eTool Position Statement on Green Star Net Zero Label


eTool welcomes the initiative of the Green Building Council of Australia (GBCA) to introduce in 2016 a new label to recognise buildings that achieve ‘net zero’ impact in energy, carbon and water. The new ‘net zero’ label is a great initiative for developments in Australia, and it will help society to drive change and live in harmony with the planet.

We believe Life Cycle Assessment is the best means to document the true impact of construction and establish the achievement of impact neutrality. Only once you account for all impacts over the lifetime of the project can you have enough confidence to confirm net zero has been achieved.
eTool sees the wide spread use of LCA as a construction design tool as key to realising low impact buildings and a sustainable future. It is imperative that as LCA progresses to become a normal part of good building design and 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 the whole construction industry. eTool has always had a strong belief that sharing information, collaboration and united communications 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.


eTool recognises the need to quantify building environmental performance and set performance based target as announced by GBCA with the ‘net zero’ label.
eTool have conducted over 300 LCAs of building and infrastructure projects in Australia. Over 20 LCA studies have been completed as part of Green Star Materials Life Cycle Credit – modelled pathway. LCA studies were conducted either by eTool engineers or by ESD Consultancy firms using eToolLCD software in-house. We have discovered that the final environmental performance can vary substantially for the same Green Star rating depending on the credits utilised, noting not all credits will have a direct relationship with environmental impact reduction. Therefore we highlight the importance of using a quantitative method to measure and improve building life cycle performance.
As an example, eTool have completed the Materials Life Cycle Impacts credit for 6-star Green Star certified projects that had a greenhouse gas performance of less than 35% reduction when compared to the reference case. Such examples demonstrate the importance of aiming for net zero carbon performance when designing world best practice buildings.

In order to support and be constructive eTool has decided to publish and provide this Position Statement on the subject with the hope that it might be taken into account when the GBCA develop the new ‘net zero’ label guidelines.

About eTool

The driving motivation behind eTool is to improve the environmental and economic performance of the built form. To that end eTool has successfully provided Life Cycle Assessment (LCA) software and Life Cycle Design consultancy services to the building industry since 2010. eTool has completed more than 300 construction project LCAs in accordance with established standards for quantifying the environmental impact of the built form. Many of these projects have demonstrated net zero carbon outcomes. eTool’s project experience ranges from shop fit-outs to large scale commercial and infrastructure projects. Given our experience we are well-positioned to provide a constructive and qualified contribution to the discussion.
Our experience and expertise include:

  • Experience with green building rating schemes including Living Building Challenge, One Planet Living, Green Star, LEED, BREEAM, DGNB and more.
  • Completed over 20 EN15978 compliant LCAs for the Materials Life Cycle Impact credit in Green Star.
  • eToolLCD software is IMPACT compliant.
  • Zero Carbon Challenge: Selected by the South Australian Government to certify the shortlisted designs for this competition.
  • Over 300 LCAs of construction projects completed, many being net zero carbon.
  • International experience.
  • Alignment with international standards such as ISO, European standards and software certification standards.

eTool Position

We see the application of EN15978 compliant LCAs quantifying whole of life, whole of buildings impact assessment as the best means for projects to document the achievement of the new labels. With the continuing improvement in energy efficiency and the rise of renewable energy supply we see the inclusion of embodied impacts as critical for the net zero label. eTool believe that whole of building, whole of life LCA is essential for ensuring no perverse outcomes arise from decisions made based on the LCA study.

This methodology aligns well with the Green Star “Materials Life Cycle Impacts” credit which prescribes Cradle to grave as defined in EN 15978 including all life cycle stages and scenarios detailed. There are a number of opportunities to improve on this methodology which are outlined below.

True whole of building energy consumption:
eTool believe the minimum scope of EN15978 is somewhat curtailed in regards to operational energy consumption as it only considers building integrated equipment energy consumption.
Notable exclusions include:

  • Plug loads (such as office work stations)
  • Servers
  • UPS systems
  • 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:

  • Designs that focus on functionality thereby decreasing base loads per functional unit.
  • Fitting out buildings with high efficiency appliances (particularly easy to implement in residential developments).
  • Integrated fit-outs of office buildings with high efficiency equipment (in partnership with tenants).
  • Tenancy agreements that stipulate energy consumption limits.
  • Tenancy agreements that encourages high functional utilisation of the building.
  • Building integrated tools designed to encourage behavioural change such as:
    • Highly visible energy monitoring displays to recognise and reward low energy use.
    • Dashboards to educate building occupants where they stand versus average and good performance.

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

  • 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 recommends inclusion of the EN15978 optional energy modules to encompass all energy loads in the building. If the GBCA wanted to increase the scope to true whole of building whole of life it would be quite a straightforward clarification to stipulateEN15978 minimum scope in addition to other building energy loads.
Benefits and Loads Beyond the System Boundary – EN15978 Module D
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

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 unless the reasons for omission are clearly stated and justifiable. 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 overrewarded 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).

eTool 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).

Integrated design at schematic stage

Crucial to the achievement of carbon or other impact neutrality is the integration of LCA at the schematic design stage of a project and use of LCA throughout the design process so that the target is achievable.

Offer of Support

eTool are excited about the GBCA’s net zero label and the opportunities it presents and would like to support the initiative in the following ways:

  • Sharing our knowledge and experience in quantifying net zero outcomes.
  • Sharing our experience in overcoming methodology, technical, and communications challenges in the field of Life Cycle Impact Assessment within the construction sector.
  • Aiding the GBCA in assessing the risks associated with different methodologies that may be applied to the net zero label.
  • Providing the GBCA with a software company’s perspective on the proposed methodology and implementation of the net zero label.
  • Sharing our knowledge of similar international initiatives we are experienced in or involved with.
  • Aiding in the communication of the new label during roll out.
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  1. […] “Full Operational Net Zero Carbon champion” badge (including building-related and non-integrated building energy as per EN15978). More details in our Position Statement on Green Star Net Zero Label from 2016. […]

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