Proposed USGBC Credit Revision Would Weaken LEED’s Leadership on Forests |
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On February 22, the U.S. Green Building Council (USGBC) made public a third draft of its Forest Certification Benchmark and related changes to the LEED (Leadership in Energy and Environmental Design) credit for certified wood. The third round of public comment is open through March 14, and non-USGBC members are encouraged to provide their perspective. Also, USGBC members who plan to vote on the credit changes must first opt in to the consensus body and do so by March 19. We at the Forest Stewardship Council are deeply troubled by changes that have been made since the second draft, which itself was a significant reduction to the standards for certified wood set by USGBC and LEED 10 years ago. The current draft is clearly intended to lower the bar further, especially in areas of system governance and overall performance on key criteria of environmental and social responsibility. Such a backward move by the market-leading USGBC is both baffling and frustrating at a time when corporations and forest managers across North America are choosing higher standards for certification at an accelerating pace. The recent changes appear to be an effort to make possible the recognition of conventional industry-biased certification systems — those systems that do not have members and that are not open to the critical engagement of major environmental and social interests. The result of such one-dimensional governance models are forest management standards that lack performance measures, specificity and rigor in some of the most important issues affecting forests today. USGBC’s own studies, performed by Yale University’s School of Forestry, confirmed the wide gap in standards rigor between the multi-stakeholder based program (FSC) and those dominated by industry (a link to Yale’s standards matrix is here). Most notably, the third draft of the benchmark is weakened because it: - Allows a forest certification system to gain recognition in LEED simply by meeting the prerequisite criteria. The previous version required meeting the prerequisites and at least 40% of the optional criteria.
- Provides no details of the Conformance Assessment Process, which will judge the system’s performance to 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 certification. Why won’t USGBC commit to applying the same principled position with benchmark conformance?
- 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 that value honest multi-stakeholder approaches to standards setting. USGBC mistakenly characterizes these changes as “more performance based,” when they are exactly the opposite.
- 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).
We will make our detailed recommendations public in the coming days. In the meanwhile, FSC strongly requests all stakeholders in forest stewardship to speak out now about the deficiencies of the draft benchmark and the lack of a credible process for conformance assessment. USGBC and LEED’s reputation are at stake, not to mention the health and well-being of forests and forest communities around the world. A strong rebuke of the weakening of the certified wood credit is needed now. Without significant changes to the current proposal, FSC will be compelled to recommend a “NO” vote on the benchmark and related LEED credit revisions.
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