SFI argued that, as currently drafted, USGBC's benchmark system may result in the continued exclusion of independent forest certification standards used in North America, including SFI, the American Tree Farm System (ATFS), the Canadian Standards Association's Sustainable Forest Management Standard (CSA), and the Programme for the Endorsement of Forest Certification schemes (PEFC).
During the September 2009 comment period, USGBC issued 80 individual benchmarks in its second draft. SFI submitted comments on most of these benchmarks. SFI complained that in the current and third draft, only five of the benchmarks are up for review, suggesting that only five of the benchmarks have changed. "The other 75 are not available for comment, and USGBC has not provided any rationale for why it has not addressed the proposed changes to these benchmarks, instead providing casual responses such as 'the requirements were deemed appropriate.'" A representative of USGBC did not immediately respond to GBI's request for a response to SFI's criticism.
"We have patiently and constructively participated in USGBC processes for over five years, but it appears the USGBC, in its home stretch to finalize the forest certification credit, is set to continue with the status-quo policy of excluding forest-certification standards other than FSC," SFI President and Chief Executive Officer Kathy Abusow said. "This position should not be taken lightly. With more than 186 million acres (75 million hectares) certified to the SFI Standard in North America, and 197 million more acres (79 million hectares) certified to CSA or ATFS, excluding SFI means excluding well-managed, third-party certified forests and the communities and jobs that depend on them in the U.S. and Canada.
"If USGBC maintains the status quo and does not recognize the SFI Standard, many LEED [Leadership in Energy and Environmental Design] builders who chase points will turn away reputable third-party certified SFI wood, which is grown in their backyard, in this nation, and instead turn to FSC-certified wood -- the vast majority of which comes from overseas and often from countries without effective social laws. FSC has more than 30 different standards around the world, yet almost half of the FSC certifications globally are to standards that are not yet fully endorsed and do not measure up to the SFI standard for North American forests."
Abusow asserted that the USGBC forest certification policy is making North American forest management worse, not better. "USGBC seems intent on driving a monopoly for one forest certification brand over others; by promoting offshore wood over North American wood, USGBC is hurting well-managed and certified forests domestically as well as causing distress for domestic forest companies, communities, and jobs. We will continue to promote and support responsible forest management through our program and our ongoing collaboration with real environmental groups, the academic community, public agencies, forest companies, small landowners, and thousands of others."
SFI believes that a 2008 resolution from the National Association of State Foresters (NASF) explains, succinctly, the rationale for inclusive policies. The resolution states that "requirements for certification should recognize ATFS, FSC, SFI, and all other credible options.... There is no single 'best' forest certification program. The value of certification is derived from credible processes and not from brand names. Competition among certification programs produces innovation and continuous improvement in certification processes and on-the-ground forestry practices." Resolutions from the NASF require 100 percent membership approval to be passed.
SFI made the following other points in alleging that USGBC "continues to miss the bigger picture":
- Approximately 80 percent of the certified forests in North America are certified to SFI, ATFS, or CSA. "Products from these vast forests are effectively ineligible for the LEED forest certification. This is not good news for forest products produced in North America and the communities that are home to forests certified to these standards." * Just 18 percent of North America's certified forests are certified to FSC, and 60 percent of FSC's supply is from offshore. "This means that USGBC is encouraging the architects, builders, and owners of LEED-rated buildings to give preference to products from offshore, often shipped incredible distances, and to exclude wood from USGBC's backyard and are certified to SFI."
- FSC's various standards and interim standards used around the world are not stronger than SFI in North America. FSC has 31 fully accredited standards worldwide, but almost half of the FSC certifications globally are not fully endorsed to FSC standards, and many of those would likely not stand up to U.S. and Canadian forest and environmental regulations and lack the rigor of a science-based standard such as the Sustainable Forestry Initiative.
- There is a double standard in that USGBC does not require other building products, such as steel and concrete, to have third-party environmental certification to achieve a credit, yet wood third-party certified to internationally recognized standards such as SFI must clear 49 mandatory benchmarks just to be considered for a single LEED point while a bicycle rack and shower can also qualify for a LEED point.
- The trend is inclusivity. There are numerous precedents that demonstrate that the global trend is to recognize all of the major third-party forest certification standards. For example, Green Globes (U.S. and Canada), BREEAM (United Kingdom), Built Green Canada, Built Green Colorado, CASBEE (Japan), and the ANSI National Green Building Standard (U.S.) all recognize multiple forest certification standards, including SFI. The Green Building Council of Australia recently ended its FSC-only preference.
- The United Nations says USGBC's position is bad for forest certification. UNECE/FAO's Forest Products Annual Market Review reports that green building may be a mixed blessing for certification because "green building initiatives standards giving exclusive recognition to particular forest-certification brands may help drive demand for these brands at the expense of wider appreciation of the environmental merits of wood." UNECE/FAO is also concerned that the growth of certification worldwide appears to be slowing.
SFI encouraged all certification programs and supporters of forest certification worldwide to comment on the draft benchmarks and urge USGBC, its board, its steering committee, and its material and resources technical advisory group to recognize "all credible forest certification programs," including SFI, FSC, ATFS, CSA, and PEFC.
