Assessing the new MR credits - #2 & 3

I find a lot to like in the new LEED MR Credits (MRc2, 3 & 4 Building product disclosure and optimization). The credits take new important steps to encourage EPR (Extended Producer Responsibility), responsibility for resource extraction practices, CSR reports (Corporate Social Responsibility), certification of the sustainability of agricultural based materials and content disclosure and toxics reduction. These begin to fill what have been some important gaps in LEED’s approach to materials. The Material Ingredients credit (MRc4) addressing content disclosure and toxics reduction represents a critical leap in forward LEED attention to health issues in materials. The USGBC deserves strong support for this important credit and will need reinforcement against the ongoing American Chemistry Council attacks on this point. That said there are many devils in the details, including some greenwash loopholes big enough to drive a project through and we need the USGBC to go further. I’ll cover my questions and suggestions for the #2 EPD and #3 Sourcing credits in this comment and follow up in the next day or so with a comment just on #4 the Material Ingredients credit MRc2 – EPDs: Option 1 Published EPD credits the industry average EPDs (1/2 credit for products that participate in an industry wide (generic) EPD) that look to me like a great opportunity for greenwash – with poor performing products being able to hide behind the industry average. Recommendation: Put a short one year limit on receiving the ½ credit for participation in the industry average EPD exercise. After that you’ve got to disclose the product specific EPD. I am also very concerned about whether PCRs for EPDs are being developed in a consistent fashion and are actually going to be comparable. I’d welcome commentary from others who are watching the PCR process development closer than I am. Option 2 Multi-Attribute Optimization gives credit for certifications that verify impact reduction below industry average in at least three of six EPD categories. More room for greenwash. This needs boundaries and more explicit guidance! A product could benchmark slightly below the industry average in three relatively inconsequential categories (where the industry has generally low impact already) and be a worst performer in the industry in the other three and still get the credit. Extended producer responsibility – I support the inclusion of this in LEED but think this would make more sense in MRc3, the sourcing of raw materials credit, as EPR is an important part of making recycling programs work. MRc3 - Sourcing of Raw Materials: Option 1 – raw material source and extraction reporting - Yes we need attention to environmental impacts of extraction operations and beyond, but there is much more room for greenwash here. This credit needs lots of work to insure that meaningful and applicable CSR reporting requirements are referenced. Recommendation: add specific language about what kinds of commitments are acceptable and about the applicable CSR formats. At minimum they should encompass consensus principles that have been developed. (i.e. the Framework for Responsible Mining). This credit could use more scrutiny from someone who knows a lot more about CSR reporting formats. Option 2 - leadership extraction practices: Keeps FSC only, and rewards recycled content, reuse, and certified biobased materials (but only with one program). I guess they haven’t been able to find any leadership in mining either. Suggestion: Stay firm on FSC! And add more agricultural standards to the mix for the biobased. Working Landscapes, Global Organic Textile Standard and even USDA Organic should be in the credit along with any other program that meets ISEAL or IFOAM standards. And lets include EPR here.