Guidance on USGBC Benchmark

Guidance on USGBC Benchmark

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What’s going on? USGBC is on the verge of compromising its credibility by establishing unacceptably low standards for wood and forests in LEED. For about two years, the LEED Certified Wood Credit (MR7 in LEED-NC) has been undergoing a process of revision. At the center of this process is the USGBC forest certification benchmark that, if the revision is approved, will be used to judge which forest certification systems are worthy of recognition under the Certified Wood Credit. The third draft of the benchmark and associated documents are now available for public comment. This draft represents a significant “lowering of the bar” relative to the previous version released in September ‘09, and urgent action is needed to persuade USGBC to return to a higher standard. If we are successful in this effort, the benchmark will be further revised and will go to a fourth round of public comment before being balloted. If we are unsuccessful, then the current version will be balloted and we must pull out the stops to persuade participating USGBC members to vote “NO”! Here are the crucial action steps we are asking you to take: 1) If you are a representative of a USGBC member organization, opt in to the consensus body that will eventually vote on this (DEADLINE MARCH 24) https://www.usgbc.org/Login.aspx?REFERRER=%2fDisplayPage.aspx%3fCMSPageID%3d2070 2) Pass it on - encourage others to opt in 3) Submit comments (DEADLINE MARCH 14) – see guidance and suggested ...

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What’s going on?
USGBC is on the verge of compromising its credibility by establishing unacceptably low
standards for wood and forests in LEED.
For about two years, the LEED Certified Wood Credit (MR7 in LEED-NC) has been
undergoing a process of revision. At the center of this process is the USGBC forest
certification benchmark that, if the revision is approved, will be used to judge which
forest certification systems are worthy of recognition under the Certified Wood Credit.
The third draft of the benchmark and associated documents are now available for public
comment. This draft represents a significant “lowering of the bar” relative to the
previous version released in September ‘09, and urgent action is needed to persuade
USGBC to return to a higher standard.
If we are successful in this effort, the benchmark will be further revised and will go to a
fourth round of public comment before being balloted. If we are unsuccessful, then the
current version will be balloted and we must pull out the stops to persuade
participating USGBC members to vote “NO”!
Here are the crucial action steps we are asking you to take:
1) If you are a representative of a USGBC member organization, opt in to the
consensus body that will eventually vote on this (DEADLINE MARCH 24)
https://www.usgbc.org/Login.aspx?REFERRER=%2fDisplayPage.aspx%3fCMS
PageID%3d2070
2) Pass it on - encourage others to opt in
3) Submit comments (DEADLINE MARCH 14) – see guidance and suggested
language at the end of this document
http://www.usgbc.org/LEED/LEEDDrafts/RatingSystemVersions.aspx?CMSPage
ID=1458
What’s at stake?
On the surface, this is a battle between competing forest certification systems:
principally, the Forest Stewardship Council (FSC), which is supported by most major
environmental groups and many in the green building movement as the highest standard
in forest certification, and the Sustainable Forestry Initiative (SFI), which is backed by
the mainstream timber industry and its trade associations.
What is really at stake, however, are fundamentally different approaches to forests
and forest management that are enshrined in the competing systems’ standards and
procedures (see article at this link for more background:
http://www.jasongrantconsulting.com/?attachment_id=187). At its lowest common
denominator, the SFI sanctions intensive and extensive industrial forestry at or barely
1 above the standard set by state or provincial law. By contrast, FSC imposes
environmental and social requirements that are well above the “floor” of law and tends to
1advance ecological alternatives to the industrial forestry paradigm.
In its public communications, SFI has argued repeatedly that a benchmark that denies it
recognition will unfairly discriminate against wood products grown and harvested “in our
backyard,” and that most FSC-certified products must be imported from overseas. SFI
and its allies argue further that FSC discriminates against small, family forest
landowners. Neither of these arguments stands up to scrutiny.
It is true that the 100+ million acres of forest that are currently certified to FSC standards
in the U.S. and Canada is only about a quarter of the area certified by SFI and its “sister
systems,” Canadian Standards Association and American Tree Farm System. However,
many tens of millions of acres of forest that are currently certified to SFI et al. and are
relatively well-managed could get FSC certified relatively quickly if SFI and its allies
were to end their embargo of FSC. This said, SFI’s core supporters and participants
include some of world’s largest timber companies that practice large-scale, intensive
industrial forestry that will never meet FSC’s high standards – and this is precisely the
sort of “forest management” that SFI wishes to see accepted by LEED.
As for the argument that FSC “discriminates” against family forest owners, in Wisconsin
in 2009, more than 2 million acres of forest land belonging to about 31,000 small
landowners achieved FSC certification under an approach called “group certification.”
And FSC-US just released a new Family Forest Standard that addresses the specific
challenges faced by smaller landowners.
The battle over the Certified Wood Credit is not about domestic vs. foreign wood, or
about large vs. small landowners. It is about high vs. low standards.
The stated intent of the Certified Wood Credit is “to encourage exemplary
environmentally and socially responsible forest management.” To fulfill this intent, the
USGBC benchmark must set a standard that drives true market transformation to
sustainability in the forest products industry. A low benchmark will undermine market
transformation and the credibility of USGBC.

1 As just one example of the differences, an empirical study of the rigor of FSC vs. SFI certification on over 250
million acres of forest land in Canada found that SFI audit teams…
• were on average 3 times smaller than FSC’s
• spent five-fold less time in the field on their audits
• identified only 2 non-conformances between the forest company’s operations and the SFI standard’s
requirements; in contrast, the average FSC audit team identified 23 non-conformances
 
2

WILL USGBC RECOGNIZE THIS AS “EXEMPLARY” FORESTRY? Large-scale clearcuts and
landslides on SFI-certified lands in Washington State, 2007 (Photo credit David Perry)

3
WILL USGBC RECOGNIZE THIS AS “EXEMPLARY” FORESTRY? Large-scale clearcuts and
heavy rutting on SFI-certified lands in Nova Scotia, 2009 (Photo credit Jamie Simpson)
What should I do?
USGBC recently adopted new rules for balloting changes to LEED. In the past, all
USGBC members were eligible to vote. Now, in order to be eligible, representatives of
USGBC member organizations must first opt in to a “consensus body” that will decide
the issue. So long as ONE person from a member organization has opted in, that’s
enough; having more won’t strengthen the organization’s vote. The deadline to opt in to
vote on the Certified Wood Credit revision is March 24 – OPT IN NOW!
http://www.usgbc.org/LEED/LEEDDrafts/RatingSystemVersions.aspx?CMSPageID=14
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The consensus body is divided into three voting categories: Producers (Contractors and
Builders); Users (Corporate, Institutional, Professional Firms, etc.); and General Interest
(everyone else, including Manufacturers, Distributors, NGOs, Trade Associations, etc). If
you are a USGBC member and fall in the Producer category, or if you know
someone in the Producer category who supports high standards for wood and
forests in LEED, it is particularly important that you join the consensus body.
After you have opted in and encouraged others to opt in, the next step is to submit
comments. The deadline for submitting comments is March 14. The key issues are
summarized below, and you will find detailed guidance on submitting comments to
USGBC near the bottom of this document.
http://www.usgbc.org/LEED/LEEDDrafts/RatingSystemVersions.aspx?CMSPageID=14
58
What are the key issues?
Following is a summary of the major problems with the current benchmark and related
documents:
 THE LOWERING OF THE THRESHOLD FOR MINIMUM RECOGNITION -
This version of the benchmark dramatically lowers the threshold for minimum
4 recognition for a forest certification system. In the last draft, a forest certification
system had to meet all of the benchmark’s mandatory prerequisites as well as
40% of the voluntary credits in order to achieve recognition. This version requires
that a forest certification system meet only the prerequisites, and this lowering of
the bar occurred without any explanation or justification. We are calling on
USGBC to redress this in one of two ways:
o EITHER convert certain voluntary credits into mandatory prerequisites
o OR go back to formulation of the second draft (all prerequisites + 40% of
credits)
 THE WEAKENING OF THE GOVERNANCE SECTION - This version of the
benchmark greatly weakened two crucial prerequisites and one voluntary credit in
the Governance section. This section of the benchmark is particularly critical for
defining a high standard for forest management as the governance of a forest
certification system – whether it is democratic and truly balanced between
environmental, social, and economic interests, or whether it is in fact controlled
and dominated by industry – winds up determining nearly everything else within
the system.
o With balanced and democratic governance, standards are likely to be
rigorous and prescriptive as opposed to loose and flexible. On-the-ground
outcomes will matter more than flowery words on paper; stakeholder input
on certification is more likely to be required and valued; etc.
o It is especially troubling that the weakened prerequisites removed the
prescriptive language that gave them “teeth” and now are limited to the
sort of vague and general language – subject to “flexible” interpretation –
that characterize weak forest certification systems like SFI.
 CONFORMANCE ASSESSMENT PROCESS - Once again, very little
information is provided about the Conformance Assessment Process (CAP) by
which forest certification systems will be judged against the benchmark. This is in
spite of the fact that numerous comments submitted in the last round called for the
CAP to be better defined and put out for public comment along with the rest of
the Certified Wood Credit revision. The CAP is as important as the benchmark
itself and absolutely requires stakeholder and USGBC member input before
the benchmark goes to ballot. Among other things, the following critical
questions related to the CAP need to be addressed:
o During and after their assessment of forest certification systems against
the benchmark, will the Independent Conformance Assessment Team take
input from other experts and stakeholders?

o Can a decision of the Conformance Assessment Team be appealed or
overruled by a higher USGBC body?
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o How will the members of the Team be chosen? What are the criteria for
the experts, e.g., what qualifications are required?

o Will the Team assess on-the-ground outcomes of the forest certification
systems as well as paper standards, i.e. will there be field audits?

o If forest certification systems recognize one another mutually, as happens
with SFI and CSA and American Tree Farm, then will all of those systems
be rated against the benchmark before any can be considered compliant?

 IGNORING PUBLIC COMMENTS FROM THE PREVIOUS ROUND – As is
evident given the volume of public comments from the last round and the limited
changes between this draft of the benchmark and the last, a great many comments
were passed over or ignored. As one example, the Alliance for Credible Forest
Certification (including Sierra Club, Greenpeace, ForestEthics, and others)
submitted nearly 10 pages of comments addressing 33 specific benchmarks, all of
which were ignored by USGBC in the current draft. This happened even though
the Alliance’s comments were supported by numerous USGBC Chapters and
other USGBC members. Among many other things, in ignoring these
comments, USGBC enshrined in the current benchmark a narrow definition
of illegal wood that is below the standard set by U.S. law!
How can I learn more?
Supporting documents can be found at this website:
http://www.jasongrantconsulting.com/?page_id=179
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Guidance for Submitting Comments

After logging in, you will be given the choice to submit comments on:

• Credit Revisions
• Benchmark Revisions
• General Comments

Credit Revisions

If you choose “Credit Revisions,” you are presented with two dialog boxes with the
following prompts:

• “Are the revisions to the credit(s) appropriate for high performance green
buildings? Please explain.” and

• “Do you have any suggestions on how to improve the technical requirements of
the credit(s)? Please explain.”

Suggested language for the first dialog box:

No. The minimum threshold for recognition of a forest certification scheme is too low for
high performance green buildings. Failure to address the inadequacy of the current
benchmarks seriously risks discrediting USGBC and belying LEED’s claim to being a
leadership standard. We will forcefully oppose the current benchmark. It is completely
unacceptable.

Suggested language for the second dialog box:

EITHER convert the following benchmarks that are currently voluntary credits into
mandatory prerequisites:

Gc1, Gc3, Gc5 (and changed back to require majority rule), Gc7, Sc3, Sc5, Sc6, Sc7,
Sc9, Sc10, Sc11, Sc15, Ac1

OR return to the minimum threshold established in the second draft of the benchmark:

All prerequisites plus 40% of voluntary credits must be met

Benchmark Revisions

If you choose “Benchmark Revisions,” you are given the opportunity to comment on the
following benchmarks:

• Gp1 (Governing Structure)
7 • Gp2 (Decision Making I)
• Gc5 (Decision Making II)
• Sp10 (Genetically-modified organisms I)
• Sp18 (Community benefit)

For each, you are presented with two dialog boxes with the following prompts:

• “Do you believe that the prerequisite/credits are appropriate for exemplary forest
certification (e.g. technical rigor, market usability, environmental performance?
Please explain.” and

• “Do you have any suggestions on how to improve the technical requirements of
the prerequisites or credits? Please explain, providing citations to data and
research where possible.”

Suggested language for the first dialog box for Gp1:

No. The language and requirements are insufficiently specific to ensure a balance of
interests and stakeholders.

Suggested language for the second dialog box for Gp1:

The following language is suggested: “The entity responsible for the Certification
scheme has governance structures that 1) balance the representation of social,
environmental and economic interests; and 2) allocate a maximum of 1/3 of all votes to
governmental or for-profit forest owners, producers, and other entities with a
commercial interest in the sale of forest products.”

* * *

Suggested language for the first dialog box for Gp2:

No. The language and requirements are insufficient to ensure a balance of interests and
stakeholders. As is consistent with USGBC’s own policies and practices, major changes
to core policies should be balloted to a certification scheme’s membership. Such major
changes should require majority approval at both the level of the governing body and the
membership.

Suggested language for the second dialog box for Gp2:

The following language is suggested: “The entity responsible for the certification scheme
has policies that 1) promote consensus-based decision-making; 2) require that major
changes to core policies be balloted to the membership; 3) require that balloted decisions
be approved by a majority of the representatives of environmental, social and economic
interests respectively at both the governing body and membership levels.”

8 * * *

Suggested language for the first dialog box for Gc5:

No. The language and requirements are insufficient to ensure a balance of interests and
stakeholders.

Suggested language for the second dialog box for Gc5:

EITHER this should retain its original language and be converted to a prerequisite, OR it
should be addressed as suggested in our comments to Gp2. The original language is as
follows: “The entity responsible for the certification scheme requires that balloted
decisions be based on a majority vote from representatives of environmental, social, and
economic interests respectively.”

* * *

Suggested language for the first dialog box for Sp10:

Yes.

Suggested language for the second dialog box for Sp10:

None.

* * *

Suggested language for the first dialog box for Sp18:

Yes.

Suggested language for the second dialog box for Sp18:

None.

General Comments

If you choose “General Comments,” you are presented with following dialog box:

“Do you have any general concerns about the revisions that cannot be addressed in the
comment fields for the individual credit or Benchmark revisions?”

Here is suggested language:
USGBC needs to better define the Conformance Assessment Process (CAP) by which
forest certification systems will be judged against the benchmark. A well-defined
9 proposal for the CAP should be put out for a fourth round of public comment along with
the rest of the documents relevant to the Certified Wood Credit revision. The CAP is as
important as the benchmark itself and absolutely requires stakeholder and USGBC
member input before the benchmark goes to ballot. Among other things, the following
critical questions related to the CAP need to be addressed:
o During and after their assessment of forest certification systems against
the benchmark, will the Independent Conformance Assessment Team take
input from other experts and stakeholders?

o Can a decision of the Conformance Assessment Team be appealed or
overruled by a higher USGBC body?

o How will the members of the Team be chosen? What are the criteria for
the experts, e.g., what qualifications are required?

o Will the Team assess on-the-ground outcomes of the forest certification
systems as well as paper standards, i.e. will there be field audits?

o If forest certification systems recognize one another mutually, as happens
with SFI and CSA and American Tree Farm, then will all of those systems
be rated against the benchmark before any can be considered compliant?

In addition, the Cp4 benchmark establishes a narrow definition of illegal logging that is
below the standard established by U.S. law under the amended Lacey Act. The current
language is as follows: “Certification schemes explicitly ban wood from illegal harvest in
protected areas. Compliance with CITES is required.” This needs to be modified anyway
because this definition of illegal harvest does not cover most illegal logging, which
occurs outside of protected areas (parks and reserves). The language should be amended
to read as follows: “Certification schemes explicitly ban wood harvested in violation of
international, national, or district laws, including but not limited to laws related to
timber harvest, social welfare, and environmental protection. Compliance with CITES is
required.”

The ban on illegally-logged wood should be extended to all wood used in all LEED
projects, and could be achieved with a new LEED prerequisite requiring that all wood
used in LEED projects be legally harvested.

Finally, the revised Certified Wood Credit should incentivize the use of products with
100% content from certified forests without unduly penalizing the use of products that
contain a mix of certified and non-certified content. This could be achieved by weighting
the former at 125% of their dollar value.

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