While the third draft of LEED 2012 is open for comment, the Forest Stewardship Council (FSC) says though it offers improvements, its still falls short of its stated goal: driving market transformation to sustainability. According to an FSC announcement, it “recognizes and appreciates the substantial effort the staff and technical advisors at the USGBC invested in addressing weaknesses in earlier drafts, significant changes are still required for LEED 2012 to drive market demand for products from responsibly managed forests.”

The FSC says when it comes from responsibly managed, FSC-certified sources, wood is among the most environmentally friendly building materials—a fact LEED should recognize and reward. Yet if approved as written, the third draft would represent a step backwards from the current Certified Wood Credit, which has directly encouraged tens of millions of acres of forest conservation and responsible management in the United States and Canada.

“LEED continues to recognize FSC as the only credible forest certification standard, which is a great step in the right direction,” says Corey Brinkema, president of FSC-US. “To drive the market for wood from responsibly managed forests, incentives must be clear and appropriately weighted.”

According to FSC, to transform the marketplace and promote environmental performance, LEED must accomplish two objectives:

1) Set the bar high by accepting only leadership standards; and

2) Create enough incentive for building projects to meet or exceed this bar.

FSC says the third draft of LEED 2012 achieves the first objective but not the second.

Some improvements still needed in LEED 2012, according to FSC, include creating clear incentives for projects to meet FSC’s high bar. It says by providing up to five points for use of Life Cycle Assessment (LCA)-based disclosure tools, LEED 2012 reduces the incentives for compliance with high performance standards such as FSC. It also says the calculations used for materials to qualify for points under the Raw Materials Extraction Credit are “out of line with the reality faced by designers, especially in commercial and institutional construction.”

As the FSC announcement notes, “Since LCA tools alone cannot yet be relied upon to make responsible product decisions, leadership performance standards and LCA-based disclosure tools are complements that must work hand in hand. Because there are enormous gaps in current LCA methodology, the Raw Materials Extraction Credit in LEED 2012 needs to be a robust complement to the Disclosure Credits. We’re not there yet.”

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