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FSC Equal + Better

Updated Comments Regarding USGBC's Proposed Wood Credit

Perkins+Will's Proposed Changes for Comprehensive and Necessary Improvements to the USGBC 3rd DRAFT Forest Certification Benchmark

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As a firm dedicated to designing sustainable environments, Perkins+Will advocates for industry practices and standards that optimize ecological synergies and embrace the spirit of green building. Specifically, this means pursuing the triple bottom line of ecological integrity, economic vitality and social balance.

While we applaud the USGBC's effort to advance the green building dialogue across a wide range of competing interests, their newly proposed certified wood credit benchmark will only serve to reverse advances made in forest stewardship and ecology over the past 17 years. The proposed 3rd benchmark issued in the spring of 2010 for public comment falls far short of the current Forest Stewardship Council (FSC) standard required by LEED Credit MR 7. If adopted, the proposed benchmark would not only weaken this credit, but also the credibility of LEED certifications by allowing the use of wood materials that do not meet the triple bottom line. In order to deliver sustainable buildings, architects, designers and builders need sustainable products and we need continuous improvement. In our opinion, the FSC certification standards are a good basis from which to build.

Perkins+Will calls upon the USGBC to continue its leadership in green building. Therefore, we have developed updated comments for inclusion in the USGBC proposed forest benchmark that we believe meet or exceed the certification standards currently promulgated by FSC. We have also added optional credits that exceed FSC and address carbon accounting, tightened validation criteria for ecologically warranted clearcutting and non-forest ecosystem conversions. We believe that a number of groups or organizations could offer certifications that meet the criteria and allow for wide participation and productive levels of competition. We also offer the following additional comments:

Certification Body Governance: The USGBC's proposed 3rd benchmark seriously impedes balanced governance for Certification Bodies and removes the "teeth" from this vital prerequisite by stripping the maximum allowable votes given to "for profit" forest owners, producers and commercial interests and opening "balanced representation" to wide interpretation. The Perkins+Will proposal restores it to its previous status allocating a maximum of 1/3 of all votes to for-profit forest owners, producers, government bodies and other entities with a commercial interest in the sale of forest products.

Respects the rights of local indigenous people: Several line-items around indigenous rights are offered as Credits (e.g., they are optional) such as Tenure Rights, Special Aboriginal Sites, Traditional Knowledge and Land Tenure. These line-items should all be Prerequisites (required without exception).

Clearcutting: Establishing ecologically appropriate clearcut limits is complex and should be based on the specific conditions of the area. Perkins+Will is proposing that along with using ecological assessments to set the appropriate size, any clearcut greater than 40 acres must be justified by scientific rationale.

Pesticides, Herbicides and Pre-cautionary Substances: Some herbicides banned in the EU for persistent groundwater contamination, endocrine disruption and carcinogenicity are widely used in the US and in other parts of the world. The Perkins+Will comments re-establish the limitations on the use of Pre-cautionary Substances equal to FSC criteria, prohibiting the use of substances recognized as highly hazardous, even if they are legal.

Genetically Modified Organisms: Application of the Pre-cautionary Principle, which the USGBC identifies as a guiding principle should inform the Prerequisite for GMO's. FSC bans GMO's and this ban should be retained due to a lack of control over GMO's once modified plants and their genetic material are introduced into the environment.

Illegal Logging: USGBC proposed Prerequisites for illegal logging should be strengthened to include 2nd and 3rd-party verification of all sources coming from areas prone to illegal logging.

Perkins+Will recommends creating a 2nd Tier Regenerative Forestry Benchmark that is better than FSC and could include Carbon Calculations, Old Growth Restoration, eco-system conversions and plantations; Perkins+Will has included provisions to calculate net carbon uptake when managing forests. Other proposals include restoring lost old-growth forest, limiting the conversion of any natural eco-system to forest or other non-forest uses, plantation conversion back to natural forest after harvest and limiting ecologically appropriate clearcuts to 20 acres without scientific rationale, follow up evaluations and public observation.

We encourage other individuals and organizations to join us in our efforts to continue transforming the marketplace in order to create a healthier environment and support the triple bottom line.

More comments on the USGBC's proposed changes to the Certified Wood Credit including access to the A+D Sustainable Leaders Group open letter are available on the FSC website.