The Forest Stewardship Council
About UsNews / MediaFAQsRegional Standards CertifiersCertified CompaniesGreen Building MembershipDocumentsFSC International Product SearchMake a DonationSite MapContact Us
About Us

Also in this section:

Design & Build with FSC:

USGBC and 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

Background on USGBC and LEED benchmark

Legal Attack by Conventional Industry

FSC in North America

(2009) USGBC Comment Period on LEED benchmark

(2008) FSC-US Comments on LEED Benchmark

Learn more about LEED

FAQs about FSC and LEED

 

Failings of the Third Draft of USGBC’s Forest Certification Benchmark

We at the Forest Stewardship Council-US would like to see USGBC complete and approve a strong benchmark and related MRc7 credit revisions that encourage forest managers to reach beyond status quo, simply legal forestry. While the second draft of the Forest Certification Benchmark, released last fall, strengthened the benchmark criteria, the third draft, released on February 22nd, takes several frustrating steps backward. If this draft does not change, FSC-US would be forced to recommend a “NO” vote on the benchmark and proposed changes to the MRc7 credit. Below, we identify the major failings in the benchmark.

To appreciate how the draft benchmark would function, it helps to know how far apart the various forest certification systems are in standards rigor and system governance. USGBC’s own studies, conducted by Yale University’s School of Forestry, confirmed the wide gap between the multi-stakeholder based program (FSC) and those dominated by industry (a link to Yale’s summary standards comparison matrix is here). Based on our own assessment of the current benchmark draft, FSC’s international system meets all of the draft prerequisite criteria and 23 of 31 (74%) of the optional credits. It is not an understatement to say that the draft benchmark (with recognition possible by simply meeting the prerequisite criteria) would be a significant reduction of USGBC’s current definition of exemplary forestry in the MRc7. And even though we are not aware of any other system that can meet the current prerequisite criteria, it seems USGBC is forsaking crucial governance and standards substance criteria to make such an outcome within reach.

The recent benchmark changes, coupled with the unwillingness of USGBC to define a credible assessment process for evaluating forest certification systems to the benchmark, make the current credit revision proposal unacceptable. Most notably, the third draft of the benchmark is weakened because it:

  1. Allows a forest certification system to gain recognition in LEED simply by meeting the prerequisite criteria. Draft 2 required meeting the prerequisites and at least 40% of the optional credits. This change is a substantial lowering of the bar without any explanation. We strongly recommend that USGBC either revert back to the recognition thresholds set in the second draft of the benchmark or, better yet, require other key credits as mandatory, such as Gc1, Gc3, Gc5 (with original majority threshold), Gc7, Sc3, Sc5, Sc6, Sc7, Sc9, Sc10, Sc11, Sc15, Sc16 and Ac1.

  2. Provides no further details of the Conformance Assessment Process, which will judge the forest certification system’s performance to meet the benchmark. Even the relatively strong prerequisite criteria in the benchmark (e.g., Forest Extent, Forests of Special Conservation Value, and Protected Areas) may be rendered toothless in the face of a “flexible” assessment process that could allow systems with weak, aspirational standards on key issues to be considered compliant. As many green builders well know, USGBC doesn’t recognize project aspirations when it comes to achieving LEED green building certification. It demands performance. Shouldn’t USGBC commit to the same principled approach for benchmark conformance?

  3. Recognizes governance models that: 1) do not allow open membership, 2) can have decision-making governing boards that are appointed by special interests, and 3) only have to be “designed to provide” rather than require balanced decision-making. In particular, the language deleted in criterion Gp1 and Gp2 (since draft 2) ought to be completely unacceptable to those who value honest multi-stakeholder approaches to standards setting. USGBC mistakenly characterizes these changes as “more performance based,” when they are exactly the opposite.

  4. Still fails to make prerequisite critical protections for indigenous peoples (Sc15 and SC16) and public consultation requirements (Sc11); and has a disturbingly narrow definition of legality for non-certified materials (Cp4).