I guess this debate has been going on for a while but I don't think the new "Timber Traceability" credit is a huge step forward for the environment. At the highest level, just getting people to follow the law doesn't seem like an accomplishment worthy of LEED credit -- you don't get pilot credits for meeting building code or ADA.
I also wonder whether the technology is mature enough to do this credit, because the approaches as described seem to range from available but insufficiently precise (but still counted, like wood anatomy - why is that?) to sufficiently precise but unavailable. From the writeup it seems they can (at best) detect the species and general location where wood comes from; none of them sound like they could tell the difference between a tree taken from a legal site and one of the same species from an illegal site nearby. Nor can they detect stolen lumber (which is another problem) unless the thief tries to mask the species or country of origin.
Perhaps the most irritating thing about this pilot credit is that this is yet another attempt to use USGBC to assert that FSC and SFI are equivalent (note that they are treated equivalently here). This is fairly misleading because they are asserting this equivalence with respect to wood from high-risk countries, but SFI only certifies wood from the US and Canada (neither are high risk countries), and relies on FSC and PEFC for certification of legality in other countries:
SFI Program Participants source 98% of their fiber from the United States and Canada where the threat of deforestation is not a risk. The other 2% comes from fiber that is certified to either the Forest Stewardship Council (FSC) or the Programme for the Endorsement of Forest Certification (PEFC). https://www.sfiprogram.org/marketrelevance/deforestation-illegallogging/
So USGBC is promoting SFI for something that SFI doesn't do, and actually uses FSC an PEFC to do for it. Where is the value in that for market participants?
Lastly, while illegal logging is a problem, that is only one aspect of unsustainable forestry. A lot of legal logging is totally unsustainable. You could buy plantation-grown wood grown on clear-cut old-growth forest from any number of countries and as long as the species and location match what was declared for that product, you'd be contributing to LEED credit. If it's not from a high-risk country, it doesn't even have to be FSC or SFI or PEFC certified. Or you could log irreplaceable old-growth forest -- as long as its legal in a low-risk country -- and contribute to this credit as long as you clearly state that you helped degrade the environment and that is borne out by the questionable testing protocols USGBC is endorsing here.
On the other hand, to be fair to the credit's authors who have done a service by compiling all the annexes and making a proposal here, illegal logging in high-risk countries is a real problem and it accelerates deforestation, biodiversity loss, and other problems. And if we are going to have standards for high-risk countries, we should have standards for low-risk countries and we should use the greater wealth in low-risk countries to develop good international protocols and technologies for stopping illegal logging. I'm glad the credit will raise the profile of a number of timber verification schemes, and hopefully increase their usage. And hopefully having some LEED project requesting lab testing will help make that service more available and less expensive over time.
Jason Grant
PrincipalJason Grant Consulting
LEEDuser Expert
164 thumbs up
April 4, 2019 - 12:23 pm
Hi Raphael -
You make many good and valid points, but as one of the credit's authors, I do think this pilot credit is important and worthwhile. Responding to your points:
At the highest level, just getting people to follow the law doesn't seem like an accomplishment worthy of LEED credit -- you don't get pilot credits for meeting building code or ADA.
Agreed, but LEED currently has no mechanism to effectively mitigate risk of illegal wood getting into LEED projects and this is an important goal. The Legal Wood Pilot credit contained very close to zero actionable guidance on how to avoid illegal wood. My hope is that if the approach taken in this credit is proven out, an improved version of it could become a LEED prerequisite for high risk wood (i.e. wood originating in countries where illegal logging is a serious problem). Using legal wood shouldn't be worthy of a point, but I would argue that going to exceptional lengths to avoid it, while contributing to the development of technologies and systems that hold promise for cracking down on illegal logging and the trade in illegal wood, is in fact worth rewarding.
I also wonder whether the technology is mature enough to do this credit, because the approaches as described seem to range from available but insufficiently precise (but still counted, like wood anatomy - why is that?) to sufficiently precise but unavailable.
The most advanced technology for determining wood origin is stable isotope analysis. It and other technologies that could help determine origin require a repository of reference data - samples of a given species from a given region that have been tested and can be used as the basis of comparison. Reference data exists for some species and geographies, but not for most. There are international efforts underway to develop this reference data and to make it publicly accessible (see for example the Global Timber Tracking Network). In my opinion, the single most important goal of this credit is to harness the power of LEED and the green building movement to drive the development of these technologies and the surrounding institutional infrastructure that will allow them to reach fruition. Technology is key because document- and auditing-based approaches (including forest certification systems and third-party legality verification systems) to controlling illegal logging and the laundering of illegal wood in the value chain are highly vulnerable to fraud and/or gaming.
A wood anatomy test could be valuable in some cases: there are occurrences of fraud where high- and low-risk species that look the same to the naked eye but can be distinguished under a microscope get mixed together and sold under the same trade name. For example, European Oak is a trade name that combines more than a dozen similar species growing across a very wide range from Western Europe to the Russian Far East (RFE). European Oak from France and Germany is very low risk, but Euro Oak from Romania and the RFE are quite risky. Euro Oak from both regions is purchases in large volumes and made into wood flooring by companies in China, and then sold all over the world. It is very easy to mix these species together and represent all of it as coming from low risk regions. A wood anatomy test would be a low cost way to detect this kind of fraud.
Your comments on SFI are spot on and suffice it to say that the ENGOs who worked on this did not have the last say on this one. SFI should not have been included, for the exact reasons you state here. We do support including both FSC and PEFC certification as additional measures to mitigate risk for wood from high risk countries, but this in no way should be construed to meain that they are equivalent in terms of sustainability performance. However, we do regard them as more or less equally effective - or ineffective - when it comes to illegal wood. Forest certification is relatively well equipped to detect illegal logging within certified forests because this is something that an annual audit can and should catch. Currently, though, these systems are not equipped to detect the mixing of illegal and legal wood in the supply chain. I won't go into all the reasons why here, but it is simply very difficult to do if a company is bent on cheating and if a company high up in the supply chain cheats, none of the downstream companies will be the wiser. I can't speak for PEFC, but I know that FSC is aware of this weakness and is working to address it by trying to incorporate the very technologies that this credit promotes.
Lastly, while illegal logging is a problem, that is only one aspect of unsustainable forestry.
Again, you're spot on. However, this credit is designed specifically to address the illegal logging problem, not to promote sustainable forestry - for now, I believe that LEED's recognition of FSC in the MR credits is the best way to do this.
Your last paragraph hits on many of the key objectives of the credit. I hope that what I've written above gives a fuller picture and helps you come around to seeing its value. We really need support for and participation in the pilot. Know of any potential projects??
Jason
Raphael Sperry
Associate Principal, Global Social Equity Skills LeaderArup
2 thumbs up
April 5, 2019 - 1:04 am
Thanks, Jason. You make some excellent points and it's much more clear to me now why this is a step forward and that it has value and the potential to address a serious environmental problem. I'll certainly consider it for projects with a lot of hardwood, especially tropical woods or "European Oak." I agree that it's an opportunity for projects with the resources to pursue LEED to help build a system that can eventually be much more comprehensive.
Leanne Conrad
Project ManagerEntuitive
19 thumbs up
January 28, 2022 - 2:54 pm
I have a project in BC where we are working directly with the lumber mill and loggers to build our heavy timber building. Our client and lumber partner are very interested in this pilot credit. Instead of conducitng expensive (and may not be available) DNA or Isotope Analysis, would it be acceptable to have the loggers take geo-tagged photos of the hand selected trees before they were cut down, have a forestry expert identify the species and provide a signed letter to confirm species and location of harvest? This way we would know the exact location of origin as well as an expert opinion on the species.