Forum discussion

Urgent: Stop LEED v5 from undermining forest protection

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.

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Mon, 10/28/2024 - 15:08

Thank you Nadav! Important call to action!! _ I posted a comment re:"Reduce Emboided Carbon"; and also one about ERV/HRV not being required for dwelling units.  Credit: Reduce Embodied Carbon Using wood as a biogenic carbon storing material, is not always climate positive! Current wood EPDs do not account for soil carbon, forestry practices, or harvesting practices. If wood is to be given counted as carbon storing - it must come from climate smart forestry, for which "FSC" is the best we have right now. More/better standards are also being developed and LEED should add require/reference them as soon as they are available. Fundamental Air Quality: BD+C New Construction:  
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.

Mon, 10/28/2024 - 15:11

Hi all, Regarding the public comment, USGBC is looking for comments on the changes that took place between the last draft and this draft – relevant for #2 and possibly #1 and #3? Nadav, are your topics #1 and #3 reflective of new changes? Do others in this list have recommended comments we should consider making TODAY? Regarding the BPDO credit, the reference to FSC comes in the resource pdf, not the credit language, which clearly states that the credit is only addressing legal wood not sustainably harvested wood. This is a major miss and should be addressed. LEED v5 MR credit BPDO - Additional Resources.pdf pages 2-3 Regarding draft innovation credits, I would encourage you to contact the relevant committees/TAGs directly. I can help get contact info if needed, but you may already know some of the members – full list of names here: USGBC LEED Committees | U.S. Green Building Council. Regarding Responsible Sourcing of Structural Materials, in my experience (which is limited) FSC is virtually unavailable in a consistent and reliable way for many types of mass timber products. Being able to lean on other options was the only opportunity to document a basic level of responsibility for mass timber construction. Have others fared better? Under the “legal wood” credit, 100% of wood had to demonstrate that it was “legal” using any of the listed certifications. This was an ACP, not an innovation credit that got you an extra point in the ID section. Now it is lumped with steel and concrete, with 50% of each material type needing to demonstrate compliance. I’m curious if any of you have had experience with achieving 50% Concrete Sustainability Council (CSC) certified and 50% Responsible Steel certified? Thanks, Mara Mara Baum​​​​ FAIA, LEED Fellow, WELL AP, EDAC PARTNER | ARCHITECTURE + SUSTAINABILITY MAIN 628.444.6130 DIRECT 415.503.5750 126 Post St, Suite 500 San Francisco , CA , 94108 [cid:image001.png@01DB290F.894DFF00] dialogdesign.ca [cid:image002.png@01DB290F.894DFF00] From: Nadav Malin

Mon, 10/28/2024 - 16:02

As the past-Chair of the MR TAG, I will jump into this thread...
  • Comment, comment, comment - USGBC has been clear that they don't want the public comment to be never ending (like in v4), so this may be your last chance to comment on the standard/credits. 
  • The intent is for BPDO Multi-Attribute Scoring Matrix to be in the reference guide, which gives USGBC more freedom to update and modify. As a TAG we are still working on the certifications that are included and their value. With a move to the 1/2/3 weightings nuance between the quality/criteria inherent to each certification is lost. This change is a result of the charge to make this credit 'simplier'. Personally, I don't love this and when the calculator is managing the values/math I don't believe it is acutally simplifing the credit.
  • The Pilot credit example (IN credit Responsible Sourcing of Structural Materials) was included in part to respond to comments about other BPDO criteria for structural products. The certifications are available in the market, but may be difficult to achieve in certain regions (including parts of the US), this is meant to be a market signal for steel/concrete/wood manufacturers. Also, by being a pilot credit it will be easier to incorporate this type of criteria in LEED v6. NOTE: Though not part of the standard so will not be voted on, the TAGs review the pilot credits annually and revise or close. As a pilot credit this can be revised more easily with criteria or thesholds changing, this is a good thing IMO. 
There are a number of Green Gurus on the TAGs and other Committees (e.g. LSC, DCCC). You can share your thoughts with us, but the best place to make an impact is through the official review comment channels.  I am not happy with everything in v5 public comment 2 draft, which is why I am encouraging you to comment. Silence is acceptance. 

Mon, 10/28/2024 - 16:07

Ditto to what Allison says – please do comment! Also, I am on the Resilience Working Group, so while I strongly encourage you to comment directly, you are also welcome to share your thoughts with me personally, mbaum@dialogdesign.ca. We are meeting Thursday at 8 am Pacific. Mara F

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