Legal forestry in the US, certified by the Sustainable Forestry Initiative. image © F. Eatherington

Does the US Green Building Council consider 

this responsible forest management?

New Pilot Alternative Compliance Path in LEED could be a step toward

verified legality of forest products or a capitulation to Big Timber
In a surprise move, USGBC recently announced a 

new Alternative Compliance Path (ACP) for the Materials & 

Resources credits in LEED 2009 and LEEDv4 that recognize 

certified wood. The ACP rewards the use of wood certified 

under ALL forest certification systems – including notably 

the timber industry-backed Sustainable Forestry Initiative 

(SFI) – whereas previously these credits had only recognized 

wood certified according to the rules of the Forest 

Stewardship Council (FSC).

This came as a shock to almost every major environmental 

group who are united in support for FSC as the highest 

standard for forest certification, and in opposition to SFI

as an industry-governed and financed greenwash system 

that seeks to pass off environmentally destructive industrial 

forestry as somehow “sustainable.” Among other things, 

SFI certifies vast clearcuts, the replacement of complex 

forest ecosystems with monocultures, and logging that 

harms water quality and jeopardizes already imperiled fish 

and wildlife. Also, SFI does not require the Free, Prior and 

Informed Consent of Indigenous Peoples when logging 

on their lands.

USGBC made this move after a dozen years of intensive 

lobbying by the logging industry and the politicians 

that support it for the inclusion of SFI in LEED:

 gubernatorial and legislative bans on the use of LEED

in half a dozen states, and attempts to ban LEED in 

many more;

 sign-on letters from governors and members of 

congress from states where the timber industry is 

dominant;

 attempts to ban or limit the use of LEED for federal 

construction; and

 aggressive promotion of a competing green building 

rating system, Green Globes, that’s largely a creation 

of the timber industry.

In spite of this pressure campaign, in 2010, a proposed rewrite of the certified wood policy that would have created 

a pathway for the inclusion of SFI in LEED failed to obtain 

sufficient support from the USGBC membership.

Given the history, it’s deeply troubling that the new 

ACP accepting SFI appears to have been developed 

and pushed through by USGBC upper management 

without any meaningful consultation of external 

stakeholders (e.g. sustainable design leaders, experts 

in forest legality, environmental groups) – with the 

possible exception of the logging industry and its 

affiliates. 

The stakes are high: since SFI largely affirms the status 

quo, while FSC embodies environmental and social 

improvements in forest management, by supporting FSC, 

LEED has played a key role in driving market transformation 

of the forest products industry. Unfortunately, unless 

the right steps are taken, the ACP has the potential to 

undermine this effect, which is vital for the well being of 

forests and forest-dependent peoples around the world.

The saving grace is that there is language in the 

new ACP and in USGBC’s communications around it 

suggesting that the purpose of the pilot is to test 

the feasibility of a new LEED prerequisite requiring 

evidence of legality for 100% of the wood used in 

LEED projects. Given that illegal logging is rampant in 

many parts of the world, and trading in illegal wood is now 

against the law in the United States, the European Union, 

Japan and Australia, this would be a positive step that 

everyone could support.

However, there are reasons to doubt whether this is the 

direction that things are actually headed. Within 24 hours 

of USGBC’s announcement of the ACP, SFI, the American 

Tree Farm System and the American Forest & Paper 

Association implemented a coordinated communications 

plan, all releasing statements of their own. Within 72 hours, 

SFI even announced a new webinar “explaining” the new 

credit language. Such a high degree of preparation and 

orchestration suggests that SFI and its allies knew this was 

coming for some time and that USGBC and industry worked 

together on the ACP behind the scenes. 

I do not believe that this is just 

about illegal logging...It is about 

supporting responsible, certified 

materials in the supply chain as 

well. It does open it up [for SFI and 

other programs] to be recognized 

for credit in the LEED rating system.

“

—SFI VP Jason Metnick

“
Predictably, the industry statements make only passing reference to 

eliminating illegal wood, emphasizing that this is about the inclusion of 

their forest certification systems in LEED.

At the heart of the ACP’s flaws is the ASTM standard that it references 

(D7612-10). Not only does this standard establish all forest certification 

systems as equivalent, it defines as “responsible” ALL timber logged in 

North America – whether certified or not! And its definition of legal wood 

is woefully inadequate. Not surprisingly, there were no environmental 

groups involved in the development of this standard

If USGBC is serious about a legal wood prerequisite, then why 

didn’t they consult the leading groups working on illegal logging?

Ever since 2008 when the amended Lacey Act made it illegal to buy or sell 

wood in the US that has been illegally logged or traded in the country of 

origin, numerous non-profit organizations have dedicated themselves to 

generating information, guidance and tools designed to help companies 

and government entities comply. Several of them have offices conveniently 

located in Washington DC, including respected names like World Resources 

Institute, World Wildlife Fund, the Environmental Investigation Agency, 

Greenpeace and Global Witness. If the ACP is truly a good faith effort to 

support the Lacey Act and similar legislation in other countries by keeping 

illegal wood out of LEED projects, why didn’t USGBC consult these groups? 

Why did USGBC choose instead to rely on a flawed standard that has the 

SFI industry’s fingerprints all over it?

USGBC and LEED have done a tremendous amount of good over the years, 

channeling inspired effort and innovation in support of healthier buildings, 

improvements in water and energy conservation, greener materials...and 

truly responsible forest management. 

If the true purpose of the ACP is not to recognize forest 

certification systems that are weaker than FSC and not to 

consecrate all North American wood as “responsible”...

If in fact its objective is a worthy prerequisite designed to 

screen illegal wood out of LEED projects...

then USGBC needs to state this emphatically and 

unequivocally, correcting the misrepresentations of SFI and 

its allies. 

This is no time to step back 

from this legacy of leadership

The fact that the USGBC

has decided to treat 

all credible forest 

management certification 

systems as equally 

acceptable could be cited 

in discussions regarding 

which sustainable forest 

management certification 

programs are acceptable 

for paper-based products... 

AF&PA has worked on this 

issue for many years; it 

is encouraging to see 

USGBC open its standard 

to recognize all credible 

certification systems, in 

alignment with our policy. 

“

—Jeff Bradley, Manager Forest & 

“

Wood Product Policy, AF&PA

SFI Approved logging, Plum Creek Timberlands