity to the modelling exercise without delivering any tangible environmental benefits to projects.



Use Stage (B5) Refurbishment is a largely speculative exercise for new build projects. It is unclear as to the benefit of including this stage in the assessment particularly when client brief, aesthetic, perceived market value, building lessee tenure, economic incentive / disincentive, available capital, geography and local building demand can all drive the churn and refurbishment cycle of a building. In our opinion, whether or not this requirement is included in the LCA model will not necessarily change the environmental impact / outcome.

We would suggest that improved refurbishment outcomes would be better driven via existing Commitment to Performance Management Credits which address improvements to “Make Good” provisions and Green Leasing. Feedback: Yes, life cycle stages (green bullet point pg. 8) should be updated to be in line with EN 15978. Feedback: We agree that EN15978 (and EN15804) are appropriate references for building life cycle stages and scenarios. The life cycle stages are clearly delineated in the European Standard. Feedback: EN 15978 is certainly supported as an appropriate reference. Aligning with and leveraging off the European Committee for Standardization (CEN) working group on Sustainability of Construction works is a sound approach; there has been much work and detailed consideration undertaken through this process as to how LCA of buildings should be best implemented. In terms of EN 15978 as a specific reference for building life cycle stages and scenarios as set out in Sections 7 & 8, this is also supported. EN 15978 quite logically and clearly sets out and delineates the separate life cycle stages and their boundaries. Feedback: We agree that EN15978 (and EN15804) are appropriate references for building life cycle stages and scenarios. Typically, there is limited information available on scenarios for maintenance and repair, and these will likely vary between assessments. This flexibility might lead to tweaking of scenarios to achieve desired LCA outcomes, rather than to achieve lower environmental impacts. The BP LCI project developed some guidance and a database of resources for incorporating operation and maintenance in whole building LCAs. We would recommend to further this work and to develop a set of default maintenance and repair factors. Feedback: There is potentially room for misinterpretation regarding the system boundary. The GBCA has defined the scope as: Cradle to grave as defined in EN 15978 including all life cycle stages and scenarios detailed. EN15978 has four main life cycle modules. Note the description relating to Module D: A: Materials Production and Construction B: Use and Maintenance C: Demolition and Disposal D: Benefits and Loads Beyond the System Boundary

Life Cycle Assessment in Green Star Stakeholder Feedback Report

It could be interpreted that module D is outside the system boundary for the Green Star Materials Life Cycle Impacts credits. However, this would be inconsistent with a compliant EN15978 LCA, which must report module D. There are very good reasons for including Module D, which likely drive the intent of CEN TC 350 in making reporting of module D compulsory when the standard was written. The following are some examples of why module D is important: 

Permanent materials such as steel, copper and aluminium that are subject to high rates of closed loop recycling should be recognised at end-of-life not just start of life.



Without including Module D there's a risk that recycled content in module A will be over-rewarded in the assessment.



Export of renewable generation is something that should be recognised as a very tangible benefit to the environment in carbon intensive grids, particularly while the grids are not renewables-saturated (at which time it is highly likely that buildings will be required by utilities to export less via the use of generation management technologies so there is very low risk of renewable oversupply into Australian electricity grids).



Diverting waste timber from landfill could be rewarded (for recycling or energy) and should be encouraged (if only highlighted in sensitivity analysis until such time that mature markets develop for this industry).

Our project team is not yet aware of the implications of module D in the Green Star projects we are working on. Regardless of implications, we strongly recommend that Module D is included and no ambiguity remains surrounding this point. We recommend adjusting the description of system boundary to: Cradle to grave as defined in EN 15978 including all life cycle stages and scenarios detailed (including Module D). Equipment, consumables and labour associated with materials replacement should be accounted for. This is quite clearly stated in EN15804 Feedback: We agree with proposed system boundaries.

GBCA Response The 'Materials Life Cycle Impacts' credit references EN 15978 for life cycle stages and scenarios. The credit does not limit the inclusion of operational energy. Because embodied water is an underdeveloped impact category in LCA that requires some work before agreed models are developed, the credit does not address this impact. Therefore at this time the Potable Water credit is currently sufficient in addressing operational water use. Inclusion of both embodied energy and operational energy in the credit means the trade-offs are evaluated as part of the LCA, not in isolation within the 'Materials life Cycle Impacts' credit and other Green Star credits. In the Life Cycle Assessment in Green Star Discussion Paper 1 the GBCA proposed to limit the scope in the initial implementation of LCA based credits, this proposal was unpopular with stakeholders and as such cannot be implemented. There however is very strong stakeholder support for a boundary of cradle-to-grave. EN 15978 includes some guidance regarding concern of double counting, if this is followed and assumptions justified, ISO 14040 and 14044 would not be

Life Cycle Assessment in Green Star Stakeholder Feedback Report

contravened. It is not clear how life cycle scenarios and stages of a building in Europe are different to a building in Australia. The actual LCA conducted by project will be Australian specific and specific to the site on which the project is constructed, EN 15978 is the guide to be followed when conducting the LCA. EN 15978 can be applied internationally despite it being developed in Europe. We welcome the endorsement of this standard in Australia so that it is issued as an Australian Standard and therefore more accessible in Australia. Maintenance, repair, replacement and refurbishment activities can result in many impacts when considered at a whole-oflife perspective. Not accounting for these impacts will create trade-offs outside the control of the GBCA or Green Star project teams. Therefore An LCA not taking these into accounts cannot be used as part of a Green Star rating. It is acknowledged that accounting for in-use impacts within an LCA is not sufficiently developed or understood, we also acknowledge repair works are entirely speculative as repair depends on many unforseen events. It is however possible to account for the majority of replacement and maintenance by using information produced by suppliers that details the expected lifespan of the materials and any maintained intervals required to maintain the function or aesthetics of the product, if this is the best assessment we can conduct, it is still worthwhile. Appropriate justification for any maintenance, repair and replacement impact not considered, and the likely influence this omission may have on the outcome, should satisfy any peer reviewer. With time and as the 'Materials Life Cycle Impacts' credit is used the GBCA will collate LCA reports and evaluate the detail of these with respect to many aspects, including how maintenance, repair and replacement activities are accounted for and the data used. The GBCA will continuously consider how further guidance can be provided. The use of the Green Star Performance rating tool will also with time provide useful data on maintenance, replacement and refurbishment activities in a variety of buildings. The intent of the credit is that all modules, including D, are included and this has been clarified as suggested.

Do you see a need to determine further rules on maintenance and repair beyond EN 15978? Feedback: Maintenance and repair conditions should bee considered specific to the Australian environment. Reference to a European standard may cause adverse outcomes unless the environmental conditions are specifically tailored to the Australian Market. Feedback: EN15978 adopts an all-encompassing definition of maintenance which therefore includes (as it should) cleaning. For floor finishes in particular, this is a very important aspect that too often gets ignored but can be very significant. For example, compare a resilient floor covering that needs weekly washing compared to a carpet that needs vacuum cleaning. The cleaning impacts can overtake the embodied impacts at installation sometimes quite quickly, so this factor should not be ignored (especially when tenancy and base-building responsibilities are now being assessed under a single combined Green Star rating system). I think that greater clarity is needed from GBCA on this aspect.

Life Cycle Assessment in Green Star Stakeholder Feedback Report

Pedantically speaking (although the EN15978 definitions disagree), in other places repair is distinguished from maintenance because it is due to an unplanned failure rather than a scheduled or planned for activity. As a result, repair is usually not included in LCA assessments, whereas maintenance and cleaning are. Feedback: For materials and building products, the largest factor that will influence this area is the service life of the products. For the LCAs eTool is conducting at present, early results suggest that recurring impacts (Modules B2 – B5) are less than 5% of the total impact of the building. Therefore the impact of “gaming” by adjusting services lives of individual building elements will be relatively small compared to some other elements of the building but should be addressed. Given that the Green Star credit is a comparative measure, an additional rule that stated: “If service lives of like products in the buildings being assessed and compared vary, this must be justified by either: 

Communication of warranty periods that reflect the relative difference in predicted service lives.



Service life calculations compliant with EN15804 Annex A”.

Equipment, consumables and labour associated with materials replacement should be accounted for. This is quite clearly stated in EN15804. Feedback: Scenarios for maintenance and repair are likely to vary between assessments. This variation is unavoidable and should be in line with building management expectations. On the other hand, flexibility might lead to tweaking of scenarios to achieve desired LCA outcomes, rather than to achieve lower environmental impacts. This trade-off will likely have to be limited by setting up default scenarios for key parameters. Feedback: Repair and maintenance are, to a certain extent, addressed in EN 15978. However, given the extended building lifespans for those structures under review, regular tasks should also be addressed as the cumulative effects in terms of water and chemical use may be substantial. Feedback: EN 15978 identifies maintenance and repair as important ‘use’ stages and identifies (section 8.3.1) that these scenarios need to be described taking into account a number of defined factors. It may be useful for GBCA to have the relevant sectors nominate and provide appropriate maintenance and repair schedules, and the rationale for these, for key common elements/ activities to ensure consistency between project assessments.

GBCA Response: Proposals for a more simplified scope for the LCA was discussed in the Life Cycle Assessment in Green Star Discussion Paper One. This proposal was not popular with stakeholders. Maintenance repair, replacement and refurbishment can result in high impact when considered at a whole-of-life perspective. Not accounting for these impacts will create trade-offs outside the control of the GBCA or Green Star project teams. Therefore an LCA not taking these into account cannot be used as part of a Green Star rating. It is acknowledged that accounting for these within an LCA is not sufficiently developed or understood, we also acknowledge repair works are entirely speculative as repair depends on many unforeseen events. It is however possible to account for the majority of replacement and maintenance, by using information produced by suppliers, that details the expected lifespan of the materials and the maintenance intervals required to preserve the function or aesthetics of the product. If this is the best assessment that can be conducted, it is still worthwhile. Appropriate justification for any maintenance, repair and replacement impact not considered, and the likely influence this omission may have on the outcome, should satisfy any 33

Life Cycle Assessment in Green Star Stakeholder Feedback Report

peer reviewer. The credit does not limit the sources that the LCA practitioner can use for guidance on repair and replacement. The Building Code of Australia (BCA) also has durability requirements for certain building elements that should be considered. We encourage building product and material suppliers and manufacturers to improve and/or provide the maintenance and replacement information for their products. The GBCA will be paying close attentions to LCA reports submitted by Green Star project teams, if a wide interpretation of maintenance and replacement is occurring we will consider means to reduce this.

Question: Is a 60-year lifespan for building an appropriate default lifespan? If not, what alternative would you suggest? Feedback: On average buildings last nearer to 100 years, but when assessing life cycle performance, since the operational (annual) impacts usually predominate, the difference in annualised life cycle performance assessed over 60 or 100 years will probably not be great. 60 years seems a more practical period. Feedback: Is there a need to be a different time span depending on the type of building? Should a minimum life span for assessment be mandated to demonstrate the sustainability of the built form? e.g. choosing less-resilient material may have less initial impacts but may not have long life and be less sustainable overall. Feedback: While a 60 year lifespan is appropriate we feel that commonly held view of the building industry is that the life span for an average building is 50 years. Feedback: For the purpose of modelling the use / operational stage of a building we agree that this is appropriate. Feedback: We support the use of a ‘whole-of-life’ system boundary for the LCA being undertaken for the ‘Materials Life Cycle Impacts’ credit. Feedback: The design life of a building should be aligned with the Building Code of Australia, this is typically 50 years. For monumental buildings it is 100 years, perhaps points should be awarded for buildings that are designed for 100 years of service. The Building Code of Australia (BCA) also has durability requirements for certain building elements which should also be considered. Feedback: We agree with the selection of a 60-year life span as an appropriate default although it can dramatically influence the outcome of the LCA results. However, should the project team provide an alternative design life, it should provide substantial quantitative evidence in support. Feedback: Our work here so far is erring towards a 60 year life. It is important to recognise that a building lifetime is not like a human lifetime. The defined building lifetime e.g. 60 years, is the point where half of the buildings that are (or would be) that age still exist. Feedback: The reference service life (RSL) of a building could as well be defined in line with ISO 15686 Buildings and construction assets –Service life planning. 34

Life Cycle Assessment in Green Star Stakeholder Feedback Report

Other rating tools have chosen 50 years. It would be good to align with those, e.g. LEED. Feedback: We consider building professionals (e.g. developers, designers, architects) are best placed to comment on the most appropriate building lifespan. We do agree with the current approach to let the project team define the building lifespan in line with the overall design requirements. Only if these are not specified the project team has to use the default lifespan as defined by the GBCA. We also believe that project teams should be able to diverge from the default with appropriate justification. Feedback: This lifespan is considered appropriate for most large buildings as the design life of these structures tends to be in the realm of 50 years. Feedback: It is suggested that the designers of a particular building would be best suited to advise on the expected life of that building which may be based on and affected by its function. A proposed 60 year lifespan may be appropriate as a default but an actual design lifespan should be preferred. Interestingly, though it was based on residential dwellings, an FWPA research project undertaken by Kapambwe (2009) found that on average, the Australian residential dwelling lifespan was estimated to be 61 years (SD=20.5). Feedback: The 60-year lifespan is appropriate and within the range of established market research. It is arguably an appropriate time-scale to highlight trade-offs between embodied and operational impacts.

GBCA Response The credit allows for project to define the service life of the building, where this is not defined for the project the default service life is applied. Where the project chooses a different service life to the default, the LCA report will include a clear justification for the lifespan choice. In the case of fitout works only, the project team will need to define and justify the service life on the basis of accepted churn rates for the type, use and location of the project.. All justifications for service life selection outside of the default are subject to peer review.

Functional Unit Any aspect of the functional unit adopted. Feedback: Many commercial buildings are mixed use, so as the different versions of Green Star are merged it is going to be challenging to reconcile data that is based on different area metrics. Accordingly, I would recommend universal use of Gross Floor Area for Commercial buildings. The functional unit needs to be expressed per year of life. Feedback: We agree with the proposed functional unit. Feedback: We support the use of one metre square of functional unit such as Gross Floor Area and Nett Leasable Area. It is however suggested that the measurement be defined further as per Draft NS S 12000.2, which refines this unit further, by requiring the reported values to be expressed as “% change in impact [from the corresponding value for the benchmark building]”. This is then independent of the units of measurement; and can be used to compare the impacts of any building component to any other component. It is recommended that if the expression of impacts is per square metre of GFA then it should be required that assessments also report “% change in impact from the corresponding value for the benchmark building”. 35

Life Cycle Assessment in Green Star Stakeholder Feedback Report

Feedback: We agree that this is appropriate. Feedback: Assuming the occupation rates and hours of the compared buildings are alike, the functional units are acceptable. eTool supports the choice of a functional unit that focuses on the core function of the building. Some considerations for the existing functional units are discussed below. Office Buildings Floor space is generally a good indicator of functionality in commercial space. However, there are some complexities. If an actual reference case is chosen that has low occupancy during the operational energy measurement period then the actual energy consumption figures should be adjusted to reflect the same occupancy rate used to model the Green Star project being assessed. If an actual reference case is chosen that has very long hours of occupancy, e.g. an office building with a 24 hour call centre, these figures should be adjusted down to be comparable with a building of 10 hours occupancy per day. The formulas for adjusting these figures could be derived from empirical data and theoretical means. eTool has made such adjustments to operational energy estimates of office spaces to show clients the likely difference in energy consumption for different rates and hours of occupancy. The challenges in deriving these formulas lie in the fact the two main determinants of overall energy use have multiple variables: 

Lighting will increase proportionally to both daylight levels and occupancy hours.



HVAC will increase due to:



occupancy hours due to increased internal heat loads and required air transfer rates



ambient temperature rise due to drop in chiller efficiency

While one may be able to make reasonable assumptions about how these may affect overall energy consumption, modelling should be conducted to draw some accurate conclusions, which could be quite arduous depending on available documentation. One method of overcoming these challenges is to change the functional unit to occupant-hour, e.g. impact per occupant hour. Multi-unit Residential In the case of residential, we would recommend an alternative approach to functional unit. The shortfall for GDA does not consider the core function of the building: 

provision of a dwelling for occupants



provision of this dwelling for a period of time

The use of GDA does not recognise two critical elements to the core function of a residential development.

Life Cycle Assessment in Green Star Stakeholder Feedback Report

The first flaw in the GDA approach is that floor area does not correlate well with occupancy. Number of bedrooms is a far better measure. eTool currently uses a regression analysis on ABS census statistics to estimate residential occupancy based on number of bedrooms and the density of the suburb (there was poor correlation with the type of dwelling). This provides a repeatable calculation to estimate occupancy. Failing to recognise the disparity between occupancy and GDA ignores the 40 year trend in Australian dwellings becoming larger with less people living in them, and therefore less sustainable. This trend has recently reversed, but further encouragement is needed to ensure occupancy is a focus in design. The second flaw is that the service life of buildings will significantly affect its sustainability (environmental sustainability through use of raw materials, social sustainability through nuisance of reconstruction and economic sustainability through large expense of reconstruction). All else being equal, a building with half the design life of another building will have double the materials impact on a per year basis. Measures to increase design life must be a consideration for sustainable design and therefore highlighted in relative assessments of buildings. eTool‟s recommendation for residential functional unit is occupant / year (impact / occupant / year). Feedback: I would envisage that most results will be calculated on a m2 floor area (net)/year basis so that point sources of impacts from construction and repair, for example, are expressed across the life of the building. What is meant by project area? If this is a building with some landscaping outside, does it include the landscaping or just the building? Feedback: The current functional unit provides options for quantifying the floor area according to different types of use. The service life is mentioned separately and could be considered part of the functional unit. The functional unit description could be further improved by adding in a description of the function of the building (regulatory or client specifications) and a pattern of use. ALCAS suggests aligning the functional unit with EN15978. Feedback: We previously indicated support for the one square metre functional unit. For assessing the impact of particular products within any standard building, we suggested both Gross Floor Area and Nett Leasable Area be used based on the type of proposal. Draft NS 12000.2, refines this unit further, by requiring the reported values to be expressed as “% change in impact [from the corresponding value for the benchmark building]”. This is then independent of the units of measurement; and can be used to compare the impacts of any building component to any other component. It is recommended that if the expression of impacts is per square metre of GFA then it should be required that assessments also report “% change in impact [from the corresponding value for the benchmark building]”. Feedback: The functional unit “one square metre of project area consistent over the life of the project (GDA, GFA, GLAR or GLA) as relevant to the rating tool under which the project is registered” is supported. It is agreed that this will help to ensure a variety of building types are accommodated and that the data collated can be categorised by building type if required. The collation of data at different units will provide data to the GBCA, this data could be the basis for reconsidering the appropriate functional unit for the credit. There seems to be some consensus on the use of the relevant floor area as required in the credit Feedback: The discussions with Edge Environment suggest that in the case of pipe at least the simplification to just 4 LCA categories will have minimal impact in terms of the comparative performance of the common pipe materials. However this comparison was based on the functional unit relevant to pipe of per m of length. At this point we remain unconvinced that the blanket functional unit of per m2 of floor area is suitable for products such as pipe, ducting and cable. We continue to recommend the use of functional units that are representative of the products being compared and whilst per m2 may be suitable for many of the

Life Cycle Assessment in Green Star Stakeholder Feedback Report

bulk construction materials and finishes the use of this functional unit for linear products such as pipe may distort the outcome or not provide the correct incentive in the LCA context to favour better material options.

GBCA response The reference case functional unit outlined in the credit now also includes a requirement to document the result in 'Gross Floor Area' and 'Occupancy Pattern'. A standard submission template has been developed and includes requirements for this reporting. The building specific functional unit requirements remain within the credit requirements and are the basis for displaying the outcomes and calculating the results. In relation to residential buildings, Green Star only addresses multi-unit developments (two units or more) so that issues with single-family home residential developments will not arise. Nonetheless the credit functional unit requirements also include requirements to present the results in occupancy patterns. The LCA-based credit, and Green Star rating tools in general, focuses on the entire building or fitout project, not the individual materials making up the building. As such the amount of piping, for example in a meter square basis, may not constitute a large percentage of building materials flow and would most likely be a small contribution to repair, maintenance and refurbishment impacts.

Impact Categories Is it clear why the four impacts of climate change, mineral fuel and fossil fuel depletion (abiotic depletion), eutrophication and human toxicity have been selected for the first iteration of the â&#x20AC;&#x2DC;Material and Life Cycle Impactsâ&#x20AC;&#x2122; credit? Feedback: This is not on the list of standard categories that must be included in EN 15978 (ref page 43) EN 15978 includes additionally - Ozone depletion potential, acidification, photochemical ozone creation potential. Ionizing Radiation is important add to the list of required impacts in an Australian built environment context. There has been cultural and political opposition to the use of nuclear power in Australia and the decision of the country to not have this option could disadvantage Australian products if the Ionizing impact category is not taken into account compared with a reliance on Global Warming impacts which are decreased when nuclear power is used. With regards to water, the Green Star Water category does not recognise water intensive materials. With regards to respiratory impacts, the human health indicator does not cover particulate matter which may not be toxic but can still harm people. e.g. asbestos and other dusts. With regards to Ozone depletion the Green Star credits do not cover materials manufacturing. The proposed impacts are a start but the impacts in manufacture of materials need to be considered, this is the key point of conducting an LCA as noted above - e.g. ODP in the manufacture of a product Compliance with the referenced standards requires additional categories.

Life Cycle Assessment in Green Star Stakeholder Feedback Report

Feedback: I do not believe that it is clear why four Impact Categories have been defined. It is suggested that you reference the BPIC weightings and survey that has been conducted. This is the most up-to date, comprehensive survey undertaken of the Australian Market to this point. Feedback: Yes, however the GBCA should consider possible misalignment of these with the Product Category Rules that govern the type of impact category results published in EPDs. For example, not all EPDs will provide human toxicity impact data in daily adjusted life years (DALY). This means that the ability for the market to easily evaluate a product against all of the four impact categories would be limited. Furthermore, if the GBCA is looking to align their approach with EN 15978 then the suggested impact categories are inconsistent. Feedback: In order to be compliant with the standards referenced in the Materials Life Cycle Impacts Credit, there is a lost opportunity for Green Star rating tool to also include the impact categories recognised under these standards in their own right. Also, it appears insufficient to suggest some impact categories are covered in other Green Star rating tools when they are not cradle-tograve in scope. On the other hand a category such as ‘human toxicity’ is included which is not a mandatory requirement for EPDs. Feedback: Yes and the approach is sound. Feedback: It is not clear why human toxicity has been selected. This impact category is not part of EN 15804. We strongly recommend staying within the impact assessment methods included within Section 6.5 of EN 15804 (see as well our comment on the previous Version). Reasons for including additional aspects to the already comprehensive EN 15804 and EN 15978 should be well justified. Abiotic depletion should be split up into fossil fuels and elements. Acidification could be included. The wording around climate change and global warming needs to be adjusted. Climate change is caused by global warming, they are not synonymous expressions. The term carbon footprint and global warming are not synonymous either. Feedback: We understand that there is conflicting information and views regarding appropriateness of impact categories. When considering uncertainty in impact assessment, international agreement on methodologies and appropriateness of environmental effect models for Australian circumstances, there is only a very limited set of indicators that would meet strict requirements. Nonetheless, many indicators are used in LCA studies to examine potential problem areas within the life cycle of a particular product. We also understand the difficulty in finding a broad range of well developed, relevant impact categories for Australia. However, the rationale behind the current selection of indicators is somewhat lost on us. The statement in the discussion paper that “The selection of a limited number of impact categories also aligns with the recommendations in Grant and Peters (2008)” could potentially be taken out of context. We would like to stress that the best practice guide (Grant and Peters (2008)) does not recommend the use of the four indicators chosen by the GBCA, or a particular limited number of impact categories. The best practice guide does provide guidance on the status of impact assessment categories for the Australian context, and from there we understand one can conclude that a limited number of indicators are appropriate for a specific purpose.

Life Cycle Assessment in Green Star Stakeholder Feedback Report

Note that due to the current state of indicators related to water use and biodiversity (or land use as a proxy) and their omission from the default set of indicators, a bias toward favouring renewable materials may be introduced. That being said, the current selection is an acceptable starting point. Please note there are some factual errors in the description of the status of impact categories: 

Human toxicity is generally considered as having high uncertainty. The inherent difficulty in linking an emission of a substance to a health effect (using fate models) would in some views mean that this indicator is less well developed. This is one of the reasons why it was not adopted in the EN15804 standard.



Eco-toxicity has similar difficulties as human toxicity. Therefore it is incorrect to state that human toxicity is well developed, while stating that for eco-toxicity an agreed characterisation method is yet to be developed.



Similarly, there is an agreed characterisation method for acidification (in Europe), although the actual environmental effect is different in Australia. It would be correct to say that the currently available characterisation method for acidification has limited relevance for Australia.

Feedback: The choice and use of the four impact assessment categories of: climate change, mineral fuel and fossil fuel depletion (abiotic depletion), eutrophication and human toxicity for the first iteration of the ‘Material and Life Cycle Impacts’ credit is clearly understood and strongly supported. It is agreed that those impact categories not selected are either adequately covered by other Green Star rating tools or require further investigation, development and agreement by the broader LCA professional community. The position of the GBCA not to assign any ‘weightings’ to these impact assessment categories is also seen as appropriate. Feedback: Whilst inclusion of human toxicity as an impact is desirable, practical issues may make it difficult to calculate. The ISO and European standards do not require the calculation and declaration of human toxicity in EPD so where data on products is derived from EPD, this is likely to be a data gap. The calculation of resource depletion for fossil fuels and other materials using kg eq. Sb is not strictly in line with EN15978 which requires that fossil fuel depletion is calculated as MJ (net calorific value) and other resource depletion is calculated as kg eq Sb Feedback: The Paper provides little guidance on why these four impacts have been chosen apart from the comment that they correspond with the primary impact categories for Green Star materials. As part of establishing the BP LCI workshops were conducted nationally which sought feedback on the Australian context and the relative importance of a range of impacts. This work was reported and is available via the BPIC LCI webpage and a copy is attached. The BP LCI weighting research identified the following four impact categories with the highest ratings by stakeholders. 1. Climate Change (Global Warming) 2. Land transformation and Use 3. Marine Aquatic Ecotoxity 4. Freshwater Aquatic Ecotoxity

Life Cycle Assessment in Green Star Stakeholder Feedback Report

These responses are not wholly inconsistent with the GBCA impacts however they are not identical. It is recommended that GBCA review the findings of the BPIC research prior to finalising these impact categories. Feedback: The choice and use of the four impact assessment categories of: climate change, mineral fuel and fossil fuel depletion (abiotic depletion), eutrophication and human toxicity for the first iteration of the ‘Material and Life Cycle Impacts’ credit is clearly understood and strongly supported. It is agreed that those impact categories not selected are either adequately covered by other Green Star rating tools or require further investigation, development and agreement by the broader LCA professional community. The position of the GBCA not to assign any ‘weightings’ to these impact assessment categories is also seen as appropriate. Feedback: It is not clear why the four impacts have been selected for the first iteration. It is our experience is that the majority of time and costs incurred in compiling the LCA for a building lies in estimating materials quantities, lifetimes of components, cleaning and maintenance implications etc. for the scope. Impact assessment is automated within LCA software and limiting impact categories does not lead to any time or cost savings. Leading international midpoint impact assessment methods use a large set of midpoint impact categories, typically between 12 and 18. Limiting impact categories can present the perception of prioritisation or favoritism toward certain impacts. ISO 14044 (section 4.4.2.2.3.c) requires to minimise value-choices and assumptions during the selection of impact categories, category indicators and characterisation models for the LCIA method. To this end the Building Products Life Cycle Inventory (BP LCI) project (jointly funded by the Building Products Innovation Council (BPIC) and AusIndustry) conducted comprehensive research to identify a broad set of environmental impact categories by reviewing and adopting the research and recommendations from International and Australian LCIA methods and best practice guidelines, including: 

a review and evaluation of 27 international and Australian LCIA methods and best practice guidelines in order to identify a broad set of environmental impact category candidates.



the work on LCIA by the International Reference Life Cycle Data System (ILCD) (European Commission, 2010) drawing from from a total of 156 models, of which 91 were short listed as possible candidates for a recommendation within their impact category.



the operational guide to the ISO standards (Guinée et al. 2001)



the Best Practice Guide to Life Cycle Impact Assessment in Australia (Grant & Peters 2009).

For ISO 14044 compliance, the BP LCI did not exclude any environmental impact category based on assumed relevance or importance of the respective impact category. In other words, some may not consider mineral depletion, ionising radiation, photochemical smog or perhaps waste as an issue of concern in Australia for various reasons. The position taken in this work is that such evaluations are best handled in the normalisation and weighting stages of the LCA and should not be disregarded a priori. We recommend the following BP LCI categories or other comprehensive mid-point indicator methods (e.g. ReCiPe or World Impact): 

Global warming.



Abiotic resource depletions (excl. water).



Land transformation and use.



Water resource depletion. 41

Life Cycle Assessment in Green Star Stakeholder Feedback Report



Eutrophication.

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Acidification.



Eco-toxicity.

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Photochemical smog.

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Ozone depletion.



Ionizing radiation.

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Human toxicity.



Particulates and respiratory effects.

The BP LCI recommendations are almost completely aligned in terms of impact category selection with leading LCIA methods and frameworks such as ReCiPe, IMPACT 2002+, World Impact + and a recently published major assessment for the International Reference Life Cycle Data System (ILCD)2. It should be noted that continued coordinated work internationally is needed to accelerate the development of methods required for full LCA. Adaptation of international methods for Australian conditions is required for the majority of the recommended impact categories for the BP LCI. It will ultimately require expert judgment whether the scientific method is sufficiently robust and developed to be used for the full LCA impact assessment. On balance, we recommend to include, rather than exclude impact categories as inclusion can drive further scientific development and refinement. Normalisation and possibly weighting of the individual impact categories are the appropriate approaches to determine which impacts matter, not a priori exclusion or prioritisation. Use of limited impact categories has repeatedly been demonstrated to lead to perverse outcomes and misleading results. Feedback: No it’s not very clear why these particular impact categories are highlighted. The BP LCI weighting surveys conducted in 11 different cities around Australia in 2010-11 found generally good consistency on the impact categories judged of most/least concern to Australian stakeholders. This consensus held between locations/climates, demographic groups (age, sex ,income). In addition these results are in good agreement with similar studies conducted in UK-1997, US - 2000 and NZ – 2007). These would suggest that if 4 impact categories were to be highlighted they should be: Global Warming, Land Transformation and Use, Marine Acquatic Ecotoxicity and Freshwater Acquatic Ecotoxicity, together accounting for 59% of stakeholders environmental concerns. If we group all of the categories that relate to human health then these would replace Freshwater Acquatic Ecotoxicity from the top 4. It has to be acknowledged that the impact assessment models for some of these impact categories are not well developed though.

GBCA Response It was expected that this area of the methodology prescribed by the credit would prove difficult to reach consensus on. It seems that one common suggestion by stakeholders is to align the indicators from EN 15804 and EN 15978 with the required indicators within the 'Materials Life Cycle Impact' credit. Accordingly, the impact categories to be reported are Global Warming, Ozone Depletion Eutrophication, Acidification (land 42

Life Cycle Assessment in Green Star Stakeholder Feedback Report

& water), Tropospheric Ozone Formation and Mineral and Fossil Fuel Depletion (abiotic depletion). This aligns the impact category requirements of the credit with the impact categories required in En 15804 and EN 15978 as well as LEED. We have also retained the Additional Life Cycle Impact Reporting criteria and have suggested the impact categories that may be included. The combination of both sets of criteria will result in reporting on most of the BP LCI categories. The limitations of using non-Australian based data for acidification is understood. However, we have also received feedback from actual submissions undertaking Innovation Challenges, and the inclusion of this indicator did not represent a challenge. Thank you for clarifying the intent of the Grant and Peters 2008 "Best Practice Guidelines for LCA in Australia". Our intent was that this publication does suggest it is acceptable to choose a limited number of indicators, based on the fact that some indicators may be too uncertain at present. Based on this clarification, the resulting impact category selection of the LCA-based credit is not contrary to this publication. A weighting study may not be the most appropriate means to select impact categories. Aligning the impact categories of the LCA-based credit, with those required by EN standards, seems a more appropriate approach especially considering little consensus could be reached on this matter.

Do you agree that the ‘Additional Life Cycle Impact Reporting’ criterion is an appropriate and effective way to facilitate and encourage reporting across other impact categories and build the industry’s understanding of how LCA should be completed in relation to such categories? If not, what alternatives would you suggest? Feedback: Yes I agree that this is important, not least because only one of the Australian stakeholders’ categories of concern is currently addressed and the LCA community needs to be kept under pressure to improve all of the impact assessment methods especially for land transformation and use; water depletion and to fix some of the discrepancies in impact assessment models (especially aquatic eco-toxicity) for Australia. I understand the politically expedient reason for not adopting weighted credits but I don’t agree with it. Although ISO14040/4 has just one rather bizarre sentence prohibiting the use of weighting for comparative assertions made to the public, it has pages of requirements for the correct use of weighting. Moreover it just doesn’t make sense – the one place where you most want your results untainted by individual practitioner bias and judged by broad consensus, is when making comparative assertions disclosed to the public. Repeated surveys have now demonstrated the robustness, repeatability and practicality of weighting (as long as it is done well) for completing the final and unavoidable subjective stage of impact assessment. I believe that GBCA should seriously consider the benefits of weighted impact categories here. Feedback: This could result in multiple, differing, requests on the manufacturers if the developer is allowed to choose the impact categories that suit from a list then the next project pick a differing set.

Feedback: It is agreed that the addition of “additional Life Cycle Impact Reporting” is valuable and will encourage the users to look for further criteria when selecting materials and products however to ensure that these are measured on a fair and comparable basis more information should be provided as to how these additional criteria are dealt with under the scheme.

Life Cycle Assessment in Green Star Stakeholder Feedback Report

Feedback: Yes agreed. However it is likely to provide only incremental improvements in the industry’s understanding of LCA as a whole. Feedback: Yes, the more these indicators are reported on the more thought and discussion will be stimulated to resolve the characterisation methods. Feedback: Additional impact categories should be in line with EN 15804. Feedback: Yes, we agree that it is important that the industry develops a greater understanding of the less common indicators. Given the differing views on impact assessment, the current approach will give project teams the opportunity to demonstrate leadership, without being held to reduction targets (which would be dubious given the uncertainty in impact assessment models and data limitations). Feedback: Additional Life Cycle Impact Reporting is an area where I expect diverging results between projects. There are a large number of impact assessment methodologies available, very few of them are specific to Australian conditions. The currently mandated four categories (climate change, resource depletion, eutrophication, human toxicity) should provide some interesting outcomes when comparing results across Green Star projects, depending on the source of life cycle inventory data. I will start a separate discussion on this matter. ALCAS intends to update its best practice guide on Life Cycle Impact Assessment, but more might be needed. I am interested to see how much we want to align with the impact categories mandated in the EPD standard (EN15804), given that ALCAS has signed an MoU with the International EPD System. Feedback: Based on the above comments and variation between the BPIC findings and the GBCA impacts it would appear appropriate to offer this additional reporting and accumulate a set of responses arising from Australian practitioners. Feedback: The GBCA’s approach to utilise an ‘Additional Life Cycle Impact Reporting’ criterion is also supported as an appropriate and effective way to further facilitate and encourage reporting across other impact categories. It is agreed that over time this is likely to build the industry’s understanding of these impact categories and how LCA should approach or consider these categories. Feedback: We do not agree that the ‘Additional Life Cycle Impact reporting’ is an appropriate and effective way to facilitate and encourage reporting across other impact categories etc.

GBCA Response The Additional Life Cycle Impact Reporting criterion now requires specific impact categories to be reported. These categories are: Human Toxicity; Land Use; Resource Depletion - Water; Ionising Radiation and Particulate Matter. Impact category selection for the Reference Case comparison criterion is now aligned with EN 15978, as suggested by stakeholder feedback. We have considered the application of weightings for Additional Life Cycle Impact Reporting criterion and have discussed this with stakeholders since the consultation process for the use of LCA in Green Star commenced (September 2012). As evident by feedback from stakeholders received to the Life Cycle Assessment In Green Star Discussion Paper 1, the use of weightings is not strongly supported.

Life Cycle Assessment in Green Star Stakeholder Feedback Report

Data Sources Do you agree with data selection requirements of the ‘Materials Life Cycle Impacts’ credit? If not, why?

Feedback: I think that these could be stronger for encouraging the use of data from methodologically consistent sources. The BP LCI protocol provides a data hierarchy that I would recommend being adopted as follows: “In order to compile the inventory for an LCA, data will need to be compiled for all of the inputs and outputs from the system boundary defined in the goal and scope phases of the project. This data must be sourced in priority order as follows, starting from the top of the list: 

From the BPIC/LCI database (this data will comply with the BPIC/LCI Methodology Guidelines).



From AusLCI (this data will comply with the AusLCI Data Guidelines and be highly compatible with BPIC/ICIP data).



From other acknowledged Australian data sources (documented for source, age, representativeness and data quality assessment).

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From other authoritative sources (e.g. Ecoinvent, USNLCI) adapted for relevance to Australian conditions (energy sources, transport distances and modes and so on, and documented to show how the data is adapted for relevance in Australia).



From other sources with sensitivity analysis reported to show the significance of this data for the results and conclusions drawn.

In using data from other sources, the practitioner should make every practical effort to adapt and model the data to be compatible with the BPIC/LCI Methodology Guidelines and this Protocol. Any deviation from the BPIC rules must be documented with reasons for deviation and attempts made.” Feedback: The use of actual product data for the products being used in the building should be the first choice - e.g. local or imported product data Feedback: The data selection criterion as presented leaves too much scope for use of data not relevant to the Australian Market. It is suggested that the criteria should be modelled as per the data hierarchy that is presented under BP-LCI to ensure that Australian relevant data is selected as a first basis and not adjusted international data. Feedback: Data to be used by the LCA practitioner should be selected based on an educated assessment of quality, availability and appropriateness. The suggestion that all imported data should be adapted for relevance to Australian conditions is not always appropriate and will unnecessarily lock the LCA practitioner into using a very limited and potentially inappropriate set of available data. For example, Lend Lease often sources a large number of building materials manufactured by offshore suppliers. LCA modelling for a façade module, where the aluminium for the frame is smelted, extruded and assembled in China, should ultimately be based on data that reflects the relevant Chinese energy mix. It would be inappropriate to use an Australian energy mix in this context particularly if you are comparing an alternative façade manufactured by a supplier locally or within another region. Lend Lease would strongly advocate greater flexibility in the choice of approved data sources. We believe that the selection and choice of the most appropriate data source should be decided by the LCA Practitioner. We believe that it is more important that projects maintain transparency and full disclosure of the data sources used for assessment purposes, consistent with best practice LCA, rather than being locked into potentially limiting or inappropriate data sources. 45

Life Cycle Assessment in Green Star Stakeholder Feedback Report

Feedback: We support the preference of Australian data. However, does the adjustment for local factors provision include energy supply source? This is unclear. Feedback: Yes, this is a sound approach. There are some papers in circulation that sensationalise the differences between regional data sets. However, when these are scrutinised it may be more the methodologies used that explain the differences rather than the actual production methods. From this perspective, eTool has taken the general approach to data in our own LCA software development: 

Use the most appropriate and rigorous data wherever possible.



Where this is not feasible, or a reliable source does not yet exist, ensure that designs being compared are using the same data source to ensure any methodology differences in data do not affect decisions being made due to the LCA results.

For Australian projects using eTool LCA software for the Green Star credits we will be using a subset of the AusLCI data set prepared by Tim Grant from Life Cycle Strategies. Feedback: We agree with the in principle requirements from EN15978, and therefore with the GBCA referencing these requirements. In practice not all available data will meet these requirements. We suggest easing this requirement by demanding that the data that make up at least 80% of the impacts in the mandatory environmental indicators meet the data quality requirements from EN15978. ALCAS has recently released a new version of its AusLCI database + shadow-database. This database contains linked processes for most common building materials. The database is based on a validated, consistent background database and key building material processes have been adjusted for Australian conditions. As the representative body for Australian LCA practitioners, we considers this database to be the best starting point for whole-of-building assessments, although the final choice of data should always be the responsibility of the practitioner in view of the scope of the project. This database will be updated with Australian data when these become available for publication. Feedback: The selection of readily available Australian data in the BP LCI database should be referenced. BPIC developed the Building Products Life Cycle Inventory to serve the national interest in reducing the impact of, and improving the sustainability of, the built environment. It is a freely available service developed and maintained by the building products industry. It provides a toolkit of nationally consistent and scientifically reliable methods and data which we recommend as the basis for conducting Life Cycle Assessment of building products and whole buildings in Australia. The BP LCI enables: 

Access to industry wide data on the environmental impact of key building products and materials,



Manufacturers of building products to measure, report and improve the environmental impact of their individual products in comparison with the industry wide data,



Building product users to assess the environmental impact of these products,



LCA Tools suppliers to develop LCA tools and integrated building design tools using this data,



Buildings rating organisations to develop LCA based assessments and credits using this data, and 46

Life Cycle Assessment in Green Star Stakeholder Feedback Report



Carbon assessors to develop industry accepted Scope III carbon assessments for building products and buildings

It is not appropriate for this discussion to be occurring with no reference to the BP LCI as a means of both assisting Green Star uses to find relevant, current Australian data and to recognise the value of the BP LCI to the industry as a whole. Feedback: GBCA’s approach and requirements to data selection are supported. It is also agreed that the use of Australian data is most desirable, and preferable. Only when accurate Australian data is not available should data from other markets be utilised and adjusted for Australian conditions. The requirements for data selection as established in EN 15978 are also supported, that being that an LCA practitioner must satisfy a number of criteria to ensure data suitability and that data selection must be reported and subjected to peer review. It is agreed that this approach to data selection should assist in ensuring that data quality is maintained and in alignment with established data selection requirements Feedback: Yes, but while there are several sets of data for Australia being used by different practitioners it will be crucial for the GBCA to establish a stricter hierarchy of data source for modelling. To illustrate the point for building products in Australia, there is currently: 

AusLCI with limited data for building products



a major database (gate to gate) for Australian manufacturing of building products through the BP LCI



a shadow database developed by ALCAS for AusLCI, although not considering the work done through the BP LCI



the Australasian LCI database by Life Cycle Strategies supplied with the SimaPro software, including a large range of building oduct data, of which some is based on the BP LCI



LCI data in the GaBi software although it’s unknown to what extent is includes Australian data



Legacy data developed by the CRC for Construction Innovation (now relaunched as the Sustainable Built Environment National Research Centre) used in LCA Design and for eco-label assessments.

The use of proprietary, out of date or inconsistently modelled data for LCA is still a major issue for comparability and transparency, and ultimately credibility for LCA in Australia.

GBCA Response The use of any data inventory is to be justified on a project basis and will be based on the requirements of EN 15978 for data quality. It is not appropriate for the GBCA to nominate exactly which data inventory should be used, although the credit does give preference to Australian data, which would mean the BP LCI, Aus LCI and other sources of Australian data will be preferred.

Life Cycle Assessment in Green Star Stakeholder Feedback Report

The ‘Materials Life Cycle Impacts’ credit reference case criteria benchmarking Do you agree with the initial cumulative reduction benchmark of 100% on the Reference Case across the four impact categories? Feedback: I don’t think this is technically robust because unless all of the impact categories are of the same importance the percentage result has mixed units. The weighting survey results reveal that Australian Stakeholders on average judged Climate Change to be 7 times as important as Eutrophication. If a single percentage is the target then it should be based on weighted contributions to be robust.

Feedback: Yes - but what checks or controls are there on the adjustments to the reference case to prevent 'gaming'. Feedback: We propose the same points are available whether it is an ‘Actual Reference Case’ or a ‘Standard Practice Reference Case’. A differentiation could instead be available where product specific LCI data is used over industry wide data (for a certain % of the materials) to help promote the development of real and Australia specific LCI information. Feedback: Yes, this approach appears appropriate notwithstanding our comments made under points 13 above and 17 below. Feedback: We agree with the initial cumulative reduction benchmark to be set at 100%. However, we suggest for thisbenchmark to be reviewed once sufficient feedbacks from practitioners can be collected. It is in fact difficult to assess whether or not the scale of reduction is relevant, and this should be subject to review. Feedback: Yes, at this stage with limited data available to determine the level of difficulty in achieving these targets, this initial reduction benchmark of 100% is appropriate. That said it will be important to be able to revise and update accordingly as data is provided through the uptake of the credit. Feedback: It is difficult to set a reduction benchmark without testing the performance of a range of buildings compared to reference cases. A 25% reduction across four indicators appears reasonable, but will have to be tested and reviewed based on initial credit applications. We think a 25% reduction of environmental impacts is a reasonable starting point. It is important to understand that the environmental performance of a building is determined by the scope of the assessment, the building design and operation, the materials used, the operational performance and also the data quality and data completeness of the underlying life cycle inventory data. It is quite possible that there are combinations of these factors that lead to unforeseen or unintentional outcomes. These effects will have to be teased out by performing multiple assessments across the spectrum of buildings, building materials and environmental indicators, using various “approved” datasets. We recommend the GBCA and industry stakeholders perform an extensive case study studying the drivers of environmental impacts for buildings and building materials. This case study should also highlight the importance of life cycle inventory data, data quality and impact assessment. The current requirement that no impact is allowed to increase by more than 5% compared to the reference case will also need to be tested. Five percent difference between two buildings is well within the uncertainty range of environmental indicators. It would be 48

Life Cycle Assessment in Green Star Stakeholder Feedback Report

undesirable if particular materials are effectively punished for data completeness; so we stress that data asymmetry should (always) be addressed by practitioner and reviewer. We suggest that a limit of 10% may be more appropriate given typical uncertainty and variability in emission measurements. We understand the rationale behind not allowing any material increases in impacts, but believe the chosen approach should be frequently evaluated We support the choice to reward effort to include additional impact categories in the assessment, as stated earlier. There is a considerable chance that important trade-offs become apparent in those additional categories, e.g. when comparing renewable and non renewable materials. While we agree that no limit for increase in those additional impacts should be imposed at this stage, we note that ISO 14040/44 requires an interpretative discussion of what such trade-offs mean in context of the goal of the project. Feedback: It is impossible to suggest whether nominating a 100% reduction (cumulative) on the base case is the appropriate benchmark. Essentially this is an arbitrary decision and the from BPIC’s perspective, the more relevant questions relate to our earlier comments about what is the actual environmental benefit of the nominated product versus the benchmarked product. For example, can a reduction be achieved by selecting a single product, which has an EPD, that has an improved outcome in these four impact categories? Potentially the answer is yes when considering the size and scope of the materials specification of commercial buildings. Arguably this scenario answers the previous concern regarding what, if any, environmental benefit is derived from solely having an EPD. However it raises an alternative question which is how this improvement can be assessed for an individual product which only has an industry wide EPD available, which will be the case for the bulk of materials at this time. Clearly the benchmarking exercise will need to address the environmental impacts of the ‘standard’ material(s) used and it is possible that no such information will exist outside the BP LCI information. Will the proponent use the EPD as the baseline or the improved product? Feedback: The cumulative reduction benchmark of 100% on the Reference Case across the four impact categories appears to provide a reasonable initial starting point for the Materials Life Cycle Impacts’ credit. It is also agreed though that this initial benchmark should be tested and adjusted as necessary over time. It is believed that the approach to offer different points for the Standard Practice Reference Case and the Actual Reference Case is an appropriate approach; whether if it encourages more projects to undertake the Actual Reference Case approach (with more accurate and reliable reference case data and impact reduction documentation) will be interesting to monitor. The GBCA’s position to offer ‘no points’ where one of the impact categories is increased by more than 5%, is also supported; as is the position that impact categories are to be assessed unweighted. Feedback: As discussed earlier, we think that the use of a sub-set of impact categories can lead to perverse environmental outcomes. LCA’s main benefit is to provide holistic and comprehensive environmental comparisons. By sub-optimising based on a few poorly researched impact categories, the full benefit of LCA isn’t utilized. Normalisation and weighting is routinely used in LCA and rating tools. We would suggest using it for benchmarking here as well. Furthermore, the number of points should be considered against those available for operational impacts. The Materials category weightings have typically prevented projects from taking up materials credits. There is now an opportunity for whole of life impacts to be calculated for both embodied and operational impacts, compared and allocated points accordingly. This may be a future iteration of Green Star, however it should be considered as an innovative approach to this credit. For example, if the embodied impact of steel and concrete is reduced by the same amount over the 60 years as another initiative such as external shading (which will increase embodied but decrease operational impacts), then what will the resultant points impact be? It should be the same, but it is likely to favour external shading due to the weighting of the energy category. Perhaps innovation points can be awarded to correct

Life Cycle Assessment in Green Star Stakeholder Feedback Report

the shortfall, else projects will always take the route of maximum point score. We think the end game for rating tools is whole of life assessment, which would actually make most of the current credits/categories in Green Star, LEED, etc. redundant and force a reassessment of weightings and scoring in line with life cycle weighted impacts. For the proposed LCA credit, we suggest looking at the overall weighted points available in the energy category, and looking at the total number of points available for embodied impacts for a large sample set of buildings, looking at the embodied vs. operational to get a feel for an appropriate distribution of (weighted) points between the

GBCA Response There has been some support for the proposed 'cumulative reduction' benchmarking approach, which was presented in the first version of the LCA-based credit. It is acknowledged that the proposed cumulative reduction approach will evolve over time and this evolution may include changes to benchmarking, impact categories and reporting. At this stage we encourage discussions on these future changes, but cannot anticipate how and when these will occur as they rely on industry using the credit and providing empirical feedback to the GBCA. Before any major changes are made to the credit the GBCA will consult with stakeholders again.

After reviewing the points available for percentage reductions below the highest 100% cumulative reduction benchmark within the draft â&#x20AC;&#x2DC;Materials Life Cycle Impactsâ&#x20AC;&#x2122; credit, do you have any feedback, comments or suggestions for improvement?

Feedback: Overall, I think that there should be a single criterion expressed as a weighted sum Ecopoint (m2 GFA .year of life) for every building use type that should be the baseline against which to reward credit. Credit should then be rewarded linearly between the metric and zero impacts. (Into the future we will need to consider how to reward net environmentally enhancing buildings I guess). These metrics could be added together for all of the contributing areas to any building to give the life cycle benchmark for any mixed use building. Feedback: We believe that it is counterproductive to introduce a tiered point system for using a Standard Practice reference case over an Actual Reference Case benchmark. As stated this will ultimately cause project teams to adopt the reference case which provides them with the best point scoring opportunity rather than actually driving any tangible environmental benefit or outcome. Unique projects, where there may be a lack of data available to develop an appropriate Actual Reference Case will also be unnecessarily penalised. Furthermore, the differences proposed for benchmarking for the two criteria would also not necessarily address inaccuracies and assumptions inherent in creating a hypothetical case. This is because the Standard Practice Case has the potential to deviate either above or below any Actual Reference Case. In short, there is no way in telling whether the differences due to inaccuracies and assumptions would be biased in a positive or negative way. We strongly suggest simplification of this approach by adopting the same points benchmarking approach for both reference cases. Feedback: We agree with the general concept that rules the calculation of points obtained. However, given the uncertainty inherent to an LCA, we believe that a 5% increase of the impact might not be a relevant limit to stop claiming points. Rounding figures and other statistical errors throughout a life cycle analysis could potentially result in a 5% variation of the final results. We suggest this limit to also be subject to a review once sufficient feedback can be collected. 50

Life Cycle Assessment in Green Star Stakeholder Feedback Report

Feedback: As stated above we feel that regular revision and updating will be required to ensure buildings follow a path of continuous improvement. We suggest that in the near future a working group is established to provide industry feedback and input into recalibrating these targets. This will ensure that as the benchmark comparison buildings improve, new technologies are released and design / construction techniques are enhanced, the percentage improvement targets will be adapted to consistently push Green Star rated buildings to best practice. We suggest the working body should meet every six months with the aim of providing annual updates to targets. Feedback: Currently the quantity reduced is to a great extend influenced by the chosen reference case study. The quantity reduced has therefore a limited meaning and the reason why a 100% reduction benchmark is set seems random. Also an evaluation and comparison of different LCA projects solely based on the overall reduction compared to a more or less randomly defined case study is questionable. This can be improved if case studies are predefined.

GBCA Response Many of the suggestions received have been addressed in other sections of this document, including: ď&#x201A;ˇ

Standard practice reference case and actual reference case criteria now have equal points available.

ď&#x201A;ˇ

The 5% threshold for increase in impact has been adjusted to 10% to accommodate LCA margins of error.

ď&#x201A;ˇ

The credit will evolve based on data collated, the GBCA are sufficiently resourced to collate this data and evaluate the data over time.

The proposed '100% improvement benchmark' may seem arbitrary. However it the intent of the GBCA to test this proposed benchmark and adjust accordingly as empirical evidence is submitted with Green Star projects. An 'ecopoint method' of calculating and evaluating the result, meaning the outcome is displayed using a single numerical (or other) metric, often means weightings are applied. However, feedback from stakeholders does not support the use of weightings for impact categories, as demonstrated via feedback collated through the Life Cycle Assessment in Green Star Discussion Paper 1.

Life Cycle Assessment in Green Star Stakeholder Feedback Report

LCA Practitioner Do you agree with the competency requirements for LCA practitioners that have been adopted for the ‘Materials Life Cycle Impacts’ credit? Do you have suggestions for improvement?

Feedback: This seems practical pending ALCAS establishing competency evaluations. Feedback: We suggest 3 Peer Reviewed LCA studies conducted and peer reviewed. This is an emerging area how do people get this experience? The requirement stated could restrict the work to a few consultants slowing delivery and driving price up. Allowing co-authoring of LCA studies could encourage emerging expertise and prevent a market bottleneck caused by having just a few consultants with the credentials. Feedback: We agree with the proposed LCA practitioner requirements. Feedback: The general LCA practitioner competency requirements are considered reasonable. However, the requirement for peer review, will add unnecessary cost to the LCA process. ISO14044 states that peer review is not mandatory unless the LCA is being used to make a comparative assertion that is disclosed to the public. Lend Lease assumes that the LCA is only intended for disclosure to the GBCA for the purpose of Green Star Assessment. In the interest of maximising early uptake of the LCA credit, we would recommend that this requirement be removed. This approach would not be inconsistent with the GBCA’s position on other aspects of building modelling. For example energy, daylight, comfort and glare modelling studies performed for Green Star do not presently require third party peer review. Feedback: Yes, these competency requirements are quite stringent but appropriate. There would be a relatively small number of practitioners in Australia that meet this requirement. In extreme cases, large industry-wide LCAs can take a team of people to complete over a number of years. Participation in such studies would render the requirement harder to achieve due to the time restriction, yet these practitioners would probably be well qualified. Feedback: ALCAS is working on the implementation of an accreditation system for LCA practitioners. That could be used as a criteria to determine the competency of LCA practitioners. It should be considered that according to ISO 14044 in a comparative situation a panel review, including 3 independent reviewers is required. The comparison of the reference building and the actual project would need to be considered as a comparative situation. Taking this into account as well, we suggest, as detailed above, taking a similar approach as for the EPDs. Points should be awarded if an LCA of the building has been undertaken, instead of requiring the comparison to a reference case. As suggested the credit now includes a criteria requiring a whole-of-building, whole-of-life LCA to be conducted and reported, not a compression with a reference case. Feedback: We consider the current competency requirements adequate. Feedback: In the absence of an accreditation scheme being available from the relevant industry association, the proposed criteria for assessors appears practical. However it may be appropriate to have some regard to the type and scope of assessments that have been undertaken in the last five years. 52

Life Cycle Assessment in Green Star Stakeholder Feedback Report

Feedback: The GBCAâ&#x20AC;&#x2122;s position on the competency requirements for LCA practitioners and peer reviewers appears on face value to be appropriate (at least at least five LCA studies undertaken over the past three years). Perhaps this requirement might be clearer if it stipulated that these studies needed to be building and construction related. It is also noted that the Australian Life Cycle Assessment Society (ALCAS) is developing a formal LCA practitioner competency accreditation program; it would obviously be less confusing and preferable if GBCA requirements were in alignment and accordance with the requirements of this program. Feedback: As yet there is not an adequate competency accreditation program in place. The ALCAS approach appears to be a reasonable direction to follow but until that is in place we have no confidence that the interim proposed measures will result in suitable quality and governance of the overall process. We would recommend waiting until the ALCAS program has been fully developed before implementing the LCA approach. Feedback: We consider the current competency requirements adequate. Feedback: There may be an opportunity in 2014, with the establishment of the Australasian EPD Scheme, to use verifiers needed for the EPD scheme to also verify building level LCAs needed for Green Star assessments?

GBCA Response We currently have several projects using the 'Innovation Challenge' credit. The first few submissions will serve to test how the credit is applied and documented. These submissions, as well as subsequent submissions will be used to evaluate any gaps in guidance and the need for further clarification. Unlike other modelling methodologies used in Green Star rating tools, application of the required LCA methodology may be easily misinterpreted or incorrectly applied due to the lack of industry experience with this topic. As a result, a peer review of the LCA result is the only means by which compliance can be determined, while also maintaining an acceptable level of robustness in Green Star. Green Star Assessors may not possess the necessary LCA expertise to judge how the credit has been applied, without advice provided from the peer review process. As far as the Green Star assessment is concerned, the peer reviewer acts as a proxy assessor, as the peer reviewer conclusions will largely determine the award of points and how the results have been documented. To simplify documentation, we have developed a Submission Template for this credit. The LCA Practitioner Competencies section of the credit has been clarified. It has been made clearer, that participation in LCA studies as a co-author is an acceptable way to demonstrate competency. The industry has indicated that there are a sufficient number of individuals and organisations that can satisfy these requirements at this time. Additionally, the credit will serve to up-skill more LCA practitioners who will work with other practitioners on credit submissions. The LCA practitioner competencies certification being planed for Australia and developed by ALCAS will be considered when final and may replace the current LCA practitioner competencies of the credit if supported by industry. Limiting the scope of LCA conducted by the practitioner to those with building and construction work experience, will mean there will be a very limited number of practitioners available to undertake the required tasks. This will not aid the implementation of the credit and may impact costs. For the purpose of the credit the LCA practitioner does not require building and construction experience, the tasks associated with design and quantification are reserved to engineers and 53

Life Cycle Assessment in Green Star Stakeholder Feedback Report

architects. It is acknowledged that building experience may be an advantage for the LCA practitioner. ISO 14044 suggest a panel peer review is only required in a comparative situation where the LCA will be publically released. In the case of LCA generated for the purpose of the 'Materials Life Cycle Impacts' credit, this report will not be released publically, so that as indicated by ISO 14044 a single peer review is acceptable.

Implementation and review Is the proposed process to release future versions of the Materials Life Cycle Impacts and Environmental Product Declarations credits clear?

Feedback: Yes it is clear and plots a good path in the absence of a more ambitious and direct path to LCA based metrics using a tool such as ENVEST® Feedback: Yes we feel the current process is clear. We do believe LCA design philosophy spans multiple categories within Green Star but understand that in this transitionary stage locating it as part of “Materials” is logical. It is vitally important the industry understands that in order to achieve positive environmental outcomes for buildings, whole of building LCA must include operational impacts and not be constrained to materials only. Feedback: It is critical that the consultation process undertaken by GBCA continue into the future with these credits. The approach taken to date is a good starting point but there will need to be robust and clear guidelines and monitoring to ensure that the predicted outcomes are being achieved. Feedback: The proposed process and timing in relation to the release of future versions of the GBCA ‘Materials Life Cycle Impacts’ and ‘Environmental Product Declarations’ credits is quite clear and supported. The GBCA should be congratulated for their ongoing and structure commitment to implementing a full whole-of-building and life cycle assessment methodology to estimate and compare the overall environmental impact of future building and construction projects

GBCA Response Any future revisions to the 'Materials Life Cycle Impacts' and 'Environmental Product Declarations' credits will be communicated and consulted with stakeholders.

Life Cycle Assessment in Green Star Stakeholder Feedback Report

General Feedback This section of the report outlines general feedback received and does not address a specific question.

Feedback: We applaud GBCA in taking this step toward a more comprehensive and meaningful assessment of the environmental impact arising from materials used in building products within the Green Star suite of Building Rating tools. We also recognise and encourage the GBCA to create momentum. Our comments should be taken in the context of a contribution to the ongoing development of sophistication and rigour, and that we wholeheartedly support the GBCA in creating the momentum with a framework that can be built on. We believe that this initiative will lead the market as the Green Star suite of tools has done to date. We believe that GBCA have the trust and engagement of stakeholders from Government and both the supply and demand side of the Property industry whilst maintaining independence from any particular interest. Feedback: The GBCA may wish to take this opportunity to consider rewarding social impacts in the supply chain. The new social hotspot index is for example a plug in to SimaPro and could be easily added onto the proposed LCA impacts for an additional point. Furthermore, look at the new LEED credits that reward even further supply chain social impact assessment – these could provide criteria for additional innovation challenges. Feedback: The 'Reporting' section states that results of the building level LCA should be expressed in accordance with ISO21930, a building product LCA standard that is currently undergoing revision. Given that there is a requirement to follow EN15978 in the Green Star credits, my suggestion would be to require reporting format based on EN15978 (pg. 21) for consistency. Feedback: We welcome the decision to incorporate LCA into the Green Star tools. We believe that this is an important first step that will advance our industry’s understanding of LCA, improve the disclosure and availability of data to support decision making and deliver significant environmental benefits in the way we design, select and specify products and materials. Lend Lease has been actively engaged in using life cycle analysis to inform design and procurement decisions across a number of projects for some years. We have developed our own methods, models and tools which have been applied to live projects. Recent examples include Forte, Australia’s first cross laminated structural timber high rise apartment building, and Barangaroo South, where we have committed ourselves to achieving a 20% embodied carbon reduction for the entire development. In addition to this, we are currently working on integrating LCA as part of our in-house building information modelling (BIM) systems. This innovation enables rapid real time life cycle assessment of a building at any stage within the design process, from early concept right through to project delivery. We believe that we are well placed to understand the technical challenges in applying LCA to buildings and fully understand the value in using LCA as a tool to guide decision making and drive improved environmental outcomes. We welcome the opportunity to assist and share with the GBCA, the technical and practical experience we have gained implementing LCA within our business. Feedback: We feel that the introduction of two draft credits operating as “Innovation Challenges” is a fantastic development for buildings in Australia. The driving motivation behind eTool is to improve the environmental and economic performance of buildings. To that end eTool has successfully provided Life Cycle Assessment (LCA) software and consultancy services to the building industry since 2010. eTool has delivered more than 90 projects, from shop fit-outs to large scale commercial and infrastructure projects, so we believe we are well-positioned to provide a constructive and qualified contribution to the discussion. 55

Life Cycle Assessment in Green Star Stakeholder Feedback Report

Understandably, eTool is motivated to see LCA propagate as a standard design methodology for the built form as fast as possible. Hence we take a comprehensive and progressive stance on the subject, which the following comments reflect. It is imperative that as LCA progresses to become a standard component of good building design that it does so in a rigorous and credible fashion. eTool is intensely aware of this and seeks to assist the GBCA in any way to ensure a positive outcome for the buildings themselves and all stakeholders involved. We also understand that the successful delivery of such an important initiative is underpinned by good collaboration amongst everyone involved in the industry. eTool has always had a strong belief that sharing information, collaboration and mutual cross promotion is the key to improving the environmental and economic performance of buildings and to that end we hope that our input into this process will be beneficial to GBCA. Feedback: We very much support the approach of including Life Cycle Assessment approaches and EPDs for the assessment of buildings. Feedback: BPIC are extremely disappointed at the lack of direct consultation since the last discussion paper was released. The lack of reference to the BP LCI in the discussion paper and the failure to recognise the activities occurring to establish an Australian context for LCA through both BPIC’s efforts and the work of National Standards is al o of great concern. As you are aware, BPIC has a strong interest in the use of life cycle assessment as a methodology to determine the environmental performance of building materials. Following the extensive efforts by our members to establish the first Australian Life Cycle Inventory of key building products and materials – the Building Products Life Cycle Inventory (BP LCI) – we believe it is fundamental to see the BP LCI recognised in rating tools such as Green Star. Whilst the first stage of the BP LCI work is now complete, BPIC is continuing to work with members to improve the operation of the data base, to engage with LCCA practitioners and to advance the use of Australian life cycle information inn preference of overseas data. Feedback: We recognise the initiative that you are taking, and the leadership that you are showing on this issue. We offer our support in the creation of the momentum - congratulations so far, and we look forward to supporting the initiative further.

GBCA Response It is not the roll of the GBCA to determine what data sources should be used by an LCA practitioner. Data selection should be performed on a case-by-case basis by the practitioner and they should ensure that the data used is representative of the actual materials and products used in the project. The credit requires that Australian data is used in preference to imported data wherever possible, to encourage the use of LCIs such as the BP LCI, Aus LCI and other Australian data sources. Social responsibility criteria are being considered as part of the development of Green Star - Design & As Built and may also be considered in future editions of the 'Materials Life Cycle' Impacts credit.

Life Cycle Assessment in Green Star Stakeholder Feedback Report

Appendix A We thank the following organisations for providing feedback in response to the Life Cycle Assessment in Green Star Discussion Paper 2, as outlined in this document. 

Clarity Environment

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BlueScope Steel

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Good Environmental Choice Australia

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Australian Window Association

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Lend Lease

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Vinyl Council of Australia

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One Steel

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e-Tool

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PE Australia

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Australasian Life Cycle Assessment Society

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Building Products Innovation Council

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COX Architects

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Forest and Wood Products Australia Limited

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The Plastic Industry Pipe Association

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EDGE Environment

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BRANZ

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Energetics



Cundall

Further feedback was also received via a LinkedIn discussion group, titled 'Green Star Life Cycle Assessment Innovation Challenge - Buildings'.