FSC Equal or Better - Our Position

Regarding USGBC’s Proposed LEED MR7 Certified Wood Credit Language

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 language and benchmark will only serve to reverse advances made in forest stewardship and ecology over the past 17 years

We support an FSC Equal + Better Certified Wood Credit and in our opinion, the proposed USGBC Forest Certification Benchmark (and the related credit language) that is up for Ballot falls far short of the current MR 7 FSC standard. Given the state of forests, climate change and bio-diversity around the world, going backwards is not an option. Below are some of the key shortcomings of the benchmark that in our opinion, make the proposed MR7 Benchmark significantly LESS than the current FSC standard.


ACCOUNTABILITY and OPENNESS: As proposed, Board Members for certifying entities are NOT required to be elected by Members. This seriously undercuts accountability and openness, making it is easy for vested interests to ‘stack the deck’ or ‘take-over’ the organization.

BALANCED REPRESENTATION: There are no metrics for what constitutes ‘Balanced Representation’ for balloting, which means there are no 'teeth' for enforcing this very important governance issue. Also, a minority (1/3) of voters per chamber can ratify changes to the standard. Balanced representation would require a majority of votes per chamber for approval.

VOTING MEMBERSHIP: (This is a new topic that has come to our attention) There are NO guidelines for the cost of being a voting member. There are green building certification bodies (NOT USGBC) that have exclusionary dues ($20,000+) to be a voting member. The fees exclude many non-profits and organizations from meaningful participation. Onerous membership fees significantly diminish accountability and openness. The Benchmark should include acceptable guidelines for membership fees.

Standards Substance:

OLD GROWTH PROTECTIONS: As proposed, the Old Growth management criteria are inadequate. In simple terms the benchmark states that “Old Growth quantities should not be further diminished across the landscape” which in the U.S (except Alaska) is already very low (we’ve cut just about everything at least once). Old Growth in the U.S. should be expanded (over time), not just maintained at current levels. Also, requiring that Old Growth quantities be retained ‘across the landscape,’ instead of on a Forest Management Unit (FMU) by FMU basis, will be completely ineffective. If it is not done by the individual FMU’s being certified, who will enforce it and with what mechanism? Who will manage it and who will establish the criteria? The Prerequisite should require that every FMU be required to retain and nurture the development of Old Growth.

FOREST CONVERSION: The baseline for defining Forest Conversion to another land use is substantially inadequate allowing up to 90% of the tree cover to be cut from the land while still being considered a forest (I.E. only 10% forest cover is required in order to NOT be consider Deforested). Additionally, the “and/or” construct of the prerequisite removes nearly the entirety of value of this requirement. It allows limitless conversion to non-forest uses (deforestation) as long as it doesn’t occur on forests of special conservation value and similarly would allow conversion of forests of special conservation value as long as it was on a very limited portion of the forest.

GMO's: As proposed, the benchmark allows Genetically Modified Organisms (GMO’s) to be used. FSC bans GMO’s and this ban should be retained due to the lack of control available once modified plants are introduced into the environment. GMO’s pollute the gene pool and they are self-replicating. Genetic engineering frequently modifies plant genetics in ways that natural evolution would simply not permit; meaning that GMO’s are in effect, a human ‘veto’ overriding the basic laws of evolution. Application of the Pre-cautionary Principle, which the USGBC identifies as a guiding principle, would very clearly exclude the use of GMO’s.

HIGHLY HAZARDOUS SUBSTANCES: The benchmark does NOT provide adequate protection against the use of Highly Hazardous Substances and it relies on legal restrictions to control their use. There are still substances regularly and legally used in forest management in the US that have been shown to have a high potential for negative non-target effects. For example, a specific high-hazard herbicide has been banned in the EU due to persistent groundwater contamination, endocrine disruption, and carcinogenicity (including to mammals and amphibians). However, the same high-hazard herbicide is still widely used in the US and it is one of the most widely used herbicides in the world. Relying on governments to effectively regulate hazardous substances is little more than business as usual and it is not representative of a leadership standard. Once again, pre-caution should rule.

RARE SPECIES: The proposed benchmark does NOT protect 'Rare' species recognizing only those legally indentified for protection. The benchmark should require that forest managers assist in keeping 'Rare' species from becoming threatened or endangered. As written, the benchmark relies on government(s) to protect species instead of the certification being pro-active. Relying on governments to provide proper protection of bio-diversity is little more than business as usual and it is not representative of a leadership standard.

NON-TIMBER HARVESTING: The benchmark does NOT require that the amount of non-timber forest products harvested to be sustainable over the long-term. This can result in ‘sterilizing’ the forest and diminishing bio-diversity, an essential and vital natural capital aspect of forests worldwide.

Local Communities

THE RIGHTS OF INDIGENOUS PEOPLES: The benchmark does NOT require adequate protection for the rights of indigenous peoples. It should require that “Certification schemes require the recognition and respect of the traditional and legal rights of indigenous peoples to their lands and resources. Free and informed consent is required for other parties to manage and/or use indigenous lands and resources.”

RIGHT TO ORGANIZE: The benchmark does NOT include an adequate definition of "fair labor practices" and it should require that forest management units recognize the rights of workers to organize and voluntarily negotiate with their employers.

PUBLIC CONSULTATION: The benchmark does NOT require adequate public consultation. It limits the required consultation to those people and groups 'directly affected.' All community stakeholders should be included, not just those 'directly affected' (who decides the criteria for 'directly affected'?). Forests frequently represent a 'common resource' and their management impacts a broad audience. Management of BP's Gulf oil spill recovery fund is good example of how the interpretation of those 'directly affected' can be very exclusionary.