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Design & Build with FSC:

FSC-US Comments to USGBC on LEED Benchmark

See Also

(2010 December) A Path Forward for Certified Wood in LEED

(2010 October) FSC urges vote of “Negative, with reason” to proposed LEED revisions

(2010 June) FSC-US Open Letter on Fourth Draft Benchmark

(2010 March) FSC-US Open Letter on Changes to LEED

(2010) Failings of the Third Draft of the Forest Certification Benchmark

(2009) USGBC Comment Period on LEED benchmark

(2008) FSC-US Comments on USGBC Forest Certification System Benchmark Proposal

Learn more about LEED

FAQs about FSC and LEED

 

September 7, 2008

Dear Mr. Fedrizzi,

We understand the US Green Building Council is reexamining how the LEED Green Building Rating System recognizes the use of certified wood. A proposal for assessing different forest certification schemes for qualification in the LEED system is currently open to public review and comment. Please know that FSC-US and our partners in forest stewardship have deep concerns with the proposed assessment tool.

In the attached document and our comments provided to your web-based system, we provide you with experienced guidance as to the critical components of an effective and credible forest certification system. The development and application of the benchmarks by USGBC has tremendous potential to affect the credibility of the LEED standard. The benchmarks also have the potential to significantly enhance or diminish the uptake of exemplary forest management practices in the US, Canada and worldwide.

In general, we support the benchmark approach as a transparent and effective mechanism to evaluate forest certification schemes and their capacity to meet USGBC objectives. Additionally, this is an opportunity to clarify the strengths and shortcomings of the different schemes. However, we believe that the current state of the benchmarks do not adequately differentiate between the certification schemes that demand truly exemplary forest management from those that certify conventional and sometimes destructive forest management. Our key concerns are:

  • The assessment process is, as of yet, undefined. There are no guidelines describing how the benchmarks will be applied and whether an evaluation of certification systems will be conducted by a balanced and skilled jury. We also do not know if all benchmarks are obligatory or if a scoring system is anticipated. This lack of definition makes detailed comments on the benchmarks secondary.
  • While some benchmarks are strong and assessable, others are quite ambiguous or set an unacceptably low bar for compliance. Additionally, fundamental aspects of exemplary forest management and Chain-of-Custody certification have been completely ignored.

We believe that high bar that LEED system has placed on forest certification has been a key underpinning to the integrity and credibility of the USGBC. We trust you will consider our comments in full and endeavor to improve the benchmarks and assessment process to accurately define and recognize exemplary forest management.

                                                                                                                                              

Thank you for your consideration,
Corey Brinkema, President