W&WP September 2004
Members of a year-old industry coalition say they are denied fair representation in LEED's standards setting.
By Rich Christianson
If nothing else, the members of the young North American Coalition on Green Building and the U.S. Green Building Council agree that "green building" is a good concept for the times. But from this central point of agreement sprouts major disagreement over whom should have the authority to determine which building materials do or don't meet the "green" standard.
"We support green building, but we do not support USGBC's LEED System as it is currently developed and implemented," states a one-page position paper drafted by the NACGB. The coalition, which was formed last year, unites 31 industry organizations; most of them are wood and plastic associations in the United States and Canada. Included are the American Plastics Council, Kitchen Cabinet Manufacturers Assn., National Paint & Coatings Assn. and the Canadian Plastics Industry Assn.
While the interests of the individual members are diverse, the main issue that brings them together under the NACGB umbrella is the hope that a stronger, unified voice will earn them a bigger role in the development of LEED system standards.
As was chronicled in the May issue of Wood & Wood Products, the USGBC created LEED to promote the development of buildings that "are designed, constructed and operated to boost environmental, economic, health and productivity performance over that of conventional buildings." While LEED is a voluntary standard, it has rapidly caught the attention of architects and designers who want to be on the cutting edge of environmental design. LEED has also been specified in numerous federal, state and municipal government building projects.
Why the Controversy
For example, many companies belonging to the Architectural Woodwork Institute, a member of the NACGB, take exception to the fact that the LEED rating system only recognizes woods certified by the Forest Stewardship Council. Such a stringent requirement raises issues of availability, quality and pricing for woods specified in LEED projects, the AWI says.
To gain greater insight into the reason for the NACGB's being and its views on the LEED system, W&WP questioned Jerry Schwartz, senior director of Water Quality Programs at the American Forestry & Paper Assn. and co-chairman of the NACGB.
Is LEED a bad idea or a good idea gone astray? What makes it so controversial?
The concept that brings LEED to the marketplace, improved environmental performance of buildings, is a great idea. In implementing LEED, however, the USGBC has allowed non-technical criteria to influence its development. All members of the Coalition share the overarching goal of building more sustainable buildings. We strongly support the concept of green building and have tried to work with USGBC at every turn to try and improve their program.
One of the often-heard criticisms about LEED is that its sole recognition of woods certified by the Forest Stewardship Council smacks of restraint of trade. Why do you agree or disagree with this criticism?
We feel that the LEED program should provide credit for all recognized forest certification programs, including the three largest programs in use in North America: The Sustainable Forestry Initiative (SFI), the American Tree Farm System (ATFS) and the CSA scheme in Canada.
To limit credit to just one program does a disservice to designers and architects by severely limiting their creative options. Architects who want to use wood, and seek to gain LEED's certified wood credit, face a crippling lack of supply of FSC-certified wood, limiting the availability and quality of certain species of wood. Architects and designers report the lack of supply is further compounded when seeking to also gain the LEED credit for locally sourced materials.
It is worth noting that an exhaustive study by Metafore, a leading non-profit organization that promotes business actions to conserve, protect and restore the world's forests, concluded that FSC, the SFI program (including ATFS) and CSA "present a range of viable models for independent forest certification systems." USGBC has not provided a scientific rationale that justifies discriminating against the SFI program, ATFS, CSA or any of the others.
There are several other provisions of LEED that also are of concern to the forest products industry because they discriminate against wood products in a number of other ways. For example, for producers of wood products that use formaldehyde-based glues or resins in their manufacture, LEED sets an inequitable and unreasonable standard for VOC emissions, as compared to other products. Rather than referencing published standards for determining credit eligibility, as is done for qualifying other VOC emitting materials, LEED grants credit for using composite wood and agrifiber products only as long as they "contain no added urea-formaldehyde resins." For non-wood products, LEED simply references compliance with published standards that mandate appropriately low VOC levels to receive credit. But for composite wood products, LEED does not recognize similar compliance with strict ANSI, ASHRAE or other industry standards for determining credit eligibility.
What is the single most important concern the North American Coalition on Green Building has with LEED? Why?
We believe green building rating systems or standards should be based on objective scientific criteria, including consideration of life cycle impacts. Without a grounding in objective, scientific criteria based on life cycle impacts, a rating system or standard is more likely to reflect the subjective biases of those who have crafted or are implementing the program. Objective criteria help ensure that the rating system or standard will not yield inconsistent results, arbitrary thresholds, an emphasis on cost rather than environmental impact measures, a lack of appropriate baselines and measures of improvement, and an inability to compare buildings in different locations on equal terms. These discrepancies can undermine the goals of the green building program as a whole.
What are some of the group's other key issues with LEED?
We believe that green building rating systems should be developed through a nationally-recognized voluntary consensus process. A consensus process is open to all interested parties, not just to selected categories of organizations that are allowed to join the entity creating the rating system or standard. A consensus process provides transparency, ensures meaningful opportunities for participation by groups that will be affected by the standard, and has procedures to ensure balance, consideration of dissenting views and appeals procedures. Collectively, these procedural safeguards ensure one group does not dominate the process to the detriment of others.
We are also concerned about USGBC's failure to allow trade associations membership in their organization. The coalition's trade association members, which represent broad segments of industry and often have that industry's technical expertise on environmental rating of buildings, have tried on several occasions to gain membership to USGBC and have been turned away each time.
If given a bigger say in the LEED process, what would the NACGB do to improve it?
Participate actively and fully. As stated, there is a lot of expertise among our members on the environmental performance of the materials and products they manufacture. At present, exclusion of trade associations and lack of a consensus-based process prevent this involvement. A consensus-process would ensure that LEED represented the best thinking of everyone, not just the hand-picked participants.
If your group does not get a bigger say, what is your biggest fear?
That more and more federal, state and local governments, not to mention private organizations and individuals, will latch on to a green building ratings system that remains flawed. We are strong supporters of green building concepts, but we fear that the widespread acceptance of the flawed LEED program will diminish the overall effectiveness of the green building movement.
U.S. government-retained experts have indicated that the USGBC process to develop LEED is neither consensus-based nor grounded in objective, scientific criteria with appropriate consideration of life cycle impacts. Therefore, as currently developed and implemented, LEED cannot ensure green buildings and thus should not be used or referenced by governments. However, with some substantive and procedural changes, the LEED rating system could achieve its stated goal of improving the environmental performance of the entire building industry.
Can you offer any special advice to our woodworking readers concerning LEED?
Wood products are a vital component of sound architectural design and facilitate ease of quality design and construction. Wood is among the most environmentally benign of all building materials because, among other things, it is a renewable resource that sequesters huge amounts of carbon. The certified wood credit, as currently constituted, and a number of other material credits in the LEED system, are clearly biased against the vast majority of wood products manufacturers.
The USGBC needs to hear a message that the current standards are not acceptable without modification. If your state or local jurisdiction is considering legislation to use LEED, make sure your voice is heard clearly and loudly.
Editor's note: For more information about the NACGB, contact Jerry Schwartz at (202) 463-2581 or [email protected].
Have something to say? Share your thoughts with us in the comments below.