On Wednesday, without public consultation or fanfare, USGBC lowered the bar on wood & forests in LEED, introducing a new Pilot Credit for Certified Products
into its LEED Pilot Credit Library.
After years of debate over which forest certification systems are worthy of LEED recognition, in this pilot credit, USGBC suddenly and without explanation ranks all forest certification systems - FSC, SFI, American Tree Farm, PEFC and CSA - as equivalent (see list of Pre-approved Certifications and Labels at the end of the pilot credit)
FSC, the gold standard for forest certification and the reference standard for the Certified Wood Credit for the last 10 years of LEED-driven market transformation of the forest products industry, here is demoted to a "single attribute certification." Defined as "verification of a single attribute through 3rd party certification," FSC is ranked the same as certification for recycled content or bio-based material or recovered/reused material. Never mind the fact that FSC certification's 10 principles, 56 criteria, and hundreds of regional indicators address a myriad of issues, from ecological functions, to biodiversity, to threatened and endangered species and other high-conservation values, to pesticide use, to water quality, to community and worker welfare, to indigenous peoples' rights -- it's still "single attribute."
FSC gets half the weight of "Type 1 Environmental Labels" defined as "voluntary, multi-criteria based third party program[s]...which authorize the use of environmental labels on products indicating overall environmental preferability of a product within a particular product category based on life cycle considerations." Pre-approved labels/programs include NSF's Sustainability Assessment for Resilient Floor Coverings, ULE's standard for Gypsum board, and CCD's standard for Energy Efficient Harmonic Cancelation Transformers. By this reckoning, dioxin-producing but above-average vinyl flooring, non-renewable but above-average gyp-board, and energy-saving harmonic cancelation transformers (whatever those are) are all twice as green as certified sustainably harvested wood.
Note that fully 30 standards are pre-approved in this pilot credit - not including all five forest certification systems. And this is before USGBC's new "Standard for Standards" which will be a "tool for decision making in the evaluation of certifications, labels and standards included in LEED" has even been released. One wonders who will be left out when the Standard for Standards is actually finished, or if there will be even token stakeholder input into the selection criteria or process. Perhaps they should dispense with the Standard for Standards and go with the Krusty Brand Seal of Approval
instead, with that catchy slogan: "It's not just good - it's good enough!"
FSC also gets equal weight to a "self-declared LCA" and half the weight of a "Third Party Certified Type III EPD: Industry Wide," the latter defined as a voluntary, third party reviewed LCA-based Environmental Product Declaration in conformance with a Product Category Rule document and program operator for industry wide declarations of a product category." No doubt anticipating this development, the Canadian forest products industry has developed PCRs for wood and has just rolled out EPDs for cedar decking
and siding - many more are sure to follow. Never mind the fact that the program operator for this EPD (FPInnovations) wrote to me that "[w]e have been engaged in LCA for wood products since 1991, evolving towards EPD's last year. This is motivated by our sense that the green building marketplace is expecting better, science-based information on the environmental footprint of materials. This is a separate issue from sustainable forestry practices, which is not a topic in our research program
How convenient - LCA, PCRs and EPDs that don't address the environmental impacts of logging - to say nothing of the social implications. Now that's new 'n' improved green!
Under the heading "Background Information," the authors of this pilot credit write that its "purpose is to communicate the difference between the levels of sophistication [of third party certifications and labels] in regard to more comprehensive perspectives of sustainability...The credit rewards greater transparency and knowledge about product life-cycles." Yeah, rank all the forest certification systems equally, when the expert research you contracted with Yale University revealed significant and substantive differences between them - way to communicate the differences in levels of sophistication! And oh yes, let's marginalize standards that actually require performance well above the status quo relative to LCA-based approaches that require no change in performance - all in the name of greater transparency.
And let's talk for a second about LCA - LCA, whose standard models don't address site-specific ecological impacts, human toxicity, or anything that isn't measurable or included in mass-averaged data sets that as often as not are imported from Europe or elsewhere (at this point North American LCI data is relatively incomplete). LCA, which to be useful for Environmental Product Declarations (EPDs) that provide apples-to-apples comparisons of different building materials, requires the development of hundreds if not thousands of Product Category Rules, many of which have yet to be started. LCA and its step-sister, Life Cycle Impact Assessment (LCIA), which disclose only those environmental impacts that the current tools are designed to measure and report. Significant environmental impacts of specific products or industries are often disguised or left out because the underlying data is highly aggregated and generalized, and, in most LCIA approaches, impact categories are narrow, limited in number, and sometimes irrelevant to the product being assessed.
And don't forget: there is NO minimum performance standard in the world of LCAs and EPDs. The assumption is that transparency alone will be sufficient to drive market transformation.
I've nothing against greater transparency, but I challenge this assumption. We still need leadership standards!
Under this pilot credit, if the vinyl industry finishes a PCR and a manufacturer of vinyl flooring produces a 3rd party certified product-specific EPD for its products, then these will be worth 4 times as much as FSC-certified sustainably harvested wood - regardless of the environmental impacts of the vinyl flooring. Again, no minimum performance threshold is required. Tell us how much dioxin you are producing, and congratulations! You've earned a point!
This is the triumph of engineering over environmentalism and common sense.
Who is responsible for this travesty? Is it a small coterie of USGBC insiders? Is it a massive bureaucratic super-tanker that is drifting away from the ideals that once anchored it, pushed by the winds of trade association, industry and certifier/SDO/LCA/EPD lobbying?
Is this a foretaste of what we can expect with the release of the next iteration of LEED 2012? Is this the brave new LEED we have been waiting for?
Many of us cling to the hope that LEED will remain a leadership standard, not just in building and carbon bean-counting, but in forest management, ecological conservation, human health, social responsibility and other important areas that have little to do with LCA but everything to do with sustainability. We are trying to organize against the drift toward lower standards and "half-cycle-analysis" tunnel vision. If you care about these issues, please join one of these groups:
To arms, ye greens of the REAL green building movement!
And special thanks if you actually read to the end of this rant -
Sierra Club Forest Certification Team