The LEED Certified Wood Credit, with its preference for FSC, has been a part of LEED since the beginning and has been one of the most important drivers for market transformation to sustainability in the forest products industry. For those of us interested in maintaining that driver, the most recent draft of LEED v4 presents a mixed picture, with both positive and problematic elements.
First, this draft retains exclusive recognition of FSC among forest certification systems. USGBC is to be strongly commended for maintaining its commitment to the leadership standard in forestry in the face of ongoing pressure from the mainstream forest products industry and its allies.
However, major portions of the MR section, including the principal credit affecting FSC-certified wood, has been rewritten, picking up elements of previous drafts but also venturing into new territory. The scope of change is surprising given USGBC’s stated wish to go to ballot in the summer of 2013 without making further substantive modifications (which would necessitate a sixth draft and comment period).
The problems with the current draft are substantial and should in fact require a sixth draft.
Positives:
1) FSC remains the only reference standard for new wood.
2) A placeholder remains for encouraging the development of FSC-style standards for non-bio-based materials.
3) The exemption from responsible extraction requirements for materials that are sourced locally (within 100 miles) in the previous draft, which created a loophole for concrete, has been removed.
4) Preliminary analysis suggests that many paths to achieving the performance-related point in the new “Building Product Disclosure and Optimization – Sourcing of Raw Materials” will need to include FSC-certified wood along with recycled-content materials, and that there will be an incentive to go beyond 50% of the wood being FSC-certified, rather that arbitrarily stop there, as some teams do currently.
Negatives:
1) FSC-certified products now qualify for only 1 point, and the award threshold is so high that projects are unlikely to earn it without also incorporating large quantities of recycled-content and/or reused products.
2) Because there are fewer points available overall (2 in the previous draft, 1 in the current) and reference to an audited checklist of the leading edge issues in the Framework for Responsible Mining has been eliminated, the incentive for developing FSC-style standards for non-bio-based materials is less powerful and specific than before.
3) FSC products, which meet a rigorous, multi-attribute performance standard with third-party auditing and chain of custody across the value chain, are weighted the same as products backed only by manufacturer claims for single environmental attributes like recycled content.
4) The new “Building Product Disclosure and Optimization” credits place as much emphasis on disclosure as on performance, awarding 1 point for products that have Environmental Product Declarations, 1point for products whose manufacturers develop Corporate Sustainability Reports that may or may not meaningfully address responsible materials extraction, and 1 point for products backed by Health Product Declarations. Half of the available points reward disclosure of certain environmental impacts related to products (no matter how bad the impacts are) rather than rewarding products that are verified as meeting high performance thresholds.
Tom Lent
Policy DirectorHealthy Building Network
152 thumbs up
November 27, 2012 - 9:43 pm
Good points Jason. Overall, though, I do support the separate crediting of disclosure and improvement (1 point for reporting, 1 product for better product performance). I know it may seem a bit strange to give points for disclosing how bad a product is, but given where we are in getting comparable information about products, rewarding disclosure is needed at this point to set the stage for informed selection. That is certainly the case in the material content and health realm. That said, I’ve got some concerns about how some of the disclosure credits are set up that I’ll cover in a separate new comment below.
I agree that that these credits are very point starved and products meeting high performance thresholds should be rewarded with more points than those simply disclosing. And the performance credits need to be a multi-point to reward improvement. There is no way to find the perfect single threshold for a credit like this.
Jason Grant
PrincipalJason Grant Consulting
LEEDuser Expert
164 thumbs up
November 27, 2012 - 10:23 pm
Thanks, Tom. I'm all for disclosure in the material content/health realm, and I am learning to live with LCA/EPDs, although I hope that the latter will evolve to become more forthright about their limitations.
I still don't see the value of disclosure in general and CSR reporting in particular when it comes to promoting responsible extraction/sourcing, though. I think it would be a lot more effective to use the two points available in this credit to promote ACTUAL responsible extraction/sourcing -- or at least definite progress in that direction -- as opposed to CSR reporting which at best appears scant on substance, and at worst is the wrong tool for the job.
I know focusing entirely on performance in the “Building Product Disclosure and Optimization – Sourcing of Raw Materials” credit would mess with the overall symmetry of the Building Disclosure and Optimization credits, but for crying out loud, it is ridiculous to shortchange market transformation for the sake of symmetry!
Tom Lent
Policy DirectorHealthy Building Network
152 thumbs up
November 27, 2012 - 11:46 pm
I agree Jason. While the disclosure-performance pairing works well for toxics, it is not at all clear that it works for extraction and the credit seems forced into the structure. For example for mineral extraction the credit doesn't have the disclosure-optimization symmetry. It has Option 1 reporting requirements for mineral extraction but no Option optimization path for demonstrating responsible mineral extraction/sourcing. But I've yet to see an example of truly responsible mineral extraction. If recycling is the only responsible way to get minerals, it raises the question of whether the CSR reporting on extraction through mining in Option 1 actually accomplishes the intent of informing product selection.
Jason Grant
PrincipalJason Grant Consulting
LEEDuser Expert
164 thumbs up
November 28, 2012 - 1:06 am
The Framework for Responsible Mining is the basis for the Initiative for Responsible Mining Assurance (IRMA) which wants to be the FSC for mining. True, it's not ready yet, but having talked to some of the key people, the main thing they need to move forward is a market driver. This credit in LEEDv4 should provide that driver. Instead, it is going to drive CSR reporting. How this will advance responsible mining is unclear.
Tom Lent
Policy DirectorHealthy Building Network
152 thumbs up
November 28, 2012 - 9:08 am
Thanks Jason. Looks like some real potential. For those watching this discussion: The Framework for Responsible Mining is described on its website as "a joint effort by NGOs, retailers, investors, insurers, and technical experts working in the minerals sector. It outlines environmental, human rights, and social issues associated with mining and mined products." and is described as "a working document intended to be used as expert guidance and to catalyze further debate and discussion among stakeholders interested in improving mining standards." Something we certainly need. http://www.frameworkforresponsiblemining.org/related.html
The Initiative for Responsible Mining Assurance (IRMA) is described on its website as "working to create a system that ensures that mining is consistent with healthy communities and environments, and that mine sites leave positive long-term legacies...establishing best practice standards that improve the environmental and social performance of mining operations, as well as a system to independently verify compliance with those standards." http://www.responsiblemining.net/
An interesting mix of NGO, community, mining company and labor groups have been involved. Sounds worthy of a deeper dive to see how it could work in the LEED sourcing credit.
We should not reward extractive resource use equally with recycling/reuse and truly sustainable renewable resource extraction (FSC and equivalent certified ag). But given that we are a long ways from a truly closed loop industry, rewarding improved extractive practices, while still giving them lower weight than the renewables/recycleds could do much to incentivize improvement of this very damaging industry.