For this portion of the credit, the Baseline Documentation includes Industry Wide Type III EPDs

Reduction in Embodied Carbon
▪10% or greater reduction in Global Warming Potential (measured in kg of CO2 Eq) Impact Area
▪Baseline Documentation compared to Optimization Documentation

BUT this portion of the credit, does not include Industry Wide Type III EPDs as the baseline as indicated in the Table within the Credit 

Reduction in Embodied Carbon
▪20% or greater reduction in Global Warming Potential (measured in kg of CO2 Eq) Impact Area
▪Baseline Documentation compared to Optimization Documentation

AND 

▪5%or greater reduction in two additional impact categories
▪ Baseline Documentation compared to Optimization Documentation

Can Industry Wide Type III EPDs be the basis for the comparison - as many products do not have a former version of a Product Specific EPD available to complete this comparison. Further, the comparison has to be reviewed and verified by an independent party - why would this be the case, if all the EPD data is open source and available for review? 

Any insights would be greatly appreciated! Thanks very much.