Rainforest Alliance Position Statement on U.S. Green Building Council's LEED 2012 Draft Standard, Version 3

March 23, 2012

The USGBC is in the final stages of a complete revision of the Leadership in Energy and Environmental Design (LEED) Rating Systems.  The third public comment period for the draft LEED 2012 standard was recently extended and will now close on Tuesday, March 27.  This could be the final opportunity for stakeholders to provide input on these standards.

The Rainforest Alliance is a member of the USGBC and we’ve been supporters of the LEED Rating Systems as an effective tool for ensuring environmental performance in built environments.  While we’re encouraged that the USGBC has revised aspects of the draft LEED 2012 standard in a manner consistent with our input after the previous public comment period, unfortunately, as it stands today, the Materials & Resources (MR) sections still contain serious flaws that will result in a major step back in the USGBC’s support of responsible forest stewardship. We encourage everyone who cares about forests and green building to take a few minutes to provide their comments to the USGBC.

We commend the USGBC for continuing to promote responsible stewardship of forests by retaining the specification for FSC-certified materials in the “Responsible Extraction of Raw Materials” credit in the BD&C and ID&C rating systems.  However, considering its importance and relative influence on “enabling an environmentally and socially responsible, healthy, and prosperous environment that improves the quality of life” -- referenced in the USGBC mission statement -- this credit is grossly under-represented in terms of point eligibility.  

The crediting threshold for FSC wood in the “Responsible Extraction of Raw Materials” credit absolutely must be revised to establish achievable targets. Unfortunately, the proposed minimum crediting threshold of 10% of all building materials required to meet responsible sourcing criteria is virtually unattainable for FSC-certified wood.  While 10% seems like a low threshold, even if 100% of the wood used in a building is FSC-certified, it will be unlikely to achieve a single point because wood typically represents a very small proportion of materials in most commercial structures.  FSC-certified content should be measured as a percentage of similar building materials (e.g. wood or other bio-based materials), not against all building materials.  In its current form, this credit represents a major step backward for market recognition of responsible forestry.  

The LEED standard should reflect the mission of the USGBC by continuing to put primary emphasis on performance, while maintaining appropriate recognition of disclosure (reporting of impacts).  We continue to be particularly concerned with USGBC’s disproportionate reliance on disclosure tools like Life Cycle Analysis (LCA) and Environmental Product Declarations (EPDs) in the current draft of LEED 2012.  The purpose of LCA-based disclosure tools is to identify, quantify, and disclose certain measurable environmental impacts of products and processes.  Alternatively, the purpose of leadership performance standards is to ensure conformance with rigorous, transparent, and auditable criteria for environmental, human health and/or social performance, and to identify products or processes that meet their requirements. Performance standards are outcome-based and result in avoided impacts.  USGBC must recognize the fundamental differences between performance standards and disclosure tools in LEED, address them separately, with distinct credits awarded for the functions they are designed to provide.  

As a leadership organization, USGBC should be keeping pace with developments in the sustainability sector.  Life cycle thinking is certainly appropriate for the built environment.  We support the USGBC’s effort to embrace the promise of LCA as an emerging tool in promoting disclosure through measuring and reporting environmental impacts. However, reporting impacts is not the same as preventing them, and while disclosure should be encouraged through LEED, it should not be afforded recognition equal to conformance with well-established leadership performance standards.  Unfortunately, more credit is available for non-certified materials that have been subjected to life cycle assessment reporting than materials that have been certified to well-established leadership performance standards like the Forest Stewardship Council (FSC).   

The USGBC’s recognition of LCA and accompanying EPDs must take full account of the current limitations of these tools.  LCA do not address a full array of important and relevant environmental, human health or social issues; do not prohibit harmful practices; and don’t fully account for site specific impacts associated with raw material extraction.  LCA-based disclosure tools should not be used to evaluate performance because they cannot yet do so reliably.  The Whole Building LCA credit must be revised to address disclosure, not performance.  The current approach of awarding credit for marginal improvement over a self-selected baseline using only half of six impact categories must be removed.  LCA must be required to report on all environmentally relevant impacts.Given their fundamental differences, disclosure tools cannot substitute for performance standards. Even the most robust and comprehensive disclosure tools should be considered complementary to well established leadership performance standards.

Additionally, while we applaud USGBC’s intent to extend the benefit of performance standards to other materials, we do not support any credit for first-party claims, as they justifiably carry little credibility in the marketplace.  USBC must not recognize corporate pledges or other unverified public statements as equivalent to achieving independent, third-party certification to leadership performance standards.

In the LEED for Homes standard, we applaud the USGBC for reinstating FSC as the measure of environmentally preferred forest products after the second comment period. However, the maximum number of achievable points must be kept at eight, as in the current LEED 2009 standard, to appropriately recognize the importance of wood products in residential construction, and the impact of sourcing practices on forests.  Crediting options must also be expanded to include material categories currently included in LEED 2009, and to allow for sub-categories of structural materials to be credited independently, rather than being lumped into a single credit opportunity.

Further, “rapidly renewable” does not equate to strong environmental performance, and, in fact, can include environmentally harmful practices. Credit must not be awarded solely on the basis of a material’s growth rate.  

The proposed changes reflected in LEED 2012, Version 3, when compared with the existing LEED standard, are so significant that a fourth comment period is absolutely necessary. If brought to a vote, the Rainforest Alliance will not support a LEED 2012 standard until the above issues are corrected.

In addition to our detailed comments, Rainforest Alliance collaborated with other leaders in environmental conservation, architectural design and construction to develop a Statement of Consensus on Driving Leadership in Performance and Disclosure in LEED 2012. This consensus statement outlines key differences between leadership standards like FSC, and disclosure tools like Life Cycle Analysis (LCA) and Environmental Product Declarations (EPDs). Included in this summary document are strengths and weaknesses of each approach, as well as broad recommendations to USGBC on how to address these key issues in LEED 2012.