stakeholder feedback received€¦ · eligibility building type - not relevant to train stations?...

GBCA App 05. Feedback Received – Green Star Design & As Built: Railway Stations Consultation Feedback Report Jan 2019 1

Stakeholder Feedback received This document includes all feedback received during the consultation period. Where applicable, it has been anonymised. Minor wording corrections and the provision of guidance will be marked with. Significant amendments to criteria or compliance requirements are marked with.

General

Section Stakeholder comment GBCA response Overall rating tool Another general thing to check – many of the web pages and

hyperlinks listed in the submission guidelines to GBCA guidance no longer exist / have moved. Would be good to do an update of all of these. e.g. http://www.gbca.org.au/greenstar/technical-support/materials-category/new-reporting-criteria-for-construction-demolitionwaste-credit/34797.htm is now https://new.gbca.org.au/construction-and-demolition-waste/

GBCA to amend and check hyperlinks.

We understand that merging the former Melbourne Metro Tool with the current Design & As Built V1.2 tool, and amending with stakeholder’s feedback, is a sound methodology. However, we have found that both specific and generic “cut and paste” problems are evident throughout the guidelines, where in some components it is difficult to see how an initiative or terminology could be applied to a railway station context. One example is the infiltration and pressure testing component, of commissioning described further down this list. [omitted] have suggested changes where we have picked up any of these anomalies, however it is strongly encouraged that a thorough QA review of the terminology in the technical manual is undertaken from the perspective of railway stations

The GBCA notes that this rating tool is intended to be a tailored version of Green Star - Design & As Built V1.2, not the existing MMRA tool, in order to ensure the tool aligns with the latest version of the Green Star - Design & As Built tool.

Further to the point above, [omitted] have developed a table (on the overleaf) of wording replacements that could possibly be implemented upon review by the tool developer and the steering committee

Noted with thanks. This will be addressed in the finalisation of the Rating tool.


The Submission Guidelines are titled “National Railways” as are the file names on the scorecards. The scorecard title in changelogs and at the top of spreadsheets is “Railway Stations”. [omitted] believe that the “Railway Stations” tool is the correct terminology.

Noted with thanks. This will be addressed in the finalisation of the Rating tool.

I’m a little concerned at a formal release of an official custom tool for a particular class of project – distinct tools for different building classes is something the GBCA deliberately moved away from for GS D&AB. My concerns are exacerbated by timing that coincides with the GBCA just embarking on industry consultation for the next major tool update. Is a formal tool release really in the GBCA’s interests here? I feel it could cloud the issue of industry engagement on this critical new tool development process we’re all about to embark on. There are three major metro projects in Australia currently – Cross-River Rail, Sydney Metro (NW, City & SW and West Metro) and Melbourne Metro. Could this not be addressed directly with the major state procurement agencies rather than an official public tool? I’m also a bit concerned at the lack of clear alignment between IS and GS for infrastructure projects. I know there are a range of views on the matter, but is it too much to expect that ISCA and the GBCA could speak with one voice on which tools are most appropriate for which components of the built environment?

While custom railway station rating tools exist for projects in Victoria and New South Wales, there is a desire to have a common rating tool which can be used by all projects to enable a common comparison and to demonstrate a clear and consistent message to stakeholders. It also increases transparency and simplifies and streamlines the work required by the GBCA to maintain multiple custom rating tools.


From my end I would like to particularly highlight the issue of a new station's role as catalyst for a community and their mobility. The priorities that are set from the beginning in terms of how people travel to a station is crucial in fostering behaviours. This may different in different locations (e.g. rural vs regional city) but in any case Green Star should foster adaptability to future technology and system changes (e.g. through autonomous vehicles or ride share services, which may drastically reduce car parking requirements) and always prioritise the modal hierarchy Mark has described. To that end consideration could be given to a station/community specific start/end-of-trip strategy/plan that demonstrates respective prioritisation and planning for adaptability. In that context I would expect far greater need for future bicycle parking than car parking in many locations. The above suggested strategy/plan should engage with local council's active transport strategies.

The GBCA has consequently explored alternative methodologies to respond to the needs of railway stations. As a result, the GBCA will adopt the Innovation section from the Green Star - Communities Sustainable Transport and Movement credit as guidance, and create connections between other sections of the rating tool including the Urban Precincts credit.

Manual now specified that subtenancies are to be included in Green Star Scope. This adds numerous challenges to the assessment process especially if they are cold shell fit outs and the station builder/owner has no control over what the tenants install.

The inclusion of subtenancies is present within previous versions of the custom rating tool as well as Design & As Built. The scope of Green Star projects is defined within the Introduction section of the rating tool. Individual projects are recommended to contact the GBCA where cold shell fitouts are included within the scope of works.

The About section mentions that some credits have undergone significant change from v1.2 D&AB. What would be helpful is a summary table / log that lists out those credits that have significant change.

GBCA to add change log upon completion. All changes from v1.2 were highlighted in the consultation draft through revision marking.

FAQ's - Good to see this is being implemented. Thanks. Noted with thanks


Small & Regional Stations

For Scenario 1 type stations with no ticket office and no habitable space – essentially car park and platform space only, it is recommended that the following further credits have “not applicable” checks in the scorecard: o 19 Greenhouse Gas Emissions – Unless a further alternative is produced to benchmark railway stations without habitable spaces o 20 Peak Demand Reduction – As above o 22 Water – It is feasible there will be no water supply to the site, or at least no toilets o 32 Microbial Control – No habitable spaces and no air conditioning o 33 Refrigerant Impacts – No habitable spaces and no air conditioning It is also suggested the commissioning and tuning be simplified for buildings with very few systems and nonhabitable spaces (noting that tuning has a small project pathway implemented)

Further consultation with Rail Projects Victoria indicated that the uptake of the Rating Tool for railway stations of this size and capacity was unlikely to occur. Eligibility criteria to be updated with guidance that small stations with little or no enclosed space are to contact the GBCA to discuss pathways for certification.

The testing of the remote railway station shows that almost half the points become not applicable (44 not applicable). This means that a 4 Star rating can be achieved with 24 core points, a 5 Star with 33 core points and a 6 Star with only 42 core points. [omitted] raise this issue because allowing this type of station to be rated could skew or de-value the Green Star definitions as to what constitutes best practice, Australian excellence or world leader in green building design. Potential solutions may be: o To allow railway stations with no habitable spaces to only be able to achieve a 4 Star only (this could be written up in the eligibility section). Or perhaps 4 or 5 Star only o Create a different scorecard for railway stations with non-habitable spaces. Potentially in combination with the suggestion above (4 Star only) o Only allow buildings with habitable spaces to be rated. [omitted] notes that this could potentially mean many green initiatives could be lost due to projects willing to rate their railway stations, but not having habitable spaces

Further consultation with Rail Projects Victoria indicated that the uptake of the Rating Tool for railway stations of this type should be tested on a pilot project and an addendum to the rating tool issued post completion.


Refurbishment With the Small Railway Station problem in mind, [omitted] note that a number of the Melbourne Metro Rail Alliance sub-projects are railway station extensions and refurbishments. Clear direction/demarcation as to what extensions and refurbishments can be rated should be given in the eligibility section

Eligibility criteria to be updated with guidance that stations undergoing refurbishment are to contact the GBCA to discuss pathways for certification.

Eligibility Building Type - Not relevant to train stations? Typical class types within stations could be mentioned here.

The Eligibility criteria for Building Type will be amended to address above ground and underground railway stations specifically, excluding items such as stabling yards and maintenance sheds.

Consider extending the expiration of the Design Review certified rating (currently 24 months) to be more in line with Rail project timeframes. This would able projects to do the Design Review rating in the early stages to benefit the design process.

Design Rating expires 24 months after project Practical Completion, not design review, and therefore the Design Rating will remain current throughout the design and construction phases of the project.

It is not clear how buildings that are not related to stations are assessed / if at all. For example would a stabling yard be considered a separate building rating to the Railway Stations tool?

The Eligibility criteria for Building Type will be amended to address railway stations specifically, excluding items such as stabling yards and maintenance sheds.

IS We have done a crossover of credits. Perhaps it could be listed here with a number of disclaimers "at the time of release of these guidelines" and "it is up to the assessor to verify credit cross overs and go through the TQ process" This at least hands over some info that it took us a few days to gather

The GBCA's next step following release of the rating tool is creation of a clear pathway for dual certification, in partnership with ISCA. We appreciate the work that has been done and will gratefully use it as a basis to build upon.

Good to see that IS tool is recognised as an overlapping method of compliance. What would be good is a cross over table / pathway that details which credits are likely to be covered by IS and vice versa or a link to this document.

As above

The content of the tool was well -laid out and is clear in scope. Thank you for acknowledging ISCA and IS rating scheme in your Submission Guidelines

Noted with thanks


Management

Section Stakeholder comment GBCA response 1 Green Star Accredited Professional

Entire credit No feedback provided

2 Commissioning and Tuning

2.1 Services and Maintainability Review - Suggest the services and maintainability review be made simpler for small station projects. Perhaps that minutes of meetings held between design team, facilities manager, operations staff and contractors (meetings can be separate) can be submitted.

The GBCA notes that this is a project-specific issue to be addressed as a technical question.

2.2.3 Air Permeability Performance Testing

1) Suggest removing this component of the credit or moving it to innovation. Or perhaps rewriting to be more specific to train stations. Generally most stations will have high infiltration due to ticket office, tunnels, doors often open due to patrons moving through. We stress that pressure testing will generally be of little value for the majority of train station projects. And difficult to test 2) Air Permeability Performance Testing may not be applicable in open, naturally ventilated station environments i.e. stations are not sealed buildings. Ticket Counters will not be sealed due to service requirements (p42) 3) Air permeability innovation challenge added for up to 2 innovation points. Note: Pressurisation requirement of platform may result in project achieving this innovation point/points regardless of any additional improvements to building fabric.

The Air Permeability Performance Testing criteria will be removed from the Commissioning and Tuning credit


Most “primary spaces” such as ticket offices and retail spaces will be open to walkways, concourses or directly to the external air. As such the infiltration and pressure testing component of the Commissioning credit does not make sense. The pressure testers may be able to block a ticket window and test the rest of the fabric, but what is the point if this is not how it functions? It is suggested that this component of the credit be taken out of the tool

Refer above.

3 Adaptation and Resilience


4 Building Information

Entire Credit 1) Reduced by 1 point and credit requirements combined into a single credit. These are two distinctly separate requirements for one credit, recommend keeping these two credits as separate items.

No changes recommended due to alignment with D&AB v1.2. The point that was removed for v1.2 had been added to credit 7 Responsible Construction Practices (previously Construction Environmental Management) for High Quality Staff Support.

Guidance Include guidance from PTV or similar organisation in other states to provide general guidelines and format of Building Users information. Additional guidance on how to deal with the ongoing agreements and management required to ensure digital format and content of information displayed is appropriately managed is also requested.

Noted, while the provision of guidance of the management of information, the documentation requirements are intended to allow project teams to demonstrate compliance in any number of methods.

5 Commitment to Performance



6 Metering and Monitoring

6.0.1 Floor by floor metering requirement is based around high rise office and not that useful for stations. Limited floors. Separating distinct uses would suffice i.e. concourses, platform, staff area etc.

Project teams are able to demonstrate best practice metering and monitoring by distinct uses. The GBCA will add more clarity for metering uses.

6.0.2 Minimum requirement now includes Energy metering integrity requirement. Would preclude a lot of projects from meeting the requirements and have an overall negative effect on the metering and monitoring employed in projects. Not clear if this is actually achievable with metering systems available within the industry. This should remain an innovation challenge, or for an additional point within credit 6, or the requirements should be refined to clearly demonstrate how compliance can be achieved. This addition is significant and should be clearly documented in the revision and amendments table.

This was not marked up on the basis that this rating tool was developed from D&AB v1.2. It was integrated in v1.2 because it is now common practice for the Australian built environment.

7 Responsible Construction Practices

Entire credit Additional point available for worker health and wellbeing. Credit specify that programs must run for the whole duration of construction, however a 'needs analysis' must also be undertaken to determine the most appropriate actions? Suggest that the programs should be implemented within a certain number of months of commencement of construction, to enable projects to undertake the 'needs analysis'.

The GBCA will amend the credit to provide clarity to ensure sufficient time for project teams to undertake a ‘needs analysis.’

8 Operational Waste

Entire Credit No feedback provided

9 Culture, Heritage and Identity

Entire Credit No Feedback provided

10 Urban Precincts


10.1 Site Planning and Layout

Integrating with existing Development - should be preferred modal hierarchy led, increasing priority pedestrian and bicycle and public transport modes over vehicle movement. Design for Mixed Use - include 'ability to adapt' or adaptability' as a key requirement rather than 'flexible enough to change over time'. (Adaptability requires an intentional anticipation and prediction of future needs. Flexibility is less overt and implies an unresolved or less considered approach to the future needs and uses.)

The GBCA will review terminology and change flexibility to adaptability, and provide clarity within the guidance section.

Public Transport - 'Avoid amenity impacts'. Change to 'mitigate', or 'resolve at design stage' to ensure benefits and potential impacts are correctly balanced.

The GBCA will review terminology and change ‘avoid amenity impacts’ to ‘mitigate amenity impacts’, and provide clarity within the guidance section.

Landscape and Green Infrastructure - 'Utilise high quality design acknowledging future maintenance'. Clarify intent. Should reference be to high quality materials?

The intent of ‘high quality design acknowledging future maintenance’ is to encourage whole of life design principles, to capture the maintenance and end of life phases. This guidance will be provided in Table 10.1, within the credit.

10.0.1b For rail projects "submission of DA or similar with any relevant approval/consent authority" are being undertaken well in advance of standard construction projects. Hence, a concept review prior to that point is generally unachievable or will be undertaken as a standard part of the early phase design process rather than driven by GBCA. Consider reviewing wording to be more aligned with rail developments and only require concept review from project award to optimise the design.

The GBCA will amend terminology from ‘DA or similar to with any relevant approval/consent authority’ to ‘project award.’

11 Safe Places

CCTV coverage and monitoring is deemed an equivalent approach to address the required passive surveillance on open patron areas that are not visible from at least one street e.g. elevated platforms.

The GBCA acknowledges that elevated platforms and skyway projects will have limited ability to meet the Safe Places criteria. In some instances, CCTV and monitoring may be considered an equivalent approach to passive surveillance if Crime Prevention through Environmental Design (CPTED) principles have been applied to all other areas. The GBCA recommends project teams to submit a project specific technical question where stations are not visible to one street.


A few thoughts while reading this: 1) what is the 'entry/exit path'. It could potentially be interpreted as the path nearest the entry and exit, but I believe the intention is to mean the path from the train right through to the exit. 2) What is the definition of a 'dark spot’? How could this be assessed?

1) The entry/exit path is the path from the train to the entry/exit of the station.

2) A dark spot refers to an area of insufficient lighting resulting in an area where there is a reduced opportunity to see and be seen.

These definitions will be included in the guidance section of the credit.

12 Wayfinding


Indoor Environment Quality Section Stakeholder comment GBCA response

13 Indoor Air Quality

13.1 Ventilation Systems

Entry of Outdoor Pollutants - Suggest further information be added to pay attention to train exhaust. E.g. air intakes and diesel exhaust fumes

Exhaust fumes have been addressed in the Exhaust or Elimination of Pollutants section of the credit


13.1.1 The separation distances outlined in ASHRAE 62.1 are not realistic for electric railways as there are minimal pollutants discharged from the tunnel ventilation systems meaning there is a low risk of contamination for outdoor air intakes from these systems. The AS1668 minimum separation distances are the current Australian regulatory requirements and are suitable for typical built environment systems including industrial and retail applications, therefore they are considered sufficient for electric rail and station applications. The other situation where these separation distances are unrealistic is where buildings are located above the station and exhaust are required to pass through this building. Given the scale of the separation distances this is difficult in many instances and also typically falls outside the control of the station developer. Update with new tool to include windows, doors, openings, vents, grilles, and skylights as intakes rather than just building services. Urban (city) rail development are generally extremely confined with entries and exits provided on sidewalks. The design teams have control over placement of mechanical intakes and exhausts, and can use vertical distances to help with achieving the requirements, often the placement of entries and exits are confined by existing site geometry. This addition may preclude projects from achieving this credit as it is outside of the designers control. Potential to make this NA for sites that meet certain constraints.

The GBCA notes that this is a project-specific issue to be addressed as a technical question. It is recommended for electric railways, evidence can be provided to demonstrate that pollutants will be negligible, by providing data sheets on the train/metro emissions. The GBCA notes that where project specific technical questions can be applied to all projects, these will be issued as FAQ’s available to all project teams using this rating tool. The GBCA acknowledges the spatial limitations of underground stations, nothing that separation distances may be difficult to achieve. It is recommended that project specific technical questions should be lodged where project teams are meeting the intent of the credit, or the credit cannot be claimed.

13.1.2 The maintenance requirement for access to both sides of all moisture collecting devices is not feasible for smaller fan coil units as it means these have to be custom made (potentially from overseas) which is not a sustainable outcome. This is also unnecessary for smaller units as the coil is typically only 700mm wide meaning the entire coil is accessible from one side.

The GBCA notes that this is a project-specific issue to be addressed as a technical question, and recommends demonstrating how the maintenance outcomes of the credit can be achieved through one side.


13.2 Provision of outdoor air

Provision of Outdoor air the % improvement should be reviewed for station spaces to ensure it is applicable. Noting that for underground stations the AS requirement is 5 x public space requirements. Awaiting information from [deleted] to provide further information for this credit.

GBCA will pursue further information on the comment to enable consideration of inclusion in the rating tool. The GBCA notes that where project specific technical questions can be applied to all projects, these will be issued as FAQs available to all project teams using this rating tool.

13.3 Exhaust of Elimination of Pollutants

Vehicle exhaust is particularly relevant here. Suggest vehicle exhaust may be made separate from photocopy equipment. Is cooking relevant? Perhaps for tenancies. Vehicle exhaust - rolling stock reference has been addressed. Given vehicle exhaust is vastly different from printing and photocopy. We still maintain it should be a separate part of the credit.

The GBCA notes that all nominated pollutants are required to be eliminated throughout the project.

14 Acoustic Comfort

Compliance Requirements

1) Suggest a sub-credit is developed for mitigating noise to surrounding areas. E.g. noise barriers around platforms 2) Again suggest train noise be included in an additional sub-credit.

The GBCA recommends that where solutions to mitigate noise pollution exceed planning requirements, project teams should claim this as an Innovation. Elements of the noise pollution credit from the industrial tool will be included as guidance.

15 Lighting Comfort

Entire credit Suggest office breakout should be primary space however. GBCA to update the guidance section for primary, secondary and tertiary spaces.

15.1 General Illuminance

If the relevant transport agency does not have any set standard on illumination levels, do these areas become N/A? Or is there a minimum this will default to? Needs a backup value.

Where a relevant transport agency does not have a set standard on illumination levels, project teams are suggested to contact the GBCA. Alternatively, project teams may use AS 1680 as a default. This process will be outlined in the Guidance section of the credit.

16 Visual Comfort


16.1 Daylight Exclude any rooms that have a one-way glass requirement. Add Protective Services Officer office & holding rooms as excluded areas to the definitions and List of Areas section of the Introduction.

Suggest office breakout should be primary space however. GBCA to update the guidance section and List of Areas for

primary, secondary and tertiary spaces.

Consider adding points for daylight to platform (in addition to concourse) as this should be achievable in shallow underground stations and greatly improves quality of experience.

The GBCA recommends project teams target this as an innovation.

Daylight - Classification "high levels of daylight" for an underground station should be reviewed. The ability to bring light into concourse versus entrances are very different and should not be rewarded with the same point. Entrances: 160Lux aligns with general illuminance best practice levels - OK Concourse: 40-100 Lux aligns with the general illuminance Ramps, walkways and platforms from AS 1680 and MCST standard (no value provided for concourses) - Therefore a DF of 2 or 160 Lux exceeds the best practice lighting levels recommended by Credit 15.1.

The GBCA will review existing criteria for the various functional spaces of underground stations and provide further information within the guidance section of the credit.

Additional notes: concourses can be more than 10m below ground level. Even with large open skylights in some areas a DF of 2 cannot be achieved (especially with the glass required for security and safety and corresponding VLT). Skylights to concourse areas are often removed where their outputs cannot be 'justified' as they do not achieve a Green Star point, hence these high levels does not encourage daylight intrusion to below ground station areas.

The GBCA notes, that this credit may not be achievable for deeper underground stations.


16.2 Views Internal Views definition altered to no longer include a view to an area with frequent movement of people. This alteration would not encourage underground station to include windows from staff areas to patron areas. Underground landscaped areas or water features are extremely difficult to maintain and atriums in the design may be not possible due to the above street geometry. Highly recommended to include "frequent movement of people" back into the definition.

GBCA to update definitions section of the credit to include “frequent movement of people”

17 Indoor Pollutants

Entire Credit No feedback provided

18 Thermal Comfort

18.1 Staff Thermal Comfort

1) Flexibility for station designers / providers should be given so that 'down' stations be very simple and 'up' stations have more comfort design features. This is common for most suburban and regional train facilities. One problem that can occur is that a down station takes budget from an up station when the down station is very likely to have a small number of waiting patrons. E.g. the station is used 90% for alighting patrons. 2) Should Zone 8 be exempt considering stations are underground with more stable temperature surroundings? 3) Suggest facade be changed to glazing as much of the glazing could be roof glazing. Facades may not be applicable to many underground stations E.g. Parliament, Flagstaff in Melbourne 4) This wording is written for above ground buildings. Perimeter zones would very likely not be more critical than other zones in below ground station

1) The GBCA notes that thermal comfort requirements may conflict with other sustainability and investment drivers. The GBCA will provide guidance for pedestrian modelling and its interaction with thermal comfort requirements.

2) Zone 8 climate zones will be limited in scope of railway stations. A technical question should be lodged for a project specific response

3) The terminology of ‘façade’ will be amended to ‘glazing.’

4) Noted. No action required.


18.2 Patron Thermal Comfort - Above ground stations

Moving from 2 % for 95% of daylight hours to 10% from afternoon peak periods... What is the logic behind this? Suggest a performance solution alternative be developed for this credit. Station providers will almost definitely do population modelling on the station use. E.g. at full function we anticipate x patrons at 9am, 10am, 11am etc. Points are awarded if there is sufficient shade (2m2 per person) based on the user frequency modelling (modelling must take into account population growth) Above ground stations - Consider increasing windbreak percentage. Shelter from wind greatly increases quality of experience and comfort across a broader range of weather conditions. Windbreak increased to cover 10% of above ground platforms (from 2%). Note this may conflict with CPTED requirements. Platform orientations are generally set prior to Green Star inclusion. Achievability to be reviewed if prevailing wind direction limits achievability

The GBCA clarifies the afternoon peak was emphasised to promote afternoon shading solutions for waiting areas. Wind Breaks The GBCA notes that thermal comfort requirements may conflict with other sustainability and investment drivers. The GBCA will provide guidance for population modelling and its interaction with thermal comfort requirements.

18.2 Patron Thermal Comfort - Underground stations

Underground Stations - Consider whether absolute compliance with a set temperature range is appropriate i.e. Dry bulb temperature must be between 20 - 24 deg C. Consider passengers will 'dress for the weather' and are unlikely to change during their journey.

Noted. The GBCA recommends a project specific technical question where a different temperature band is recommended.


Innovation Innovation challenge added to provide protection from inclement weather. Radiant heating of outdoor areas - commuting patrons will be dressed for outside weather conditions - Innovation does not encourage sustainability practices - The radiant heating could be turned on for extensive periods with no one on the platforms 1) Wet bulb temperature? Did you mean dry bulb temperature? 2) Potentially a lot of area to heat - may be energy intensive and counter to the proposed innovation. Consider removing this as an innovation strategy.

The GBCA will review the credit prior to release, and will provide further detail about requirements around the radiant heating systems to be controlled via timers. Guidance will also be provided about it interaction with the Greenhouse Gas Emissions credit. The innovation for radiant heating is included as an incentive to reduce car use and is therefore considered sustainable when viewed in this broader context. Wet bulb temperature was intended in order to replicate outdoor weather conditions.

Energy Section Stakeholder comment GBCA response

19 Greenhouse Gas Emissions

Entire credit Perhaps acknowledge that Class will almost invariably be 9b with potential of 5 and maybe some retail.

Noted, the GBCA will amend the applicable classes within the credit


19A Greenhouse Gas Emissions Reduction – Prescriptive Pathway

A question we have for this and D&AB tool is if the prescriptive pathway is chosen, how does the team calculate the electricity consumption. They really have to do 19B then to get the Green Power points for 19A. I'd suggest a way around this is to add up kW ratings of all lights and HVAC and 25% or 50% of that multiplied by 3000 hours is the annual electricity consumption Also suggest that on site solar contribution also be given points here. E.g. 20% contribution 1 point up to 100% contribution 5 points. For solar kW rating can be % of kW of power draw for lighting and HVAC under certain size station

The contract needs to stipulate that a percentage will be procured for a minimum amount of time. The contract percentage is for supply, not based on estimated demand, therefore energy does not need to be modelled. On-site solar contribution is available to projects pursuing the prescriptive pathway as innovation. Up to 2 points can be claimed. Project teams will need to demonstrate their approach to energy calculations for approval via a technical question. GreenPower is included to encourage broader market transformation and linked to a strategic goal of the GBCA, where we are investing in resilient and renewable energy infrastructure in Australia. We acknowledge that having onsite renewable energy is a good outcome – however, we need to keep this equitable to the overall Green Star rating tools – where installing onsite renewables may not be the best outcome for that particular building type. As such, we will maintain the innovation points for onsite renewables, but not include it as a general requirement.

Solar options for stations are quite abundant (large roof or canopy spaces) and will likely be taken up. On most smaller projects the roof space to power usage requirements would be much greater than conventional building projects. In this Railway Stations tool if no energy modelling is being undertaken the maximum innovation for renewable energy is 2 points. Whereas, the purchase of Green Power is up to 5 points. Suggest there could be a re-thinking of the credit where a DTS calc could be implemented for renewable energy. For example, if the renewable energy power rating exceeds the lighting and HVAC power ratings by 50%, then 5 points is achieved and points are reduced in proportion to this benchmark

Refer above.


The problem with the deemed-to-satisfy solution is that to claim renewable energy or green power the 19B calculation needs to be undertaken. So, if 19B needs to be done to claim this, why is green power an option for 19A? Assuming that the reason most projects would undertake the 19A path is to avoid doing the modelling required for 19B

Refer above.

19B Reference Building Pathway

We will soon be putting in a technical question regarding the fresh air requirements for the reference building for the project. The NCC requirements for fresh air are 5 times lower than the requirements. We suggest the fresh air requirements benchmark should be changed to minimum requirements for underground stations.

No current action. The GBCA notes that where project specific technical questions can be applied to all projects, these will be issued as FAQs available to all project teams using this rating tool.

For the GHG emissions reduction credit the proposed building is measured against a Reference Building. The definition of a Reference Building is in compliance with minimum NCC Section J requirements, however this is not realistic for underground stations given the length of duct and pipe runs and high critical equipment loads, which result in fan and pump powers much greater than would be found in a typical building. The NCC is tailored around above ground buildings as opposed to underground stations and therefore a different approach should be used for define BAU systems, whether it's a reference design or standard motor/equipment efficiencies.

Where items outlined in the reference case are inappropriate to underground (or other) stations, the reference case may be modified through a technical question, as noted in the Greenhouse Gas Emissions Calculator guide.

19B Reference Building Pathway

A 20% reduction in total energy consumption cannot be achieved in most Australian climates through building fabric alterations. 30-40% of total energy usually attributed to heating and cooling (even less for above ground rail which usually has limited conditioned areas) - building fabric can impact heating and cooling loads but not to contribute to a 20% reduction to the total energy usage. Would be interested in a case study to demonstrate how this would be achieved?

Noted. Where items outlined in the reference case are inappropriate to underground (or other) stations, the reference case may be modified through a technical question, as noted in the Greenhouse Gas Emissions Calculator guide. The GBCA recommends the use of the Prescriptive pathway for projects with non-complex building systems.


The lift energy calculations required by the energy modelling guide need to be revised – particularly for the reference building. Currently the equation used to determine reference lift motor power is underestimating motor size, therefore resulting in much lower energy use when compared to actual motor sizes for the proposed building – even when applying factors such as standby, power off and regenerative brakes. When discussing with Vertical Transport Engineers about the calculated reference motor size they have expressed concern that calculated reference size is far lower than would ever be selected by themselves during design, or by contractors.

Where items outlined in the reference case are inappropriate to underground (or other) stations, the reference case may be modified through a technical question, as noted in the Greenhouse Gas Emissions Calculator guide.

Innovation It appears the Onsite Renewable Energy Innovation values have changed from 5% to 15% for 1 point and 10% to 30% for 2 points?

This is in line with the new Innovation challenge.

Difficulty of achieving the Renewable Energy Innovation challenge has increased from 5% to 15% for 1 point. The onsite renewable energy target is very difficult to achieve for below ground stations with a minimal above ground footprint. Consider, adding a separate target for above/ below ground stations.

Noted. However, the current approach is in line with D&AB v1.2. I.e. buildings with a small footprint may not be able to achieve these Innovation points. The current approach is in line with the GBCA's carbon positive roadmap and underwent significant consultation. It is noted that this is an innovation opportunity and should not be viewed as a necessary element to achieving Green Star certification for underground railway stations.

General Conditional requirements now added to for 5 and 6 Star ratings with minimum performance requirements. Relevant version of the NCC to be used. How will the credit adapt to the 2019 NCC update? Intent of stipulating minimum GHG points is good, but considerations will need to be added of how this impacts projects complying with the 2019 version of the NCC. Significant changes with the lighting levels proposed which will greatly impact the reduction levels achievable. Should be considered in making 6 points a minimum requirement to achieve a 6 star rating and 30% reduction LPD a minimum for the prescriptive pathway.

GBCA has been reviewing the proposed changes to the National Construction Code and their impact to Green Star – Design & As Built. While we are supportive of the proposed changes and the increase in stringency, we have identified that the impacts to the rating tool are significant and are looking to provide certainty to those that may be impacted beginning from next year. This is part of a broader piece of work the GBCA is undertaking in regards to the anticipated updates to the NCC.


20 Peak Electricity Demand Reduction

Entire Credit Suggest including query relating to lift energy calculation (will also impact GHG credit), as lifts represent a significant portion of site peak electrical loads at railway stations.

Where items outlined in the reference case are inappropriate to stations, the reference case may be modified through a technical question, as noted in the Greenhouse Gas Emissions Calculator guide. This guidance will be added to the Submission Guidelines.

Transport Section Stakeholder comment GBCA response 21 Sustainable Transport

21.1 Intermodal Connectivity

Based on calculations undertaken for stations in CBD we have found this calculation methodology does not necessarily award best practice for densely populated areas with an abundance of public transport. We have had discussions with the GBCA regarding this and still advocate that having over a certain number of transport routes within 400mm should automatically get full points. Much like the old public transport calculator in Office Design V2.

The 'proximity to CBD' definition was added to credit, which awards points based on postcode. The GBCA acknowledge that this was omitted from the draft submission guidelines.

The intermodal connectivity credit calculation methodology can be inconsistent in rewarding best practice for dense and semi-dense built areas / populations. It is again strongly suggested that the calculation be simplified, to be only number and frequency of public transport routes within walking distance to the station.

As above.


Calculation method and distribution of points should be reconsidered for highly urbanised areas where there are a high number of services. Assessment of what constitutes accessible in the sustainable transport credit is not realistic for central city locations. The definition of 'near the train station' means the number of transport routes picked up in this calculation far exceeds those that pass close enough to have a stop within 400m. Especially when there is a significant distance between train stations as this expands the 'near' category far further than what would be considered near. This is still the case even if the station location is realistically 'near' to multiple public transport routes.

As above

Just wondering what the logic is for having different distance requirements for above ground and underground stations? Also, I would suggest that escalators and travelators not be included in the 400m distance measurement.

The separation is tied to the calculation of the distance. For underground, escalators are excluded, as the measurement point is the entry/exit of the station.

21.2 Reduced Car Parking Provision

"For suburban stations 1 point is available where either: -Future provision for car parking for the project's users has been increased by at least 50% above the required 'Day One' car parking; or -For brownfield redevelopments, the number of car parks has not decreased from prior to redevelopment" Incentives to reduce car dependency through reduction of car parking and prioritising other modes would support more sustainable transport modes, and support opportunities for a higher quality urban design solution. Suggest adoption of requirement for 'urban stations' i.e. no net increase (unless this is covered by the 'Innovation' clause?).

Noted. The intent of the credit is reduce single car use and encourage the use of rail transportation by providing facilities for patrons at suburban stations.


21.4 Active Transport Facilities

May only apply to Victoria but note that Parkiteer bike cages come in standard sizes, therefore projects either provide standard with no increase (and don't target credit), or increase by 100% if area is available. Consider inclusion of 100% increase in Innovation list for improving on Green Star Benchmarks

The GBCA confirms that Parkiteer bike cages are specific to Victoria. The provision of these cages will not result in Innovation points.

Review Active Transport criteria and guidance - Credit criteria does not correlate with credit guidance - Credit only award points for patron bicycle parking - The guidance reference staff bicycle parking and changing facilities but no mention on number of parks required or points awarded for it. - comment on page 200 'Staff rates and numbers of required amenities are to be confirmed' - Recommendation: either award points for providing staff bicycle parking or remove guidance for staff bicycle facilities

The GBCA will amend and clarify the credit criteria to include staff bicycle parking.

Review bike parking facilities location distance requirements to be in line with the Sydney Metro tool. The requirement to have bicycle parking 50m from and entrance and 30m from a bicycle path is very restrictive. Recommended that this will be updated to reflect the Sydney Metro tool as below: Bike parking: when facilities are >50m <150m away from station entry, they can still meet credit if they are one or more of the following: - Within 30m of bicycle path - Be situated to minimise conflicts between pedestrians and cyclists - In areas with good passive surveillance

The GBCA acknowledge that this omitted from the draft submission guidelines, and will include additional guidance for facilities between 50m and 150m from station entry.


One major issue - as is the case for our "day one" provision provided by TFV, is the quality of the information behind the day one provision figure. This should increasingly be better informed and more onerous (25% of very small in the past still = very small and insignificant in international best practice context). Bicycle Network Parkiteers have in the past come as a "standard" type blue cage, with provision for 26 spaces but recent cage parking has been bespoke, so there is flexibility with number of spaces, which should really be the case (based on future mode split). Other issues: • secure parking is not always the best option to provide bicycle parking. Recent experience would suggest cages are less used than bicycle rails and this comes down to a number of factors, including position (of cages/rails) and security (linked to position, footfall with service frequency, surrounding land uses and passive surveillance). So I would recommend that the bicycle parking component consider what is suitable to the context and bicycle parking rather than specifically just cages. • Provision versus outcome. Is it good enough just to measure provision of an asset, or will the effectiveness be the measure? Could existing and outcome mode splits (% patrons cycling to station) be measured instead? Or at least, could utilisation of BPD be measured? • Linked to the above, could the criteria include not just provision of the "hard" infrastructure but also the "soft" infrastructure eg promotion of bicycle parking and facilities (e.g. new paths/bike lanes) provided as part project? The change moment is only really capitalised on if both components are delivered. Timing is also key - can something from the tool drive contractors to deliver the active transport infrastructure earlier (rather than late, when

It is acknowledged that the quality of information behind ‘day one’ provision may not drive international best practice outcomes and the uptake of bicycle usage. The GBCA recommends project teams to submit technical questions regarding the delivery of secure bicycle parking infrastructure based of performance metrics, context or timing provisions. The GBCA will adopt the Innovation guidance from the Green Star - Communities Sustainable Transport and Movement credit, which incentivises future planning solutions and associated infrastructure.


station users have established the habit of driving to the new station)?

Showers and Changing Amenities for Staff - "Showers cannot be located within a toilet or disabled bathroom facility". Intent of this is understood, however for small stations with very few staff members (for example the 'Host station' classification used by Public Transport Victoria) providing separate facilities when the station generally has 1-2 staff members present at a time is excessive and some stations may therefore be precluded from this point.

Guidance will be provided for small stations with few staff members to include shared facilities.

21.5 Walkable Neighbourhoods

"21.5 Walkable Neighbourhoods - 1 point is available where either; The project is located conveniently to amenities The project achieves a specified walk score." Acknowledgement is required that railway stations are often catalytic, forward thinking projects that 'arrive first' and therefore should be encouraged to provide not only for day-one scenarios but also short and long-term scenarios Consider adding rating for acknowledgement and anticipation of integration into a planned urban intensification, or adding the catalyst for a neighbourhood to become walkable. Consider adding rating for supporting modal shift. For example adaptable car parking areas when urban intensification supports alternate modes. Locating car parking to ensure day-one development opportunities can create support a high quality station environment.

The GBCA acknowledges that for greenfield projects, points are awarded on the basis that the As Built rating is for when the station is complete for this pathway. The GBCA will adopt the Innovation guidance from the Green Star - Communities Sustainable Transport and Movement credit, and create connections between other sections of the rating tool including the Urban Precincts credit.

Walkable Neighbourhoods credit looks at whether the train station is close to amenities or achieves a certain walk score. This precludes greenfield developments which are providing train connections to growth areas for the first time. Suggest noting that amenities marked in masterplans may be able to be included in this calculation.

As above.


Innovation Innovation challenge added for not providing new car parks. This is typically not up to the project team and the credit criteria already awards N/A for not providing any carparks

The GBCA will include this innovation challenge for any project teams or stakeholders that do have the ability to influence this outcome.

Water Section Stakeholder comment GBCA response

22 Potable Water

Entire credit The calculator still needs to be adjusted to include public toilet use. This is a huge potable water consumption element that is missing from the performance pathway. Drought tolerant landscaping should also be recognised.

The GBCA will review the occupancy profiles required for the modelled pathway, as well as the mechanics of the Potable Water calculator and calculator guide. Drought tolerant landscaping is currently captured by through the selection of crop coefficient

The potable water calculator for the custom tool appear to be derived from the office tool and assume unrealistically high usage rates for fixtures and fittings. The calculator assumes a proportion of the total number of Patrons will use the amenities regardless of the number of actual fixtures in the station, which dramatically overestimate the amenities water use. This calculation should be based on first principles and calculate usage based on the number of fixtures and fittings and a public space realistic usage rate.

The GBCA will make amendments to the Potable Water Calculator to include a manual entry for the 'number of public uses per year' for toilets, urinals and tabs as manually determined by the project hydraulic engineer. This figure is then used to determine the water consumption by public bathroom usage, and added to the existing calculations. The Potable Water Calculator Guide will also be amended to reflect the changes to the calculator.

22B Update credit requirement to state Prescriptive up to 6 points out of 10 available (not 12).

The GBCA will amend in the final version of the rating tool.


22B.2 Rainwater reuse is usually not viable for underground stations due to the smaller catchment area. GFA of stations are usually very high meaning that the prescriptive tanks size mandated do not align with the consumption levels or available catchment. Suggest an NA option when catchment area is below a certain threshold. And/or change the credit to be awarded when a certain % of non-potable water demand is met through on site supply (i.e. could be rainwater of stormwater).

This criteria will not be considered ‘not applicable’ for underground stations The GBCA recommends submitting a project specific technical question to demonstrate an alternate compliance method or size of tank. The GBCA also notes that the performance pathway uses are more holistic view of rainwater tank sizing.

22B.5 Isolation valves on sprinklers for 'floor-by-floor' testing, more applicable to a multi-storey building. Stations usually have limited levels. Should be reviewed to confirm the outcome matches the intent

Where sprinkler systems are installed, each system must be fitted with isolation valves for testing. Guidance will be provided within credit criteria.

Materials Section Stakeholder comment GBCA response

23A Life Cycle Assessment

Entire credit New options available for additional points are good Up to 6 points and up to 4 additional points sounds like 10 points are available but only 7, slightly confusing.

No GBCA action. The change is intended to allow projects a pathway to more points because 3 operational energy use points have been removed in v1.2.

23B.1 Concrete

Entire credit New innovation - 2 additional points available for 80% reduction in Portland cement content. Good addition. This should be a sliding scale from 40-80% to encourage and reward all incremental improvements in Portland cement content.

Points achieved are not awarded on a sliding scale, however the GBCA will include a stepped point approach, where a 60% reduction will achieve 1 additional point, and an 80% reduction will achieve 2 additional points.

23B.2 Steel


23B.3 Building Reuse



23B.4 Asphalt

Entire credit Can R-07236 be considered, whilst removing reference to Vic Roads as an alternative compliance path?

Maximum recycled asphalt percentages outlined by the VicRoads specification, Section 407 – Hot Mix Asphalt to be included in the guidance section for projects in Victoria. A technical question is recommended to be submitted for projects located outside of Victoria.

"Asphalt which is pre existing in the complex and kept in the complex without removal" - having an asphalt crusher on site to enable "no removal" is difficult to achieve in urban settings due to other environmental and social considerations. Suggested that projects who utilise Recycled Asphalt Pavement (RAP) are able to achieve points under this credit. Suggest investigation into current practices that are combining RAP with a warm-mix - potential for this to become an 'exceeding benchmark' criteria.

As above

23B.5 Low-Maintenance Design

Entire credit. Suggest that maintenance requirements and agreements will/should be governed outside of green star.

Agreed. Maintenance requirements and agreements should be governed outside of Green Star. Green Star intends to reward sustainable practices. Green Star requires that project teams demonstrate that information is available and processes in place ensure proper operational care and maintenance is provided by staff. It does not prescribe or govern the processes themselves.

23B.5.3 "All Architectural finishes....are easily cleaned following graffiti.....and timber is avoided" Suggest avoiding reference to specific materials such as 'timber', to ensure high-quality design solutions can be explored which, if maintenance requirements can be met, will deliver high-quality experiences.

GBCA to remove references to specific materials.


23B.5.7 "23B.5.7 All glass accessible to patrons after-hours, or without good passive oversight by station staff, is a manufactured stock item, not custom made." Suggest avoiding prescriptive solutions to potential maintenance issues, to allow high-quality design solutions to be explored. Replacement and maintenance of glass will be governed by operational agreements and requirements outside of green star

As above.

23B.6 Structural Timber

Entire credit. Structural timber credit added giving more options to achieve the 5 points for the prescriptive pathway. Blast, impact and fire requirements for train stations may limit timber constructions, Not realistic for underground stations. Consider point to be N/A for below ground stations or would need to exclude structural components with overarching fire/impact/blast requirements from the % to be achievable.

This credit is not able to be claimed for underground stations.

Suggest having points available for designing a station structure that would support a timber Over Station Development. Stations designing for OSD need to increase their structure to support the potential structure above, this is generally assumed to be concrete. There is the potential to encourage the OSD to build timber through designing the structure to support timber construction only.

The GBCA recommends project teams to target this as an innovation point.

24 Responsible Building Materials

Entire credit No feedback provided.

25 Sustainable Products

Entire credit Please specify the benchmark for the percentage of compliant products in the credit criteria e.g. sliding scale where 1 point is 50% and 2 points are 100% compliant. "fitout works" needs to be defined more clearly for Station works.

The GBCA will include a scale outlining the award of points within the Sustainable Products credit.


2) The % points allocation should be presented in the credit. The only way to decipher this is to back calculate in the calculator. Percentages required for points should be detailed in the technical manual. Based on the calculator provided a Percentage Value of Complaint Products of 2% gives 1 point and 4% gives 2 points, the technical also states that the focus of the credit is on office fitout. Indicating that 2 points are awarded where the Percentage Value of Complaint Products of the relevant fitout items in the staff areas is 4%.

Refer to above.

26 Construction and Demolition Waste

Entire credit There's a definition for 'Excavation Waste' but no mention of this in the credit. The credit should outline what requirements relate to excavation waste.

Noted. The excavation waste will be added to the guidance section of the credit. Excavation waste is also captured in the ‘Sustainable Sites’ credit.

Land Use & Ecology Section Stakeholder comment GBCA response

27 Ecological Value


28 Sustainable Sites

28.2 Contamination and Hazardous Materials

When would this credit be NA? e.g. what if there are no existing buildings or structures and not contamination is found? Propose for NA criteria to be added.

The GBCA confirms that the Contamination and Hazardous Materials credit cannot be claimed not applicable on the basis that the scope of works includes any remediation and hazardous material removed at any stage of the project delivery.


29 Heat Island Effect

Credit scope Consider the exclusion of car parks for suburban stations from this calculation - these will be large areas of asphalt (and will be primarily covered with cars that we cannot control the colour of) and we are encouraging people to drive to train stations to then take public transport into the city.

The GBCA notes that car parks are a key contributor to heat island effect and as such, will remain in the credit criteria. The GBCA will include guidance on the treatment of carparks and underground access points in the project surface areas.

Good addition of entry and exit areas for below ground compliance. Further clarification required for 'Project surface areas' - How are entry and exit areas defined (especially for below ground stations)?

Project surface areas and boundaries will be defined and be consistent within the rating tool.

Emissions Section Stakeholder comment GBCA response 30 Stormwater

WSUD Engineering Procedures does not contain manual calculation guidance of how to model Petroleum Hydrocarbons or Free Oils. There is currently no real guidance in this manual as to how to achieve the targets for Petroleum Hydrocarbons and Free Oils.

The GBCA acknowledges the limited availability of information on hydrocarbons and free oils and will review the appropriateness in future Green Star rating tools. The GBCA recommends a project specific technical question to clarify the applicability of petroleum hydrocarbons and free oils for projects.

31 Light Pollution


32 Microbial Control


Entire credit Provide clarification on adiabatic chillers and where these sit under heat rejection. Should be included under waterless heat rejection as adiabatic chillers with air-cooled condensers have introduced an alternative to cooling towers that offers the potential for water-cooled performance from an air-cooled solution with no serious threat of Legionella contamination as adiabatic chillers produce smaller droplets of between 50 and 100 microns which cannot support the bacteria growth.

The GBCA acknowledges that the legionella risk associated with evaporative coolers is low, however, there is still a level of risk and as such cannot be excluded from this credit. The GBCA to provide guidance on which are considered ‘non water based.’

The Microbial Control credit is not achievable for almost all water based heat rejection systems as the premise of water based heat rejection is to reject heat to the air through evaporation, which requires an aerosol spray to be remotely effective. Therefore this credit should either be not achievable at all for water based systems or the 'no aerosol spray' requirement should be removed.

As above.

33 Refrigerant Impacts


Innovation Section Stakeholder comment GBCA response 34 Innovation

Improving on Green Star Benchmarks: Greenhouse Gas Emissions - the criteria here for onsite renewable energy conflicts with criteria listed in the actual credit. Refer to comment above against Credit 19B.

The GBCA will update innovation section for consistency.

Sustainable Transport - No new car parks on site should only be applicable to urban stations. Suburban stations will provide equivalent to before, if not increased car parking to encourage more patrons to park and travel into the CBD via public transport.



Sustainable products - it appears this is included in error? The percentage of compliant products increasing from 3% to 12% is not relevant to this tool. Also refer to comment under Credit 25 regarding percentages for this credit.


stakeholder feedback received€¦ · eligibility building type - not relevant to train stations?...

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