image © F. E atherington 

### Lega l f orestry in the U S, certi f ied by the Su stainab l e Forestry I nitiative. 

# Does the U S Green B u il d in g Co u n c il c onsi d er this responsi b le forest manag ement?

N ew P ilot A lternative Complian c e P ath in LEE D c o u l d b e a step towar d verifie d le g ality of forest pro duc ts or a capit u lation to Bi g T im b erI n a s u rprise move, U S GBC re c ently anno u n c e d a new A lternative C ompliance Path (AC P) for the M aterials & R esources credits in L EED 2009 and L EED v4 that recognize certified wood. T he AC P rewards the use of wood certified under A LL forest certification systems – including notably the timber industry-backed S ustainable Forestry I nitiative ( S F I ) – whereas previously these credits had only recognized wood certified according to the rules of the Forest S tewardship C ouncil (F SC ).

T his came as a shock to almost every major environmental group who are united in support for F SC as the highest standard for forest certification, and in opposition to S F I as an industry-governed and financed greenwash system that seeks to pass off environmentally destructive industrial forestry as somehow “sustainable.” A mong other things, S F I certifies vast clearcuts, the replacement of complex forest ecosystems with monocultures, and logging that harms water quality and jeopardizes already imperiled fish and wildlife

. A lso, S F I does not require the Free, Prior and I nformed C onsent of I ndigenous Peoples when logging on their lands.



### U SGBCmade this move after a dozen years of intensive lobbying by the logging industry and the politicians that support it for the inclusion of S F I in L EED :

 gubernatorial and legislative banson the use of L EED in half a dozen states, and attempts to ban L EEDin 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 L EEDfor federal construction; and

 aggressive promotion of a competing green building rating system

, G reen G lobes, that’s largely a creation of the timber industry. I n spite of this pressure campaign, in 2010, a proposed re

write of the certified wood policy that would have created a pathway for the inclusion of S F I in L EED failed to obtain sufficient support from the U SGBC membership. Given the history, it’s deeply troubling that the new AC Paccepting SFI appears to have been developed and pushed through by U S GBC 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 S F I largely affirms the status quo , while F SC embodies environmental and social improvements in forest management, by supporting F SC
, L EEDhas played a key role in driving market transformation of the forest products industry. Unfortunately, unless the right steps are taken, the AC P has the potential to undermine this effect, which is vital for the well being of forests and forest-dependent peoples around the world.

T he saving grace is that there is language in the
new AC Pand in U S GBC’s communications around it suggesting that the purpose of the pilot is to test the feasibility of a new LEE D prerequisite requiring evidence of legality for 100% of the wood used in LEE D projects. G iven that illegal logging is rampantin many parts of the world, and trading in illegal wood is now against the law in the United S tates, the E uropean Union, Japan and A ustralia, this would be a positive step that everyone could support.

H owever, there are reasons to doubt whether this is the direction that things are actually headed. Within 24 hours of U SGBC ’s announcement of the AC P, S F I , the A merican Tree Farm S ystem and the A merican Forest & Paper Association implemented a coordinated communications plan, all releasing statements of their own. Within 72 hours, S F I even announced a new webinar “explaining” the new credit language. S uch a high degree of preparation and orchestration suggests that S F I and its allies knew this was coming for some time and that U SGBC and industry worked together on the AC P behind the scenes. 

## I do not be l ieve that this is ju st abo u t i ll ega l l ogging... I t is abo u t s upp orting res p onsib l e, certi f ied materia l s in the s uppl y chain as w e ll

. I t does o p en it up[ f or S F I and other p rograms] to be recognized f or credit in the L EEDrating system. 

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—SFI VP Ja s on Metn i ckPredictably, the industry statements make only passing reference to eliminating illegal wood, emphasizing that this is about the inclusion of their forest certification systems in L EED

. At the heart of the AC P’s flaws is the ASTM standard that it references ( D 7612-10). N ot only does this standard establish all forest certification systems as equivalent, it defines as “responsible” A LL timber logged in N orth A merica – whether certified or not! A nd its definition of legal wood is woefully inadequate. N ot surprisingly, there were no environmental groups involved in the development of this standard

I f U S GBC is serious about a legal wood prerequisite, then why didn’t they consult the leading groups working on illegal logging?

E ver since 2008 when the amended Lacey A ct made it illegal to buy or sell wood in the U S 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. S everal of them have offices conveniently located in Washington DC , including respected names like World R esources I nstitute, World Wildlife Fund, the E nvironmental I nvestigation Agency, G reenpeace and G lobal Witness. I f the AC P is truly a good faith effort to support the Lacey A ct and similar legislation in other countries by keeping illegal wood out of L EEDprojects, why didn’t U SGBC consult these groups? Why did U SGBC choose instead to rely on a flawed standard that has the S F I industry’s fingerprints all over it?

U SGBC and L EEDhave 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.



### I f the true purpose of the AC Pis not to recognize forest certification systems that are weaker than FS C and not to consecrate all N orth A merican wood as “responsible”...
I f in fact its objective is a worthy prerequisite designed to screen illegal wood out of LEE D projects...
then U S GBC needs to state this emphatically and unequivocally, correcting the misrepresentations of SFI and its allies. 

# T his is no time to step bac k from this le g ac y of lea d ership T he f act that the U SGBC has decided to treat a llcredib l e f orest management certi f ication systems as eq u a ll y acce p tab l e co ul d be cited in disc u ssions regarding w hich s u stainab l e f orest management certi f ication p rograms are acce p tab l e f or p a p er-based p rod u cts... A F&P Ahas w orked on this iss u e f or many years; it is enco u raging to see U SGBC o p en its standard to recognize a llcredib l e certi f ication systems, in a l ignment w ith o u r p o l icy. 

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—Je ffBradley, Manager Fore s t & Wood Product Pol i cy, A F&P A SFI App ro v ed logg i ng, Plu m C reek Timb erland s