In response to criticism of its new Certified Products pilot credit, USGBC appears to be sending the message that all pilot credits are experiments that will be modified before they are balloted, so people like me should provide constructive criticism instead of freaking out. This is an attempt to do just that.

The critical flaw that I see in the current credit structure is that it combines performance-based standards ("Certification Declarations") with disclosure tools ("LCA-Based Declarations"). These are fundamentally distinct and should be treated as complements rather than alternatives. Performance-based standards have minimum thresholds that must be exceeded to achieve certification, but they generally lack transparency. Disclosure tools assess and disclose environmental impacts, but they don't set performance standards of any kind.

Where high-bar performance standards for building materials exist, then there should be strong incentives to use products certified to these standards. Where such standards don't exist, LEED should drive their creation. Credits designed to reward the adoption and continuous progress of LCA tools should not undermine or dilute leadership standards. When it comes to wood, the answer is both FSC and LCA/EPDs, not either/or.

The current Certified Products credit is a step in the wrong direction. It inexplicably reduces forest certification to "single attribute certification" and dilutes it relative to other performance standards and EPDs. It makes FSC equivalent to industry-based forest certification systems with demonstrably lower standards. Given the history of the certified wood credit revision, this is indefensible, even in a pilot credit. The camel's nose is now under the tent, and no amount of hand-waving on the part of USGBC can disguise or negate this fact. The environmental community, committed sustainable design professionals, and others concerned about keeping the "L" in LEED are now on full alert - and are anxiously awaiting the release of the next iteration of LEED 2012.