FSC and Beyond: LEED 2012 Buries the "Wood Wars" Hatchet
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After months of controversy, the third public comment draft of LEED 2012 strengthens commitments to both FSC and local wood--while not budging on the importance of life-cycle assessment. This is Part 2 in our "Wood Wars" series. Part 1: Are FSC a... The LEED 2012 Wood Credits There are three main subsections in the third draft that could potentially apply to lumber products: Building reuse and whole-building life-cycle assessment (1–3 points) This option encourages reuse or salvage of onsite or off-site materials. It could include existing wood framing, wood flooring, etc., as well as steel framing and many other materials. Issues of wood certification and transparency don't apply when building products are simply reused, although the effect of wood certification on whole-building life cycle assessment remains to be seen. Material life-cycle disclosure and assessment (2 points) This controversial subsection promotes transparency by offering three different options ( see more about the conflict in our prior coverage , along with USGBC's rationale for incentivizing transparency). The first two would give one point each for using products that have a third-party-reviewed life-cycle assessment (LCA) or environmental product declaration (EPD); one point is for transparency for 20% of non-structural materials, and one point is for transparency for 20% of structural and enclosure materials. The section has been controversial because it rewards transparency without regard to a product's environmental performance: in theory, cedar clapboards harvested using slash-and-burn forestry practices could be used in calculations for achieving one of these credits--just by virtue of having an LCA or EPD associated with it. There are also issues with the ability of LCA (which is the methodology underlying EPDs) to capture ecosystem damage and many other impacts. (See " The End of Greenwashing? Five Myths about Product Transparency " for a quick take on the limitations of LCA.) The other option is called "multi-attribute assessment," which is an odd name since it appears to be based on single attributes: materials reuse, recycled content, and local sourcing. This third option sets a high bar for achievement: 50% of nonstructural products. Responsible extraction of raw materials (1–2 points) All new wood products used to achieve this credit must be FSC-certified "or better." The only exception to this is wood harvested and milled within 50 miles of the building site--a significant change from prior versions of LEED, which gave credit for "locally" sourced wood and other materials within 500 miles of the site. The whole subsection on extraction of raw materials also has local-sourcing tiers for calculating credit, which is based on percentage by cost. Domestic products have their cost value multiplied by 1.5; in-state or in-province products have their cost value doubled; and products from within 50 miles/80 km have their cost value tripled. It's a major incentive for using locally and regionally sourced materials, which fosters local economies and could potentially quell arguments against using LEED for government projects--despite LEED 2012's renewed commitment to FSC for wood sourcing. Two other subsections could apply to composite wood products: Disclosure of chemicals of concern (1 point) While wood products are not the first thing that come to mind, sheathing products or composite countertops, for example, could count toward a credit collected for disclosure of chemicals. Again, the credit is based on disclosure itself--not on whether there are high levels of formaldehyde or other chemicals we should be concerned about. Avoidance of chemicals of concern (2 points) Unlike the disclosure credit, which was previously combined with the avoidance credit, this subsection addresses the actual performance of products and rewards them for reductions in chemicals of concern. So a sheathing product or composite countertop that avoids formaldehyde or other chemicals on the list could count toward these credits in addition to the disclosure credit. Is This a "Back Door" for SFI? By my count, that makes three points based entirely on transparency that could potentially be used for wood products, as opposed to seven based on specific green attributes. It remains to be seen how opponents of the weighting in the previous draft will react, but there are those who thought that a focus on transparency would let FSC's competitor--the Sustainable Forestry Council (SFI)--in through a "back door" in LEED. Should we be worried about this? USGBC doesn't think so. "That accusation can't be made without already fundamentally misunderstanding the rating system," said Lane Burt, director of technical policy at USGBC. "Right now you can get credit for any wood within 500 miles [for the Regional Materials credit], and you only have to use 50% of wood that's FSC-certified [for the Certified Wood credit]." That means lots of SFI-certified wood and non-certified can be used for LEED regional points, while the project could still earn the Certified Wood point with FSC material. Revising local sourcing to 50 miles is a huge change that could close out a lot of previously accepted SFI-certified and non-certified products for achieving this particular credit. If any other wood products are going to be included for LEED credits, if they are not sourced from a 50-mile radius, they'll now have to do it almost exclusively through transparency--by having LCAs or EPDs or by disclosing chemicals of concern. But that's not really the point anyway, as far as the crafters of the system are concerned. Burt continued, "We're now moving away even from wood and local credits to something more robust and realistic. People can continue to make those accusations, but they are going to be even more fundamentally flawed in their premise." Eyes on the Prize Brendan Owens, P.E., vice president of LEED development for USGBC, acknowledges the historic leadership role of FSC and encourages FSC to support efforts to increase transparency. Because standard LCA methodology is currently limited, part of the point, he says, is to incentivize further development of these tools. "Wouldn't it be great if we had quantifiable metrics that allow us to distinguish between FSC and SFI?" asked Owens. Instead, he said, "We rely on proxies rather than data." In the long term, Owens anticipates "the 2.0 or the 3.0" version of forestry standards--driven by the development of better measurement tools. "We want to push that," he said. But right now, "we're not getting the information that allows us to quantifiably say that the things we are assigning as proxies are necessarily outcomes." Owens challenged FSC supporters to look at the forest instead of the trees: "One of the things that's important about this is the fact that we are juggling at least seven different environmental and social issues simultaneously across a complex infrastructure for design, construction, operation, and maintenance of buildings," said Owens. "Buildings are not a wood issue. It's the other way around." "The Soul of the Green Building Movement" Jason Grant, a consultant to the sustainable forest products industry and a long-time backer of FSC, sees things a little differently. "Forests matter," he said in an interview conducted before draft three of LEED 2012 was released. "They are one of the key systems for our survival. It is fundamental." Grant believes that sustainable forestry isn't just about two or three credits. "It's about the soul of the green building movement. It's about the soul of LEED," he said. "Are we going to capitulate to greenwashing and an intense pressure campaign? Or are we going to stand strong for what LEED is supposed to be about? That really matters." I find both of these passionate arguments moving and convincing. And I don't actually think they're mutually exclusive. LEED is large; it contains multitudes. I'll be curious to hear what Grant and other FSC supporters will say about the third draft once they've had a chance to mull it over. Does it thread the needle? Or is it a poke in the eye? What do you think? Let us know in the comments.