Green Building
Mr. Rick Fedrizzi
President & CEO, U.S. Green Building Council
2101 L Street NW, Suite 500
Washington, DC 20037
October 19, 2009
Dear Mr. Fedrizzi,
Thank you for providing stakeholders an opportunity to comment on the revised Forest Certification Benchmark. We appreciate the USGBC’s leadership in the green building movement and believe there is great potential for green building markets to drive the sustainable management of woodlands of all sizes in the United States.
Access to the emerging green building market, through recognition by the LEED green building rating systems, is incredibly important to the American Forest Foundation, and our program, the American Tree Farm System®. The American Tree Farm System represents over 91,000 family woodland owners who are sustainably managing 24 million acres across the United States. Family woodland owners have the potential to provide the growing green building market with a critically needed local source of sustainably managed wood.
Unfortunately, the proposed Forest Certification Benchmark will have a tremendous negative impact on the credibility of the LEED rating systems, the continued viability of sustainably operated woodlands, especially small, family-owned woodlands that supply most of the fiber for forest products in the U.S., and buyer accessibility to sustainably produced wood at the local level. This Benchmark will lead to less sustainable building practices.
There are three fundamental problems with the approach proposed in the revised Benchmark. The Benchmark discourages the use of wood as a building material, clearly favors one certification standard over other equally credible standards, and is tiered towards industrial forest producers when most woodlands in the U.S. are owned by small, family, woodland owners. Discouraging Use of Wood as Building Material.The Forest Certification Benchmark and Certified Wood credit establish a complicated process for establishing recognition of wood as a green material which in effect, discourages the use of wood products. It is well documented that wood building products provide significant environmental and energy efficiency benefits, yet these benefits have never been appropriately recognized under the LEED rating systems (The Consortium for Research on Renewable Industrial Materials (CORRIM)). In addition, by discouraging the use of wood, the LEED rating systems generally may have unintended environmentally destructive consequences by failing to demand other building materials meet the sustainability practices catalogued in the Forest Certification Benchmark.
Wood is a renewable resource that can increase the sustainability of our buildings and providing other social, environmental, health, and economic benefits at the community level. Using wood can help mitigate climate change, through the conservation of well-managed forests that sequester and store carbon and through storage of carbon in harvested wood products.
The Forest Certification Benchmark includes sustainability criteria that steel, concrete and competing products do not even have to attempt to meet. Forest Certification programs must meet a minimum of 60 different prerequisites and credits to be considered for a single point in LEED. Installation of bicycle racks or employee shower facilities will also gain the builder a single point under LEED but the materials that make up the bicycle rack or shower do not have to be verified for their environmental sustainability.
LEED users should be encouraged to use more wood in their buildings not discouraged by confusing measures such as determining the ratio of points received based upon cost and certifying program recognition under the Forest Certification Benchmark.
We ask that you quickly finalize your long-promised inclusion of life cycle analysis methods within the LEED rating systems so that architects, governments and builders that rely on the LEED systems to create environmentally friendly buildings can make fully informed decisions about the materials they choose to use. We believe this is essential to the credibility of your system.
Favoring One Certification Standard over Others.The Benchmark is clearly structured so that the “objective” prerequisites and criteria favor one forest certification system, the Forest Stewardship Council, above all others. This does little to address environmental concerns with the production of wood products. Any fair-minded review of certified lands in the U.S. shows there are few significant differences between the practices on small, family woodlands enrolled in any of the credible certification systems.
Small family woodland owners protect the environment in the production of wood building products by practicing sustainable forest management. A more inclusive policy under LEED is needed to support the use of certified wood from all credible forest certification systems. This would send a positive signal to landowners and land managers that their responsible forest management practices are supported by legislators and the public.
The exclusive recognition of the Forest Stewardship Council (FSC) certified wood products under the LEED rating systems pushes green building markets towards wood products grown outside of the United States. There are ample sources of sustainable wood products sourced from well-managed forests in the U.S. In a time of almost 10% unemployment in our nation (and often much higher in America’s woodbasket areas), USGBC should be encouraging the use of sustainably grown and harvested wood right here in the US.
The American Tree Farm System and the Sustainable Forestry Initiative, working together as PEFC-US, certify over 80 million acres, while the Forest Stewardship Council certifies only 31 million acres in the United States. With limited FSC-certified forest acres in the United States, FSC wood often must be imported from distant countries such as Russia and Indonesia to meet the demand of paper producers and green builders. We often hear from paper and wood products companies that they are discouraged from buying locally sourced wood because of the LEED requirement for FSC-certified products, even though a nearby family woodlot operation has been sustainably managed and certified for several generations. Favoring a foreign market unnecessarily adds high environmental costs resulting from transportation, when a local, sustainable source is readily available. Recognition of all credible forest certification systems would increase the supply of sustainable wood products to builders and designers and be a better model of sustainability. If the certified wood credit fully recognizes all credible forest certification standards (FSC, SFI, ATFS, CSA, PEFC), builders and designers would have the opportunity to source local products that meet not just 1 credit as a regionally produced products but another for certified content as well. This would have the overall effect of incentivizing the use of wood, the most sustainable building product.
With only 10% of the world’s forests certified, organizations, such as the USGBC, that guide significant buying power should support all credible third-party forest certification systems. Many governments, companies and green building rating systems around the world have already recognized the importance of supporting all forest certification systems. For example, Green Globes (US and Canada) BREEAM (United Kingdom) Built Green Canada (Alberta & BC), Built Green Colorado, CASBEE (Japan), American Consumer Council and National Green Building Standard (US) recognize all credible systems. Governments around the world that follow this example include the U.S. Government Service Agency, and government purchasing policies in the UK, Japan, Germany and France, and the Canadian Competition Bureau.
Focus on Large, Industrial ProducersThe proposed Benchmark is obviously written for industrial forest producers, even though small woodland owners, typically families and individuals, own the majority of private woodlands in the U.S. The proposed prerequisites and credits were written with large landowners in mind, landowners who can afford the cost of extensive outreach and documentation that the Benchmark demands of them. While the Benchmark makes references to flexibility in implementing these standards, we fear that a lack of understanding of the costs of compliance by USGBC may exclude small, family owners from green building markets. We recommend that you clearly delineate what on-the-ground activities landowners must undertake to meet your benchmark. The simplest and most credible way to do this is to establish that wood harvested from forests certified by FSC, SFI, CSA, PEFC or the American Tree Farm System is recognized under the LEED rating systems.
We would also like to ask USGBC to consider adding a new credit to the Benchmark that will encourage environmental education in conjunction with fulfilling forest certification. The success of sustainable forest management and green building relies on a public which understands and values the social, economic and environmental benefits forests provide to our communities, our nation and our world. Education about forests, green building and sustainability is beneficial for current landowners but will have an even greater impact if directed towards the next generation of forest landowners. This new credit should promote peer reviewed K-12 environmental education programs that teach concepts relating to green building, life cycle analysis and sustainable forestry.
We urge you to reconsider the ramifications of favoring a single forest certification system over other credible systems, imposing a complicated credit process that discourages the use of wood in LEED certified buildings, and tailoring the benchmark process towards larger landowners. USGBC has tremendous potential to promote sustainability; the proposed Benchmark is misguiding the well intentioned effort.
The USGBC and its staff have worked hard to build the credibility of the LEED brand and support the growth of green building the U.S. We stand ready to help you with this effort, if you reconsider the approach taken in the proposed Forest Certification Benchmark.
Sincerely,
Tom Martin
President & CEO, American Forest Foundation
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