Hi folks,
I’m sorry to be so last minute with this. LEED v5’s second public comment period ends TOMORROW (Monday, Oct 28). As it currently stands, LEED has eliminated its preferential support for FSC over other forest certification programs and is silent on climate-smart forestry.
I’m hoping that the Climate Smart folks in this network can advise on how best to advocate for a change to address that shortfall. Here's what I've figured out so far (with help from friends, of course!)
On the FSC thing, we’ve been working on an in-depth analysis comparing FSC to SFI (and it’s global “parent”, PEFC). This report will drop in a few weeks. Unsurprisingly, we found many ways in which FSC goes a lot further in protecting forests and the communities that are affected by forestry than the other two programs.
There are four separate places where this issue shows up in the LEED v5 drafts:
1. O&M: Green Cleaning — janitorial paper can be either SFI or FSC. I commented on that here a few weeks ago, but I haven’t seen any responses to that comment.
The rest are BD&C credits:
2. Building Product Disclosure and Optimization: This is the credit with the big Multi-Attribute scoring matrix based on the Common Materials Framework. In the previous draft, FSC was given more credit than SFI. Now neither program is listed by name, but the wording suggests that they would qualify equally for points. This is still listed as a draft, and subject to change over time, so hopefully this can still be addressed with USGBC in the future.
3. Reduce Embodied Carbon: this is a missed opportunity, as it doesn’t include any guidance on ensuring that wood is sourced from operations that are carbon positive. At least it does include this important clarification: “Biogenic carbon may only be included for calculations that include C-stage emissions.”
4. Draft Innovation credit on Responsible Sourcing of Structural Materials is an update of the v4 Legal Wood pilot credit that treats FSC, SFI, and PEFC as all equal. This would be an important opportunity to elevate FSC as a big step above the others.
Innovation credits are not balloted, apparently. You can find the list of draft credits here, but there is no direct way to comment on any one of them. You can comment on the Project Priorities and Innovation credit and address this limitation.
There are two places you can comment on v5: USGBC’s credit library (you can leave public or private comments) and on BuildingGreen’s LEEDuser forums (public only).
If you have a suggestion or post a public comment that others can reinforce by replicating in their own comments, please share a note on that here. Now is the time to make sure LEED advances good forestry practices.
Residential requirements for ventilation in residential units, in this v5 proposed rating system, do not require ERV/HRVs and supply to all habitable spaces. This is an unfortunate and a missed opportunity. Standard new construction is tight enough to prevent sufficient makeup-air from a leaky facade or shared neightbor walls. DOE has published studies that trickle vents for makeup-air do not work. There are studies showing that without dedicated supply air (provided in an energy efficient manner with ERV/HRV) oxygen/carbon dioxide balance reaches unhealthy levels, and toxins are not removed. In pollution events such as wildfires, the only way to remove PM2.5 and other pollutants it to filter the incoming fresh air which you can only do with an ERV/HRV with MERV 13 or better filters. LEED should be the standard bearer of what is best, but still reasonable to achieve - so requiring dedicated makeup air to dwelling units (where we spend a lot of our time!) should be required.