Submitted via email to: [email protected] General ...
David Tow Head of Strategy UrbanGrowth NSW Level 16, 227 Elizabeth Street
SYDNEY NSW 2000
Submitted via email to: [email protected] 14 June 2016 Dear David, RE: DRAFT SUSTAINABILITY COMPACT Thank you for the opportunity to provide comment on draft UrbanGrowth NSW Sustainability Compact (the Compact). The Green Building Council Australia (GBCA) commends UrbanGrowth on its ambition to deliver world leading sustainability outcomes from urban transformation projects. We applaud the aspiration to once again position UrbanGrowth NSW as an international leader in sustainable urban development and believe that a government land organisation has a unique opportunity, as well as an obligation to encourage, support and endorse best practice in NSW and Australia In drafting this submission, the GBCA has consulted with key members, and drawn upon its own experience in working with governments and the private sector in communities across Australia and internationally, which are seeking to achieve global sustainability standards in their planning, design and delivery. The GBCA sees itself as custodian and national representative for sustainable urban development in Australia, and like its relationship with all GLO’s, is committed to working with UrbanGrowth NSW as it moves towards a new era of sustainability leadership. We provide below a series of general comments regarding the Compact, followed by three specific areas where we wish to work further with UrbanGrowth NSW to ensure the Compact is robust and implementable.
General comments We note several statements made within the Compact that might benefit from review, to ensure the Compact reflects Australian best practice standards that are already supported and aspired to by industry. The Sustainability Framework (which is a component of the Compact), identifies 15 commitments and strategic interventions that it states “would not otherwise occur” (p 4). This statement infers that industry either has not been able to advance such sustainability outcomes, or that UrbanGrowth NSW has underperformed in its own capability to deliver on sustainability commitments in its projects. The GBCA argues that industry has already been demonstrating leadership in many of these areas and that this statement also indicates a lack of awareness of the ‘ecosystem’ of sustainability methods and tools industry has been using
to underpin their projects successfully across the country for many years and to international acknowledgement, and how industry practitioners are advancing their own professional development and engaging in dialogue. Further, the Compact makes a statement about the "contextualisation of our commitments, rather than the typical approach of forcing copy-cat strategies not fit for purpose, that will be a big differentiator in the performance and commercial viability of our projects”. The GBCA disagrees with this statement, and would argue that copy-cat strategies are not the typical approach to urban regeneration. As can be seen with the prolific use of Green Star, the market is delivering a diversity of approaches and contextualised responses while still meeting the best practice criteria within the rating tool. The National and Global Benchmarking section of the Compact, which sets out to answer the question “What defines world leading sustainability in urban transformation projects”, did not fully explore and identify key success factors in delivering successful urban transformation projects, such as governance, leadership, collaboration and creative and sustainable financing models. Neither did it reference the industry rating tools that were used to assess and benchmark these projects. This may possibly be supporting research that was not included in the Compact, and if so, the GBCA would welcome the opportunity to review such material and work with UrbanGrowth NSW to provide further insight and information based on our experiences. Whilst an informative read, the section of the Compact titled “Giving Effect to our Principles and Commitments”, could be made into an appendix, as it provides a desktop review of sustainability issues, concepts and data rather than providing guidance on such principles and commitments will be implemented.
Working together Further to the general comments above, we outline the following issues as areas of concern, as well as opportunity. The GBCA offers assistance to help further scope and develop these areas in partnership with UrbanGrowth NSW. 1. GREEN STAR – COMMUNITIES At our meeting in March you mentioned that Green Star – Communities was not considered when drafting the Compact. Whilst this is disappointing, we understand that not all key decision makers within UrbanGrowth NSW are aware of the Green Star – Communities rating tool and what it represents for the urban development community in Australia. We are acutely aware of the substantial staff changes that have occurred at UrbanGrowth NSW over the past 12-18 months, and understand that this may mean that there is no one within the organisation with a strong understanding of Green Star – Communities at the time the Compact was produced.
At the time of its development, VicUrban (now Places Victoria) was a key supporter and sponsor of the Green Star – Communities rating tool, providing important intellectual property and case studies which were then leveraged to build out the tool that is available today. All other Government Land Organisations came together as collaborators of the rating tool, as well as additional sponsors from local government, the Australian Government, academia and industry. This included Landcom, now UrbanGrowth NSW. It still remains the only sustainability performance rating system that was developed as an Australia-wide partnership among public and private sector, and today has more than 50+ projects that are either certified or registered for certification, including a project in NZ and South Africa. The GBCA believes that with the ever-increasing environmental, social and governance (ESG) investment requirements by national and international investors, there is a strong need for
projects to demonstrate international relevance using recognised, existing rating tools which can offer independent verification and assurance, rather than bespoke and in-house methods of framing and assessing sustainability performance. This does not mean bespoke and inhouse frameworks cannot be impactful, however by not embracing industry-recognised rating tools, barriers to development and property funds investing in UrbanGrowth NSW projects may be created. In recent years, GRESB (Global Real Estate Sustainability Benchmark) has emerged as a global leader in assessing the sustainability performance of infrastructure and real estate assets, which more than 60 pension funds now use in their investment management processes. Without independent assurance that industry or internationally-agreed standards have been met, UrbanGrowth NSW has no reliable way to verify that desired project outcomes have been achieved. By not specifying a specific, independent rating tool, UrbanGrowth NSW may also create a potentially uneven playing field for projects where some developers may commit to setting and achieving higher benchmarks than others and/or using more or less rigorous rating systems. Without an agreed, independent method of assessment, there is no way to compare projects fairly. Today, Green Star – Communities is assisting governments, development project teams, contractors and other stakeholders planning and delivering large scale sustainable developments around Australia. Other Government Land Organisations, along with private sector developers, have corporate policies which commit to achieving Green Star – Communities ratings on their precinct-wide development projects. For the reasons above, the GBCA calls on UrbanGrowth NSW to include Green Star – Communities as the sustainability benchmarking rating tool of choice in the Compact. We believe this to be a first key step in its journey to becoming a world leading urban transformation agent. I would welcome the opportunity for the GBCA leadership team to meet with and brief the UrbanGrowth NSW leadership team on Green Star – Communities, the benefits and influence it is having on Australia’s urban regeneration landscape, and how it can be embedded into the Compact. 2. PRECINCX The GBCA has been, and will continue to be, a supporter of quantitative performance analysis tools, such as PRECINCX, which compare development scenarios using robust metrics. We believe that this is a valuable activity that supports a more holistic sustainability assessment, such as those guided by rating tools like Green Star – Communities.
While the GBCA is supportive of PRECINCX, we and many of our developer members have noted that this tool was developed without extensive industry engagement and does not have a high level of transparency and interoperability with other systems. PRECINCX was also not designed to provide a robust independent verification process, which is a characteristic many key stakeholders now demand in the application of decision-making tools. The decision to make PRECINCX the only tool referenced within the Compact may limit outcomes, lead to concerns from developers and will require greater explanation about what is expected of the development community in using this tool. The GBCA proposes that we work together with UrbanGrowth NSW and Kinesis to host an industry forum on the use of PRECINCX in urban regeneration projects, its interoperability with Green Star - Communities and how a co-created sustainability agenda can be realised for UrbanGrowth NSW projects.
3. METRICS, GOVERNANCE AND PROJECT IMPLEMENTATION
UrbanGrowth NSW is making a bold and welcome step in transitioning to a performance monitoring and reporting platform for its projects. This aspiration is admirable. In the section on “A Mechanism for Implementation”, the issue of required collaboration between private and public sector is identified. However, the role of the non-profit or thirdparty sector, and also the community could also be included to strengthen UrbanGrowth NSW’s approach. This is a fundamental issue that should be recognised in the overall stakeholder engagement approach for all projects. A more comprehensive review of international best practices, and engagement with industry stakeholders, could help identify next generation urban transformation projects emerging globally that are adopting deep collaborative processes not only between public and private sector, but also non-profits and the community. This critical information would sit well in the ‘Implementation' section of the Compact, as it is a critical success factor in ongoing monitoring and reporting. The operational nature of many metrics within the Compact, along with the proposed implementation and knowledge management platform, raise the critical question of governance, and how UrbanGrowth NSW proposes to deliver and manage projects, and what it will require of its partners. The GBCA would be willing to assist UrbanGrowth NSW in exploring this issue, and in helping to identify approaches to ongoing sustainability governance, with which our members and partners have extensive experience. We look forward to working closely with UrbanGrowth NSW in refining the Compact to ensure it becomes both a reflection of best practice and commitment currently displayed by market leaders, as well as a document to guide aspiration towards world-class urban renewal. I look forward to finding a time to discuss the opportunities to collaborate which we have identified in this submission. Yours sincerely,
Romilly Madew
Submitted via email to: [email protected] 14 June 2016 Dear David, RE: DRAFT SUSTAINABILITY COMPACT Thank you for the opportunity to provide comment on draft UrbanGrowth NSW Sustainability Compact (the Compact). The Green Building Council Australia (GBCA) commends UrbanGrowth on its ambition to deliver world leading sustainability outcomes from urban transformation projects. We applaud the aspiration to once again position UrbanGrowth NSW as an international leader in sustainable urban development and believe that a government land organisation has a unique opportunity, as well as an obligation to encourage, support and endorse best practice in NSW and Australia In drafting this submission, the GBCA has consulted with key members, and drawn upon its own experience in working with governments and the private sector in communities across Australia and internationally, which are seeking to achieve global sustainability standards in their planning, design and delivery. The GBCA sees itself as custodian and national representative for sustainable urban development in Australia, and like its relationship with all GLO’s, is committed to working with UrbanGrowth NSW as it moves towards a new era of sustainability leadership. We provide below a series of general comments regarding the Compact, followed by three specific areas where we wish to work further with UrbanGrowth NSW to ensure the Compact is robust and implementable.
General comments We note several statements made within the Compact that might benefit from review, to ensure the Compact reflects Australian best practice standards that are already supported and aspired to by industry. The Sustainability Framework (which is a component of the Compact), identifies 15 commitments and strategic interventions that it states “would not otherwise occur” (p 4). This statement infers that industry either has not been able to advance such sustainability outcomes, or that UrbanGrowth NSW has underperformed in its own capability to deliver on sustainability commitments in its projects. The GBCA argues that industry has already been demonstrating leadership in many of these areas and that this statement also indicates a lack of awareness of the ‘ecosystem’ of sustainability methods and tools industry has been using
to underpin their projects successfully across the country for many years and to international acknowledgement, and how industry practitioners are advancing their own professional development and engaging in dialogue. Further, the Compact makes a statement about the "contextualisation of our commitments, rather than the typical approach of forcing copy-cat strategies not fit for purpose, that will be a big differentiator in the performance and commercial viability of our projects”. The GBCA disagrees with this statement, and would argue that copy-cat strategies are not the typical approach to urban regeneration. As can be seen with the prolific use of Green Star, the market is delivering a diversity of approaches and contextualised responses while still meeting the best practice criteria within the rating tool. The National and Global Benchmarking section of the Compact, which sets out to answer the question “What defines world leading sustainability in urban transformation projects”, did not fully explore and identify key success factors in delivering successful urban transformation projects, such as governance, leadership, collaboration and creative and sustainable financing models. Neither did it reference the industry rating tools that were used to assess and benchmark these projects. This may possibly be supporting research that was not included in the Compact, and if so, the GBCA would welcome the opportunity to review such material and work with UrbanGrowth NSW to provide further insight and information based on our experiences. Whilst an informative read, the section of the Compact titled “Giving Effect to our Principles and Commitments”, could be made into an appendix, as it provides a desktop review of sustainability issues, concepts and data rather than providing guidance on such principles and commitments will be implemented.
Working together Further to the general comments above, we outline the following issues as areas of concern, as well as opportunity. The GBCA offers assistance to help further scope and develop these areas in partnership with UrbanGrowth NSW. 1. GREEN STAR – COMMUNITIES At our meeting in March you mentioned that Green Star – Communities was not considered when drafting the Compact. Whilst this is disappointing, we understand that not all key decision makers within UrbanGrowth NSW are aware of the Green Star – Communities rating tool and what it represents for the urban development community in Australia. We are acutely aware of the substantial staff changes that have occurred at UrbanGrowth NSW over the past 12-18 months, and understand that this may mean that there is no one within the organisation with a strong understanding of Green Star – Communities at the time the Compact was produced.
At the time of its development, VicUrban (now Places Victoria) was a key supporter and sponsor of the Green Star – Communities rating tool, providing important intellectual property and case studies which were then leveraged to build out the tool that is available today. All other Government Land Organisations came together as collaborators of the rating tool, as well as additional sponsors from local government, the Australian Government, academia and industry. This included Landcom, now UrbanGrowth NSW. It still remains the only sustainability performance rating system that was developed as an Australia-wide partnership among public and private sector, and today has more than 50+ projects that are either certified or registered for certification, including a project in NZ and South Africa. The GBCA believes that with the ever-increasing environmental, social and governance (ESG) investment requirements by national and international investors, there is a strong need for
projects to demonstrate international relevance using recognised, existing rating tools which can offer independent verification and assurance, rather than bespoke and in-house methods of framing and assessing sustainability performance. This does not mean bespoke and inhouse frameworks cannot be impactful, however by not embracing industry-recognised rating tools, barriers to development and property funds investing in UrbanGrowth NSW projects may be created. In recent years, GRESB (Global Real Estate Sustainability Benchmark) has emerged as a global leader in assessing the sustainability performance of infrastructure and real estate assets, which more than 60 pension funds now use in their investment management processes. Without independent assurance that industry or internationally-agreed standards have been met, UrbanGrowth NSW has no reliable way to verify that desired project outcomes have been achieved. By not specifying a specific, independent rating tool, UrbanGrowth NSW may also create a potentially uneven playing field for projects where some developers may commit to setting and achieving higher benchmarks than others and/or using more or less rigorous rating systems. Without an agreed, independent method of assessment, there is no way to compare projects fairly. Today, Green Star – Communities is assisting governments, development project teams, contractors and other stakeholders planning and delivering large scale sustainable developments around Australia. Other Government Land Organisations, along with private sector developers, have corporate policies which commit to achieving Green Star – Communities ratings on their precinct-wide development projects. For the reasons above, the GBCA calls on UrbanGrowth NSW to include Green Star – Communities as the sustainability benchmarking rating tool of choice in the Compact. We believe this to be a first key step in its journey to becoming a world leading urban transformation agent. I would welcome the opportunity for the GBCA leadership team to meet with and brief the UrbanGrowth NSW leadership team on Green Star – Communities, the benefits and influence it is having on Australia’s urban regeneration landscape, and how it can be embedded into the Compact. 2. PRECINCX The GBCA has been, and will continue to be, a supporter of quantitative performance analysis tools, such as PRECINCX, which compare development scenarios using robust metrics. We believe that this is a valuable activity that supports a more holistic sustainability assessment, such as those guided by rating tools like Green Star – Communities.
While the GBCA is supportive of PRECINCX, we and many of our developer members have noted that this tool was developed without extensive industry engagement and does not have a high level of transparency and interoperability with other systems. PRECINCX was also not designed to provide a robust independent verification process, which is a characteristic many key stakeholders now demand in the application of decision-making tools. The decision to make PRECINCX the only tool referenced within the Compact may limit outcomes, lead to concerns from developers and will require greater explanation about what is expected of the development community in using this tool. The GBCA proposes that we work together with UrbanGrowth NSW and Kinesis to host an industry forum on the use of PRECINCX in urban regeneration projects, its interoperability with Green Star - Communities and how a co-created sustainability agenda can be realised for UrbanGrowth NSW projects.
3. METRICS, GOVERNANCE AND PROJECT IMPLEMENTATION
UrbanGrowth NSW is making a bold and welcome step in transitioning to a performance monitoring and reporting platform for its projects. This aspiration is admirable. In the section on “A Mechanism for Implementation”, the issue of required collaboration between private and public sector is identified. However, the role of the non-profit or thirdparty sector, and also the community could also be included to strengthen UrbanGrowth NSW’s approach. This is a fundamental issue that should be recognised in the overall stakeholder engagement approach for all projects. A more comprehensive review of international best practices, and engagement with industry stakeholders, could help identify next generation urban transformation projects emerging globally that are adopting deep collaborative processes not only between public and private sector, but also non-profits and the community. This critical information would sit well in the ‘Implementation' section of the Compact, as it is a critical success factor in ongoing monitoring and reporting. The operational nature of many metrics within the Compact, along with the proposed implementation and knowledge management platform, raise the critical question of governance, and how UrbanGrowth NSW proposes to deliver and manage projects, and what it will require of its partners. The GBCA would be willing to assist UrbanGrowth NSW in exploring this issue, and in helping to identify approaches to ongoing sustainability governance, with which our members and partners have extensive experience. We look forward to working closely with UrbanGrowth NSW in refining the Compact to ensure it becomes both a reflection of best practice and commitment currently displayed by market leaders, as well as a document to guide aspiration towards world-class urban renewal. I look forward to finding a time to discuss the opportunities to collaborate which we have identified in this submission. Yours sincerely,
Romilly Madew
