Environmental Action 2016-2021 Strategy and Action Plan


The Property Council welcomes the City’s Environmental Action 2016-2021 Strategy and Action Plan. We have appreciated the opportunity to work with the City on its development through its External Reference Group. The City has a strong partnership with the property industry and the strategy reflects an understanding of the role and opportunity.

The Strategy continues the City’s environmental leadership and addresses the main issues facing Sydney as it endeavours to improve energy, water and waste efficiency, and cut greenhouse gas emissions. The Strategy leverages strengths and draws on learnings from the past eight years. We commend the approach to maintain and improve targets and to introduce clearer responsibilities and actions.

As recognised in the Strategy, the property industry has been a leading contributor to environmental improvements in Sydney and has already saved over 186Mt of emissions and delivered $28 billion in avoided energy bills

The property industry is committed to continuing to play a critical role in sustainability. The Better Buildings Partnership grouping of major commercial office owners is an example of this, delivering a 45% reduction in the members’ emissions over its first five years.

The Property Council has worked with other members of the Australian Sustainable Built Environment Council (ASBEC) on the pathway to zero carbon buildings by 2050. We support the findings that cost effective action across property could deliver a 23% reduction in emissions by 2030 and a 55% by 2050. These opportunities could deliver over $20 billion in financial savings by 2030.

There is still a lot of work to be done to deliver on our shared goals for Sydney, and our comments on the Strategy will focus on these areas.

Expectations for excellence in environmental performance in new buildings

The benchmarks outlined within the City of Sydney expectations for excellence in environmental performance in new buildings is of concern to industry. While we support the Green Star rating tools we do not support mandating the benchmarks listed. The Strategy identifies that these benchmarks constitute leading practice and encourages developers to discuss them with the City in the development proposal process.

While aspirational targets are valuable, the document could be interpreted by the City’s planners as mandating this performance as new minimum standards. The Property Council would not support these as mandated standards. We recommend that the City carefully rework this section and ensure that there is no explicit or implicit perception of mandatory standards in planning.

The gap between best practice and minimum standards is large. There is an opportunity to consider raising limited standards but also identifying targeted incentives to motivate and support higher performance.

Mid-tier buildings

As the City knows, the property industry is very diverse. While Sydney’s Premium and A Grade buildings are leading the way in environmental performance, mid-tier buildings are lagging. Owners of these grades of buildings are less likely to be members of industry associations such as the Property Council.

The City is uniquely positioned to facilitate advice and support to assist action in mid-tier buildings. Their access to data through rates enables the City to identify these building owners. We recommend that this segment of the market is prioritised in the City’s actions. While top tier properties will continue to focus on improving performance, the big gains have already been made. The success and learnings of the BBP can also be leveraged. We look forward to seeing the sector strategy once issued.

If you would like to discuss anything further, I can always be reached on (02) 9033 1907 or [email protected]


Yours sincerely,

Felicity Wilson

NSW Deputy Executive Director

Property Council of Australia