Forest advocates have until Monday December 10th to provide official comments on the US Green Building Council’s 5th draft of LEED v4.

Please take a few minutes between now and this coming Monday to provide USGBC with your thoughts and suggestions on how to improve this leading driver of sustainability within the building industry. You can provide your comments on the Materials and Resources section right now by clicking on this link.

We would like to take this moment to offer our perspective on the fifth draft.

Overall, the Forest Stewardship Council is supportive of the direction that USGBC has taken the LEED standards in this draft. FSC remains the only forest certification standard recognized in LEED, signaling the strength of USGBC's commitment to leadership, high standards and market transformation. It also appears that FSC will serve as a model for recognizing leadership standards for other raw materials in construction products. This is a promising development, since other materials are rightly criticized for lacking similar rigorous, independent certifications of their environmental performance.

USGBC made two other important improvements with the fifth draft: 1) In the proposed MRc3 Sourcing of Raw Materials credit, local and regional sourcing are a multiplier rather than a substitute for compliant leadership extraction practices, and 2) structural and envelope materials are limited to a maximum 30% of the value of compliant building products (the industry norm of recycled content structural steel will not in itself be sufficient to earn a point).

Our primary critique with the fifth draft, as with prior drafts, is that performance (optimization) is undervalued relative to transparency (disclosure).

We respect USGBC’s intent in jumpstarting disclosure initiatives within the building products industry, and recognize the rationale that comprehensive and accurate disclosure should over time encourage improvements in performance. The proposed MRc2 Environmental Product Declarations and MRc4 Material Ingredients credits have improved and are generally well structured (though we would like to see greater incentive for the inclusion of landscape conditions, biodiversity and ecosystem services impacts in EPDs).

However, when it comes to the proposed MRc3 Sourcing of Raw Materials credit, the disclosure option (raw material source and extraction reporting) is unlikely to result in widespread market transformation and is a point that we believe would be better allocated to the optimization option, further incentivizing the development and use of leadership certification standards in raw materials.

Based on our research, only a narrow subset of building product manufacturers will find it feasible to comply with the requirements in Option 1 raw material source and extraction reporting. It would be far more impactful and transformative to eliminate this option and apply a second point to a single leadership extraction practices credit. The thresholds could be adjusted so that one point is achieved at x% compliant materials relative to the total materials cost, and a second point is achieved at a higher threshold. Even better, the second point could specifically distinguish and credit the use of materials certified to USGBC-approved leadership standards (as opposed to recycled content or salvaged sources).

Finally, we recommend the following edits to the list of “responsible extraction criteria” within Option 2 leadership extraction practices:

“Bio-based materials” in first bullet should be deleted and replaced with “Non-wood biobased materials”.

The word “New” should be deleted in the second bullet so as to read: “Wood products. Wood products must be certified by the Forest Stewardship Council or USGBC-approved equivalent.

We’d like to close by thanking all of you who have followed the LEED v4 development process and shared your expert guidance with us and directly to USGBC staff and membership. We hope you will continue that critical engagement as we close in on the final ballot version of the LEED v4 standard.

Source: FSC

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