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USGBC Second Public Comment Period on LEED benchmark

September 29, 2009

Re: USGBC Second Public Comment Period—Recognition of Certified Wood Products in LEED

Dear Partners in Forest Stewardship:

USGBC has opened a second public comment period on the revised Forest Certification Benchmark. While we feel the Benchmark has been fundamentally improved since last year's initial draft, it is still lacking key components of exemplary forest management. If approved by a ballot of USGBC members, this Benchmark will define exemplary forestry for the USGBC and will be the measure by which forest certification programs are judged for recognition in the LEED rating system. It is critical that we, as supporters, partners, and members of USGBC, make our voice heard to ensure that none of the defining qualities of exemplary forestry are diluted, made optional or overlooked.

We also feel that it is essential that the USGBC distinguish truly environmentally and socially-sound forestry from status-quo forestry in North America. We have noted persistent questions or concerns with the proposed benchmark. Some of our more serious concerns are highlighted below:

  • There are no prerequisites for the standards-setting organization to be a membership-based organization or for the Board of Directors to be elected by the membership. USGBC's own governance structures are ignored and devalued by this omission and these structures are absolutely essential to a certification system's integrity and credibility.

  • There are no prerequisites addressing Indigenous Peoples rights—these issues are instead relegated to "distinguishing" credits. We find this omission a glaring affront to native peoples around the world and counter to USGBC's guiding principle on social equity. It is well documented that even the legally-binding rights of Native Americans and First Nations peoples have been ignored by forest managers in North America.

  • USGBC states support for forest production that does not lead to the loss of natural forest habitat, but does not include conversion of natural forests to plantations in its requirement addressing loss of forest extent. Conversion of rich natural forests to impoverished plantations is of central concern.

  • There are no prerequisites requiring public consultations to determine and verify environmental and social values of forests.

The public comment period will close on October 14, 2009. FSC-US staff will provide stakeholders with our detailed assessment of the benchmark later this week. We hope that you will take the time during the next two weeks to provide your own comments to USGBC. You will find the draft benchmark at the USGBC website.

                                                                                                                                              

Thank you for your consideration and support,
Corey Brinkema, President