Yesterday I attended a great workshop on a new life cycle impact assessment ANSI standard currently in development. The LEED 2012 draft was discussed, and Brendan Owens (USGBC’s VP of LEED development) spoke about the new proposed MR credit on Non-Structural Materials Transparency, which is often referred to as the Environmental Product Declaration (EPD) credit. There’s been a lot of industry concern about this credit because it doesn’t require a product to actually be environmentally preferable – just for it to declare some or all of its environmental impact, and it’s possible for a product to get partial credit with no third party verification of the stated impacts. Furthermore, some types of third party certification gets double credit, even if that certification is meaningless. (Example: we all know SFI is worthless, but I think it would count for double credit. EPDs are justifiably complicated, so I may be misinterpreting.)
Yesterday I finally heard a good argument from Brendan on the EPD credit. He said something to the effect that this is a critical first step to growing a body of knowledge about environmental impacts that might lead to the creation of better third party certifications, and for extracting info that manufacturers currently refuse to disclose. Wouldn’t it be great if we had the equivalent of FSC for other materials?
Given that logic, it seems like this credit could potentially transform the market for product categories for which there is currently little information available. It’s less relevant, though, for areas where we already have robust, trustworthy certifications for environmentally preferable products. If I were rewriting this credit, I would exclude wood, bamboo, and other products that have the potential to FSC certify. That way we could push the rest of the industry forward without shooting ourselves in the foot on the wood issue.
Given the current weaknesses of the EPD credit, I am disappointed to see that it has up to two points available, whereas other credits that actually require environmental performance often have only one. (The transparency ideas in the EPD credit also overlap with the intent of a similar credit for raw materials, but that one also requires environmental performance.)
Any thoughts on this?
Tom Lent
Policy DirectorHealthy Building Network
152 thumbs up
September 2, 2011 - 2:24 pm
I think Mara's idea is intriguing and worth exploration. Focus the EPD credit on the areas where we need more information of the type that current LCAs can provide. Unless you can do a much more ambitious LCA of the type that SCS is proposing, and expand LCA into the land use/extraction issues it appears that LCA's aren't providing much useful differentiation between wood products and may be missing the most important differentiating impacts between wood and non-wood products.
I share the concern that the weighting feels high on this one - most particularly giving full value for a product with only a generic product family LCA. This gives full credit weight to a product whose environmental performance is not even disclosed yet, only its industry's average.
Tom Lent
Policy DirectorHealthy Building Network
152 thumbs up
September 7, 2011 - 12:47 pm
Can anyone clarify the difference between the upper two levels in the Non-Structural Materials Transparency credit? The three read as follows:
• Manufacturer declared LCA42 (contributing value = 0.5 x product cost)
• Third-party Certified Type III Environmental Product Declaration (EPD) based on Generic Product Family Product Category Rules (contributing value = 1.0 x product cost)
• Third-party Certified Type III EPD based on Product or Brand Specific Product Category Rules45 (contributing value = 2.0 x product cost)
Does this mean that a product gets full 1.0X credit if that manufacturer's industry has generated an industry average EPD? This has some hazardous unintended consequences. The industry could have a wide spread of performance and this would mean that the worst performing product in the industry can contribute toward a point in a project at full credit.
Tom Lent
Policy DirectorHealthy Building Network
152 thumbs up
September 8, 2011 - 2:24 am
Thanks to Steve Baer for clarifying the credit for us. He affirmed that my interpretation is correct. The 1X value Generic EPD credit is indeed for an assessment of an industry average for a product category and only the 2X value Product EPD credit is for an EPD of a specific manufacturer’s product or product line. He further explained that the USGBC has designed the credit to encourage transparency not performance but with hopes that worst performers will learn of their relative positions by participating in the study and be encouraged to improve and that a buyer will also be able to compare different product solutions, such as carpet to linoleum to ceramic for flooring.
I appreciate the potential value of EPDs (e.g., we need them to assess climate change impact of products and address the 2030 Product Challenge) but I have deep concerns about the Generic EPDs and the potential for the worst performers to use them for greenwash and to actually avoid pressure to improve. Specifically, I expect that:
a) Some worst performers will not participate (leaving the industry average looking better than it really is) but will try to take advantage of the easy credit for the industry EPD anyway.
b) Participants in the study will not necessarily learn about their individual performance and how to improve it.
c) Those that do find out (or even just suspect) that they are worst performers will have more incentive to just stick with the easy marketable full credit for the industry generic average (particularly if it makes them look better than a competing product type) rather than to do a product specific EPD that shows how much worse they are and could hurt sales.
Furthermore, comparing Generic industry average EPDs can be a very deceptive way of making a choice between product selections. Unless you know not only the industry averages but also the minimum and maximum and which manufacturer and products were included in the survey, there will be no way to know whether an apparent difference between product type averages (such as between linoleum and ceramic) is likely to play out in the actual purchase. And if the two different product type averages were done under different product category rules (likely) with different boundaries, then even with ranges the comparison between product types will not be meaningful. They will only be useful as benchmarks *within* their product category (to answer the question of whether a specific linoleum product is better than the average linoleum product) not between categories (linoleum versus ceramic).
This credit will require some careful thinking about rules for the PCRs and the industry studies to make the resulting generic EPDs comparable and greenwash resistant. Can they be made comparable across different product types and designed to avoid rewarding worst performers with lots of LEED credit with little incentive to improve? Frankly I'm still skeptical of whether the Generic product EPD can be made meaningful enough – with enough protections to avoid its use for greenwash - to warrant LEED credit. I suggest just sticking with one point for real product specific EPDs.
Lyle Axelarris
Civil Engineering Intern, LEED GADesign Alaska
26 thumbs up
September 12, 2011 - 4:33 pm
I agree whole-heartedly with Tom's concerns about generic EPDs. If the EPDs are not generated by independent (not industry-based) organizations, they are nothing more than greenwashing vehicles. We've already seen the timber industry's devious representation of the environmental benefits of current logging practices ("clearcuts create habitat"), and therefore they say "wood is good". If this becomes a credit, will we see the plastics, mining and agricultural industries try to out-greenwash each other in the construction of their respective generic EPDs? What incentive is there for industry-generated EPDs to be at all factual?