Thursday, 07 April 2016
Action Alert: Legal Forestry Alone is Not Worthy of LEED Credit
April 7, 2016
Contact USGBC Today About New LEED Pilot Credit
On April 5th, 2016, the US Green Building Council announced a pilot Alternative Compliance Path (ACP) credit to:
“…further advance environmentally responsible forest management and help rid our buildings of illegal wood by promoting the use of wood that is verified to be legal. The pilot ACP builds on the robust infrastructure that has been built around responsible wood sourcing and chain of custody to test an approach to prerequisite requirements, which could serve as a model for other building materials.”
Critically, this pilot ACP credit is suggested as an alternative to the membership-approved credit that currently recognizes building projects for use of FSC-certified products.
The Forest Stewardship Council has serious concerns about the pilot ACP. First and foremost, we are concerned that it functionally asserts equivalence between legal wood products from North America and those from responsibly managed forests. FSC also questions the process to develop the pilot, as we first learned about it moments before the press release was issued.
So while we are still analyzing its potential impacts, we believe it is critical to move quickly to get our community of stakeholders engaged.
The Forest Stewardship Council calls on FSC Certificate Holders, supporters in the sustainable design industry, Environmental and Social Chamber Members of FSC, and business leaders to communicate the following to the US Green Building Council:
- Legality is appropriate as a prerequisite in LEED. It is entirely wrong as a credit.
- The scope of the pilot must be clearly limited. By testing the ACP with 100 LEED projects, USGBC can determine how it would work as a prerequisite.
- By limiting the scope of the pilot, USGBC can determine its validity while maintaining support for the LEED program in the marketplace.
- We encourage USGBC to engage with stakeholders to credibly address legality and strengthen the prerequisite.
We encourage all stakeholders to submit letters to Rick Fedrizzi, CEO (email@example.com) and Fiona Cousins, Board Chair (firstname.lastname@example.org) at the US Green Building Council.
The Forest Stewardship Council strongly supports efforts to screen out illegal forest products from the LEED program. But legal forestry is not the same as responsible forest management, and legal forestry alone should not be enough to meet credit requirements in LEED.
The new pilot credit effectively gives credit to all forestry in the US and Canada, even when it involves destruction of wildlife habitat, use of highly hazardous chemicals, or clearcuts the size of 400 football fields. This is not responsible management and it is not worthy of credit in the LEED program.
LEED was designed to improve environmental performance and transform markets. Requiring legal forest products as a prerequisite is an important step in the right direction. But providing a credit for legal forestry in LEED, especially one that replaces high standards and responsible forest management, is irresponsible, damaging to USGBC’s credibility and a black mark against the LEED program.
The Forest Stewardship Council stands ready to work with USGBC to quickly test the impacts of their pilot. Along with our partners, we also offer to provide input, based on decades of collective work, about how to credibly verify legality in forest products. For example, the reference standard USGBC specifies for legality – ASTM D7612-10 – may not be the best way to practice due care under the Lacey Act.
FSC will provide regular updates as we learn more about this new pilot credit.
Please write to the USGBC leadership today.