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									Public Comments
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.

FSC IC recognizes that strong benchmarks exist in the proposed Governance benchmarks. However,
there are opportunities to strengthen the benchmarks within this section. Firstly, the benchmark on
"organizational type" should define the standard-setting organization as a membership organization
open to all groups and individuals. Secondly, the process of membership voting needs to be clearly
defined and require that the membership voting process gives equal weight to environmental, social
and economic interests.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.

The proposed governing board structure does not provide for a consensus approach, which is critical
to having an objective benchmark system. As proposed, it would be possible for a minority view to
overrule the majority. We suggest following the due process requirements as determined by ANSI.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
The Illinois Emerald Ash Borer Wood Utilization Committee welcomes the U.S. Green Building
Council's move toward a Forest Certification System Benchmark, but we want to make sure that the
new benchmarking system allows urban forests to be certified so that urban and community trees
can receive wood material credits in LEED buildings. As currently written, only forests managed for
their commodity crop value will qualify. This is not acceptable. LEED certification is supposed to
demonstrate that a building is, among other things, environmentally responsible. When certifying
wood used in buildings, which is more environmentally responsible: using wood from trees grown to
be harvested as a crop (typically) hundreds of miles away from the site or using wood (typically)
from nearby trees grown for their aesthetic benefits and felled due to insect infestation, disease,
age specific decline, safety issues, or to make way for the very project seeking certification?
Commodity forests are managed for the trees value when dead. Urban forests are managed for the
trees value while living: improving the quality of life and saving energy costs (as reflected in
increased property values). Because urban and community trees are not grown for their timber

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
No, but urban forest management system could qualify if recognized.

If yes, please explain indicate which systems comply and how they are compliant.
-

If not, please explain how the existing systems are deficient.
Urban forests are currently certified by the National Arbor Day Foundation. The most common and
recognizable program, Tree City USA, awards annual certificates to municipalities for sound
community tree management. The Growth Award, provides Tree City USA communities an
opportunity to be recognized for continual improvements in community forest management
including wood reclamation. There are complementary programs for campuses, utility rights-of-way
and military lands. However, the Tree City USA program currently does not address urban timber
harvesting in a significant way and therefore would not meet the Forest Certification System
Benchmark for LEED Certified Wood. II. LEED Certified Wood, Credit Language Revisions "certified by
a recognized certification system" replaces "FSC-certified" LEED 2009, New Construction, Certified
Wood [Comment] LEED 2009, Commercial Interiors, Certified Wood [Comment] LEED 2009, Schools,
Certified Wood [Comment] LEED 2009, Core and Shell, Certified Wood [Comment] LEED 2009,
Existing Buildings: Operations & Maintenance, Sustainable Purchasing: Ongoing Consumables
[Comment] LEED 2009, Existing Buildings: Operations & Maintenance, Sustainable Purchasing:
Facility Alterations and Additions [Comment] LEED for Homes, Environmentally Preferable Products
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
No. Perkins + Will feels that the USGBC should maintain a strong performance standard for Wood
Certification in the LEED rating system. As a reflection of the USGBC's core values, the standard
should require continuous improvement through market transformation and must retain rigorous
social and environmental requirements founded on the best available objective science. A strong
Certified Wood Credit is important because the health of our forest eco-systems and their
inhabitants is vital to the health of our planet and our civilization. Forests cover 30% of the world's
land area and store over 50% of the world's carbon. The Certified Wood credit is the only LEED
credit that explicitly establishes criteria for all three core elements of Sustainability and the Triple
Bottom Line: Environment, Economics and Social Equity. While the intent of moving to a
performance based criteria for the credit language is acceptable, the verification process for
certification is critical for the Benchmark to be successful. It must be objective and transparent. In
addition, the membership should be presented with the process before voting on the final revisions.
The Criteria for Governance - Openness - Organizational type: "Membership organizations (i.e.
organizations governed by members) are open to all major interest groups, organizations and

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
yes

If yes, please explain indicate which systems comply and how they are compliant.
The Forest Stewardship Council is a member organization.

If not, please explain how the existing systems are deficient.
The SFI BOD is elected by the existing board in a closed process. Thus the social and environmental
decision-makers are hand-selected by the existing board members.


Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
Balancing board structure - The Economic Chamber is significant in size and critical to success of the
overall program. For this reason given the chamber model used, this chamber should have a larger
voice, perhaps approaching 50%.




Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
I support the idea of benchmark criteria if it includes fully developed and consistent criteria that is
not in any way "less than" the current FSC requirement. It appears as though the current criteria are
inconsistent, not in accordance with the USGBC's Guiding Principles, and also not consistent with
the recommendations of the Yale report. Even though I support the idea of benchmark standards, I
cannot support this proposal in its current form because of flawed criteria and lack of transparent
process over time.

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
FSC
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
The Comment structure for the benchmarks is overally burdensome and confusing. As there is no
opportunity provided for general comments or overview comments, please consider the
commentors use of the first available comment box as equal to a general comments box. General
Comment on the USGBC Proposed Certified Benchmark and they are being submitted on behalf of
the AIA Minnesota Committee on the Environment by the Co-Chair, Doug Pierce, AIA, LEED AP: The
US Green Building Council (USGBC) has prepared a number of revisions to the Certified Wood credit
in all LEED rating systems. A thorough review of the benchmark finds that the revisions will greatly
diminish the criteria for certifying forests in the U.S. and around the world. A strong Certified Wood
Credit is important because the health of our forest eco-systems and their inhabitants is vital to the
health of our planet and our civilization. Forests cover 30% of the world s land area and store over
50% of the world s carbon. The LEED Certified Wood credit must continue to address the three core
elements of Sustainability; Environment, Economics and Social Equity. It should embody the
Precautionary Principle, require continuous improvement and retain rigorous requirements founded
on the best available objective science. The proposed revisions are clearly not appropriate for a
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
Yes I believe the benchmarks are sufficiently rigorous. The sections regarding the power of the
economic chamber and ownership are particularly critical.

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
I believe so.
If yes, please explain indicate which systems comply and how they are compliant.
I believe FSC complies.

If not, please explain how the existing systems are deficient.
I do not know.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
No. Please refer to the comprehensive statement submitted to the "Credit Language Revisions"
comments page by the Cascadia Chapter of the USGBC.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.

No. Any proposed benchmark must maintain the current requirement for third-party verification,
not certification by "major interest groups." The Yale Program on Forest Policy and Governance
(YPFPG) Report suggested that "those being regulated cannot dominate the standards setting
process" but this permission contradicts those recommendations. Funding - making funding sources
publicly available does not necessarily equate to openness. The contrary is possible if the financial
flow is motivated by the potential to sway regulation to assuage private interests. In addition to
publicizing monetary sources, there should be restrictions on funding that prohibit contributions
from those directly impacted by the regulations. For example, trade associations should be kept
separate from funding certification programs.

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
It is unclear, based on the vague descriptions of many of the benchmarks proposed.

If yes, please explain indicate which systems comply and how they are compliant.
it is unclear

If not, please explain how the existing systems are deficient.
it is unclear

If yes, please explain indicate which systems comply and how they are compliant.
The Forest Stewardship Council is a member organization.

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
Yes

Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
No. Perkins + Will feels that the USGBC should maintain a strong performance standard for Wood
Certification in the LEED rating system. As a reflection of the USGBC's core values, the standard
should require continuous improvement through market transformation and must retain rigorous
social and environmental requirements founded on the best available objective science. A strong
Certified Wood Credit is important because the health of our forest eco-systems and their
inhabitants is vital to the health of our planet and our civilization. Forests cover 30% of the world's
land area and store over 50% of the world's carbon. The Certified Wood credit is the only LEED
credit that explicitly establishes criteria for all three core elements of Sustainability and the Triple
Bottom Line: Environment, Economics and Social Equity. While the intent of moving to a
performance based criteria for the credit language is acceptable, the verification process for
certification is critical for the Benchmark to be successful. It must be objective and transparent. In
addition, the membership should be presented with the process before voting on the final
revisions."

If not, please explain how the existing systems are deficient.
The SFI BOD is elected by the existing board in a closed process. Thus the social and environmental
decision-makers are hand-selected by the existing board members.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.

I think they are still missing an important section of the millwork market - orchards. Much of the
cherry, walnut, and pearwoods that are milled come from orchards that have reached the end of
production cycle or become diseased. These orchards are re-planted once the trees are chopped
down so the overall life of the orchard continues. It would be a bit excessive to force farmers to
certify their orchards simply so they can be chopped down and re-planted.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
Yes, we believe the USGBC Benchmark criteria have the appropriate forest management
requirements.

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
It is not clear how the forest certification program (FSC, SFI, etc.) is recognized as conforming to the
USGBC's benchmark criteria. My hope is that this proposal is not adding another level of certification
to the certified wood requirement.

If yes, please explain indicate which systems comply and how they are compliant.
n/a

If not, please explain how the existing systems are deficient.
As a manufacturer of finished goods, I currently have FSC third-party certification at my
manufacturing facilities to promote the use of certified wood. I am afraid that my certification cost
will increase if the FSC (or other forest certification programs) are required to be certified to the
USGBC benchmarking requirements. Adding another level of certification does not appear to be the
appropriate answer.



Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
Governance: The balance required in board structure and decision-making is strong, but the lack of
requirement for "organizational type" is of great concern. There needs to be a benchmark
requirement that the standard-setting organization is a membership organization that is open to all
groups and individuals. In addition, there needs to be a benchmark requirement for membership
voting balance so that it is equally weighted between economic, social and environmental interests.
Only if both these requirements are included will the process ensure that a standard-setting
organization purporting to represent social and environmental interests actually does. Standards
Content: 1. Certification should place limits conversion and maintaining "forest extent". A standard
can and should include requirements that certificate holders prohibit or strictly limit conversion of
natural forest lands to non-forest uses or plantations. With a mixed-source label, certification should
exclude wood from conversion sources. The benchmark needs to be rewritten to explicitly restrict
conversion. Otherwise this is a huge loophole that undercuts USGBC and LEED's integrity and
credibility as a cutting-edge driver of green building. 2. As currently written, the benchmark will
leave it to each assessor of compliance to determine whether a certification program is meeting the

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
N/A

If not, please explain how the existing systems are deficient.
N/A

If yes, please explain indicate which systems comply and how they are compliant.
N/A
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
APA supports the establishment of a consensus-based decision process. As proposed, this governing
structure would allow a majority viewpoint to be overruled by a minority view. This benchmark does
not reflect the spirit of consensus-based decision making as established by ANSI, ISO, and ISEAL
standards. To create a more consensus-based governance, the USGBC needs to review the the
economic and social groupings in the supply chain and ensure their views are represented in a
balanced process.

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
While some Forest Stewardship Council standards reflect true consensus, many of the standards
lack consensus because they do not have full participation by key economic interests. Narrow
participation, in turn, has produced standards that are either economically unsustainable or are
protective of participants in unique circumstances. This does not promote sustainable forestry or
the overarching goals of the USGBC.

If not, please explain how the existing systems are deficient.


Forest certification systems that are operating in the U.S. and Canada have, as a foundation, well
developed laws, regulations, treaties and agreements that support social considerations, as well as
established judicial systems to address concerns and grievances. In developing countries that lack
this social foundation, there is a greater need for the certification programs to address social
concerns. Because the FSC system is used in many developing countries, it places more emphasis on
the social concerns and does not always take into consideration the importance of established laws
and regulations that influence forest practices in the U.S. and Canada. Because the proposed
benchmark is closely aligned with the structure of the FSC, it may cause bias against the economic
groupings that must also have a voice in a consensus-based review of forest certification systems.

If yes, please explain indicate which systems comply and how they are compliant.
FSC remains compliant. Other systems will encourage lower level compliance due to lower first cost.
This is not market transformation. This is taking a step backward.

If not, please explain how the existing systems are deficient.
X

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
FSC has been compliant and a working standard.

Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
No. it is a step backwards from existing methods. See Cacadia Region letter of Sept. 2, 2008. The
proposed yes/no vote on an undefined system and process is an insufficient opportunity to
comment upon a complex issue. Even though I support the idea of benchmark standards, I cannot
support this proposal in its current form because of flawed criteria and lack of transparent process
over time
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
Once again, mankind begins to shift in directions that are important to only them, and not to the
ecosphere that we all live on. Regarding "certification's impact on forest management", nowhere in
this document does the systems approach of sustainability emerge, except as a mention of being an
adjunct forest practices methodology, 'sustainable forestry'. Elsewhere, mention of the
"limits(on)USGBC's ability to play a leadership role in promoting effective certification themes"
feeds into my opening point: for example, what happened to consideration of the forest's role in
combatting global warming(?)- and its'inherent need for health so that it can absorb more CO2,
while offsetting other out-of-control gaseous emmissions with oxygen (?) Several years ago, I had
the occasion to visit with Christine Ervin, former CEO of the USGBC, and at that time, I mentioned to
her that the USGBC needed a better orientation to the principles of sustainability, to avoid the
tendency to be politically driven by industies' need for 'market share',or, in the case of your work
here,be in a position to have any one entity "come to dominate(the) development of
"certification"... There are market-driven examples of commerce working in tandem with sound and
ecological needs: IKEA, a 15 billion dollar global enterpriise, uses a model of working with
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
Points for USBGC consideration include: ? Balanced representation is essential to defining truly
sustainable forest management. As proposed, voting rules that do not require a consensus or a
majority vote from each interest group or a consensus or majority vote from the whole group would
be favored. This would recognize the bias inherent in the Forest Stewardship Council (FSC)
governance system. The result is that it becomes possible for a majority viewpoint to be overruled
by a minority view. Similarly, it would allow one sector to be ignored or dominated by the others,
leading to adoption of standards despite sustained opposition. This benchmark can not be defended
by the requirements of ANSI on governance, balance, or dominance, and ignores ANSI, ISO, and
ISEAL standards for consensus-based decision making. ? Some FSC standards do reflect true
consensus, where participants agreed on a consensus decision rule at the outset. Many, however,
are able to reach apparent consensus, but only because of the lack of any semblance of broad
participation by economic interests. Narrow participation, in turn, has produced standards that are
either economically unsustainable or are protective of participants in unique circumstances. The
result does not promote sustainable forestry, and thus, is contrary to USGBC's interests. ? The
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.

Balanced representation is critical to defining truly sustainable forest managment. The proposed
benchmarks simply adopts the bias inherent in the FSC governance system. It is possible, under the
proposed benchmark, for a majority viewpoint to be overruled by a minority view, a clear violation
of ANSI requirements. The need for social representation is different in the United States versus
third world nations, for example. We have a social and judicial system that addresses grievances and
concerns. This benchmark is too closely aligned with the FSC program and should be modified to
avoid bias.

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
Most of the proposed benchmarks are objective criteria and consistent with internationally
recognized assessments for determining the quality of certification systmes.

If yes, please explain indicate which systems comply and how they are compliant.
I have very familiar with the language and requirements of the major forest certification programs.
Existing certification systems should be able to meet most of the benchmarks in the current draft.
That includes FSC, SFI, PEFC, ATFS, and CSA.

If not, please explain how the existing systems are deficient.
I do not believe they are.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
No, the proposed benchmarks do not establish appropriate program requirements. Balanced
representation is essential to defining truly sustainable forest management. The USGBC benchmarks
on this issue simply propose to adopt the bias inherent in the Forest Stewardship Council (FSC)
governance system. As proposed, voting rules that do not require a consensus or a majority vote
from each interest group or a consensus or majority vote from the whole group, would be favored.
The result is that it becomes possible for a majority viewpoint to be overruled by a minority view.
This benchmark cannot be defended by the requirements of ANSI on governance, balance, or
dominance. Some FSC standards do reflect true consensus, where participants agreed on a
consensus decision rule at the outset. Many, however, are able to reach apparent consensus, but
only because of the lack of any semblance of broad participation by economic interests. Narrow
participation, in turn, has produced standards that are either economically unsustainable or are
protective of participants in unique circumstances. The result does not promote sustainable
forestry, and thus, is contrary to USGBC's interests. The interests of all entities in the supply chain
are not aligned. In most cases, their interests are competing. It is inappropriate to pre-determine an
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
NO - the benchmarks are not fully developed (many are mere subjects/topic headers rather than
normative requirements that a certification program must meet) and, as such, SFI and American
Tree Farm (in the U.S.) and PEFC (internationally) will be able to achieve recognition probably
without much effort. USGBC needs to substantially improve the benchmarks so that the
fundamental differences between FSC and SFI are properly revealed and so that SFI is not allowed to
qualify for the MR point credit.

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
NO

If not, please explain how the existing systems are deficient.
SFI/ATF is an industry developed and controlled program that fails to require real leadership in
forest management which stands in stark contrast with the "L" in "LEED"
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
This benchmark is too closely aligned with the FSC program and should be modified to avoid system
bias.

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
There is a bias in the Forest Stewardship Council (FSC) governance system which results in a majority
viewpoint to be overruled by a minority view.

If yes, please explain indicate which systems comply and how they are compliant.
Narrow participation, can produce standards that are either economically unsustainable or are
protective of participants in unique circumstances.

If not, please explain how the existing systems are deficient.
The need for social representation is not consistent, nor required across all forest certification
systems.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.

Yes. The benchmark and standards should govern, and not any particular certifying organization

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
PEFC standards conform to the USGBC benchmarks, at least in concept. I have not studied in detail
to ensure that all specifics match, but the USGBC benchmarks will provide the basis for PEFC
adjustments

If yes, please explain indicate which systems comply and how they are compliant.
All the specific USGBC benchmark standards appear to match similar standards in PEFC, ATFS, at
leastin concept.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
The VFPA membership feels that balanced representation and a consensus-based decision process
are essential to defining truly sustainable forest management. As proposed, voting rules that do not
require a consensus or a majority vote from each interest group or a consensus or majority vote
from the whole group would be favored. This would recognize the bias inherent in the Forest
Stewardship Council (FSC) governance system. The result is that it becomes possible for a majority
viewpoint to be overruled by a minority view. Similarly, it would allow one sector to be ignored or
dominated by the others, leading to adoption of standards despite sustained opposition. This
benchmark can not be defended by the requirements of ANSI on governance, balance, or
dominance, and ignores ANSI, ISO, and ISEAL standards for consensus-based decision making. We
recognize that selective FSC standards do reflect true consensus, where participants agreed on a
consensus decision rule at the outset. Many, however, are able to reach apparent consensus, but
only because of the lack of any semblance of broad participation by economic interests. Narrow
participation, in turn, has produced standards that are either economically unsustainable or are
protective of participants in unique circumstances. The result does not promote sustainable
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
Overall the proposed benchmarks related to governance are appropriate; however some need to be
modified or clarified in order for them to have maximum benefit to the LEED standard. These are: A.
Governance and Board Structure: 1) Forest owners, producers and all entities participating in the
forest product supply chain limited to economic chamber/sector; 2) Economic chamber/sector
afforded no more than 1/3 vote. Use caution with this definition of "economic" members. As
currently defined, the term does not recognize that forest owners, producers and "all entities
participating in the forest product supply chain" all maintain separate functions when participating
on boards of forest certification programs. B. Level of Standard Setting: 1) International or national-
level standards provide a performance baseline. 2) There are opportunities for development of sub-
national indicators in larger federated countries. The intent of this benchmark should be clarified. If
the USGBC seeks flexibility to adapt to local conditions, then the benchmark should be re-written to
clarify this, but should not be meant to mandate that all international forest certification programs
must develop separate local standards. Also recognize that when a certification program has
multiple standards, the standards can vary widely and it is essential for these differences be

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
All of the major forest certification programs at play in North America have strong governance
structures in place, though clarification and modifications to the benchmarks in question 1 are
needed.

If yes, please explain indicate which systems comply and how they are compliant.
SFI Inc follows all relevant ISO guidelines in both the accreditation and labeling aspects of SFI's
program. SFI Inc is a fully independent non-profit organization devoted to improving responsible
forest management through the comprehensive SFI program. SFI certification is open to all types of
landowners, including non profit organizations, academic institutions, family forest landowner and
public agencies. Its volunteer Board of Directors represents environmental, social and economic
interests equally. The three-chamber structure of SFI Inc.'s Board of Directors ensures that the SFI
program represents economic, environmental and social needs equally. Board members include
representatives of environmental, conservation, professional and academic groups, independent
professional loggers, small family forest owners, public officials, labor and the forest products
industry. The SFI Board is broken out by Economic, Environmental and Social sectors. The social
sector represents a wide variety of stakeholders, which are inherently different than the economic
or environmental sectors. These currently include, but are not limited to, public officials, such as
State Foresters, labor representatives, academics and community level representatives. Clause 5 of
Bylaws of the SFI, Inc states that 'In order to ensure that no Sector of the Board of Directors can

If not, please explain how the existing systems are deficient.
FSC "certifies" forests in areas where accredited standards do not exist. Many times, these are just
checklists created by a certification body and have not completed full public consultation, nor has it
had input from a broad range of stakeholders.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.

USGBC should determine what other wood sustainabilty rating systems that are acceptable before
making change final to the LEED rating systems to be more clear to uers.

If not, please explain how the existing systems are deficient.
The SFI BOD is elected by the existing board in a closed process. Thus the social and environmental
decision-makers are hand-selected by the existing board members.

Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.


No. Perkins + Will feels that the USGBC should maintain a strong performance standard for Wood
Certification in the LEED rating system. As a reflection of the USGBC's core values, the standard
should require continuous improvement through market transformation and must retain rigorous
social and environmental requirements founded on the best available objective science. A strong
Certified Wood Credit is important because the health of our forest eco-systems and their
inhabitants is vital to the health of our planet and our civilization. Forests cover 30% of the world's
land area and store over 50% of the world's carbon. The Certified Wood credit is the only LEED
credit that explicitly establishes criteria for all three core elements of Sustainability and the Triple
Bottom Line: Environment, Economics and Social Equity. While the intent of moving to a
performance based criteria for the credit language is acceptable, the verification process for
certification is critical for the Benchmark to be successful. It must be objective and transparent. In
addition, the membership should be presented with the process before voting on the final revisions.
Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
Yes

If yes, please explain indicate which systems comply and how they are compliant.
The Forest Stewardship Council is a member organization.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.

I do believe the benchmarks relating to forest certification establish good requirements.

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?

I would like to see other certification systems incorporated into the LEED program. For example, the
American Tree Farm System is the oldest certification system in the United States, and the most
widely available to private forest landowners. This is a very good system with a great membership of
concerned landowners. Since most of the forestland in the US is privately held (especially the
eastern US), this is a great way to get the common landowner more involved with sustainable
forestry and certified wood.

If yes, please explain indicate which systems comply and how they are compliant.
ATFS has undergone rigorous changes to become more stringently audited. In my professional
opinion, the sytem requirements for Tree Farm closely mirror the requirements for the benchmarks.
I beleive the same could be said for SFI certification as well. SFI in particular is very good at chain of
custody requirements.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
The Louisiana Society of American Foresters strongly advocates the revision of LEED Standard and
Benchmark Criteria to include wood which is produced from forests that are certified by
organizations approved by the PERFC. Most importantly in the U.S., this enlargement would also
include ownership certified under the Sustainable Forestry Initiative (SFI) and within the Tree Farm
System. Such an enlargement would incorporate into LEED, the additional emphasis on quality of
harvesting operations which is required by SFI, in the form of required continuing logger training
(which is not a part of FSC). Additionally, SFI involves the committment to continued review and
improvement of its criteria, as demonstrated by the current review underway. Furthermore, it is of
extreme importance for such an important authorization system as LEED to recognize: 1) all systems
which are as stringent or more-so than FSC, 2) to provide for the inclusion of products produced
from all of the landowners of the U.S. who own and value and commit their forests for a sustainable
future. Members of the Louisiana Society of American Foresters are involved with all of the
certification systems, and we assert that LEED could only be strengthened by the enlargement
advocated herein. by: William F. Wieger, Certified Forester, for the Louisiana SAF
Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
FSC complies with current benchmarks, but actually is less stringent than SFI in the logging
component.

If yes, please explain indicate which systems comply and how they are compliant.
See above.

If not, please explain how the existing systems are deficient.
The limitation of approved certification systems to recognize only FSC, produces a less than
optimum category of Standards and Benchmark Criteria for LEED.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.


No. Perkins + Will feels that the USGBC should maintain a strong performance standard for Wood
Certification in the LEED rating system. As a reflection of the USGBC's core values, the standard
should require continuous improvement through market transformation and must retain rigorous
social and environmental requirements founded on the best available objective science. A strong
Certified Wood Credit is important because the health of our forest eco-systems and their
inhabitants is vital to the health of our planet and our civilization. Forests cover 30% of the world's
land area and store over 50% of the world's carbon. The Certified Wood credit is the only LEED
credit that explicitly establishes criteria for all three core elements of Sustainability and the Triple
Bottom Line: Environment, Economics and Social Equity. While the intent of moving to a
performance based criteria for the credit language is acceptable, the verification process for
certification is critical for the Benchmark to be successful. It must be objective and transparent. In
addition, the membership should be presented with the process before voting on the final revisions.

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
Yes

If not, please explain how the existing systems are deficient.
The SFI BOD is elected by the existing board in a closed process. Thus the social and environmental
decision-makers are hand-selected by the existing board members.

If yes, please explain indicate which systems comply and how they are compliant.
The Forest Stewardship Council is a member organization.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
No, these proposed changes completely undermines the core value of high performance buildings.
The proposed yes/no vote on an undefined system and process is an insufficient opportunity to
comment upon a complex issue. We are being asked to vote on a benchmark standard that has not
been defined in detail and appears to be lacking critical information. We support the idea of
benchmark criteria if it includes fully developed and consistent criteria that is not in any way "less
than" the current FSC requirement. It appears as though the proposed criteria are inconsistent, not
in accordance with the USGBC's Guiding Principles, and also not consistent with the
recommendations of the Yale report. This blantant disregard will undermine the credibility of USGBC
and will appear that the USGBC lessoned the standards to allow large production forestry
companies to undermine the standards of high-performance buildings. We urge the tag committee,
USGBC board, stakeholders, members, etc to visit the following site for more information:
www.dontbuysfi.com. Why are we proposing to weaken the most riquorous forestry scheme with
one that is diluted and does not appear to offer transperency, openess, disverse govering
stakeholder group.

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
YES

If yes, please explain indicate which systems comply and how they are compliant.
FSC -
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.


The USGBC benchmarks on this issue simply propose to adopt the bias inherent in the Forest
Stewardship Council (FSC) governance system. As proposed, voting rules that do not require a
consensus or a majority vote from each interest group or a consensus or majority vote from the
whole group, would be favored. The result is that it becomes possible for a majority viewpoint to be
overruled by a minority view. This benchmark can not be defended by the requirements of ANSI on
governance, balance, or dominance. Some FSC standards do reflect true consensus, where
participants agreed on a consensus decision rule at the outset. Many, however, are able to reach
apparent consensus, but only because of the lack of any semblance of broad participation by
economic interests. Narrow participation, in turn, has produced standards that are either
economically unsustainable or are protective of participants in unique circumstances. The result
does not promote sustainable forestry, and thus, is contrary to USGBC's interests.

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?

If not, please explain how the existing systems are deficient.
The benchmark is too closely aligned with the FSC program and should be modified to avoid system
bias.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
Yes. We support the benchmark approach and general concept and policy criteria as outlined but we
do feel that overall the governance benchmarks are too prescriptive. We believe that the
benchmark assessment should focus on the objectives of inclusiveness, fairness, consensus and
transparency. As such, prescriptive benchmarks should be relied on only where attainment of
objectives is not evident.

If not, please explain how the existing systems are deficient.
Not applicable.

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?

Yes. The four standards used in British Columbia and Canada - the Canadian Standards Association's
Sustainable Forest Management Standard (CSA), the Forest Stewardship Council (FSC), the
Programme for the Endorsement of Forest Certification schemes (PEFC), and the Sustainable
Forestry Initiative (SFI) - all comply with the Governance objectives.

If yes, please explain indicate which systems comply and how they are compliant.


The four standards used in British Columbia and Canada - CSA, FSC, PEFC and SFI - all measure up to
the objectives of inclusiveness, fairness, consensus and transparency. Various other benchmarking
exercises such as that conducted by the Central Point of Expertise on Timber have concluded that
the predominant North American forest certification standards are compliant. The four programs all
provide for compliance with international normative institutions. They have open membership, and
clear and established governance structures and decision-making processes. And they all remain
current and relevant through a regular standard review cycle (approximately every 5 years).
International governments, notably the United Kingdom, Germany, France, European Union, Japan,
New Zealand and Switzerland, have reached similar conclusions through their research of these
standards, and recognize all four standards in operation in North America.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.

Question: Who, or what body, will determine if a forest meets the benchmark requirements? Will a
list of these forests be available so that contractors/suppliers can determine where to buy the
certified wood? I assume FSC certified will still apply to this credit, or will even currently FSC
certified forests need to undergo the new evaluations? On the surface, this seems like a good move
as it will include forests that are responsible to a high level, but for one reason or another do not
carry the FSC label. However, there will be a negative reaction to this change if it is time consuming
or difficult to ascertain which sources produce wood that will earn the point. Thank you. Charles
Cinamella, P.E., LEED AP, The Whiting-Turner Contracting Company
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
No. Perkins + Will feels that the USGBC should maintain a strong performance standard for Wood
Certification in the LEED rating system. As a reflection of the USGBC's core values, the standard
should require continuous improvement through market transformation and must retain rigorous
social and environmental requirements founded on the best available objective science. A strong
Certified Wood Credit is important because the health of our forest eco-systems and their
inhabitants is vital to the health of our planet and our civilization. Forests cover 30% of the world's
land area and store over 50% of the world's carbon. The Certified Wood credit is the only LEED
credit that explicitly establishes criteria for all three core elements of Sustainability and the Triple
Bottom Line: Environment, Economics and Social Equity. While the intent of moving to a
performance based criteria for the credit language is acceptable, the verification process for
certification is critical for the Benchmark to be successful. It must be objective and transparent. In
addition, the membership should be presented with the process before voting on the final revisions.

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
yes.

If yes, please explain indicate which systems comply and how they are compliant.
The Forest Stewardship Council is a member organization.

If not, please explain how the existing systems are deficient.
The SFI BOD is elected by the existing board in a closed process. Thus the social and environmental
decision-makers are hand-selected by the existing board members.

If yes, please explain indicate which systems comply and how they are compliant.
Decline Comment until Benchmark and Process are Defined

If not, please explain how the existing systems are deficient.
Decline Comment until Benchmark and Process are Defined

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
Decline Comment until Benchmark and Process are Defined

Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
Openness; organizational type These benchmarks are not adequate. It is not clear that the
organizational type must actually be a membership organization in the first place. In addition to
their existing requirements, the benchmarks should require that organizations be membership
based-otherwise, the benchmarks regarding the make-up of membership-based organizations will
not be consistently applied. This is a crucial benchmark and should be mandatory. Balance;
governing board structure These benchmarks are not adequate. There is no clear requirement that
governing boards be comprised of an equal balance of economic, environmental, and social
interests. The influence of each of these three sectors should also be more clearly limited to 1/3
vote. In addition, the certification systems' governing boards should be elected by a membership
that is balanced among economic, social, and environmental interests. Otherwise, the benchmarks
can permit certification systems whose boardmembers may be affiliated with different stakeholder
sectors, but who do not actually represent the views of the persons and organizations comprising
those stakeholder sectors. This is a crucial benchmark and should be mandatory. Balance; governing
board decision-making Balance requirements should not be limited to "balloted" decisions. This is a
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
General comments: There are strong benchmarks in the governance section requiring balance in
board structure and decision-making. However, there are some concerns regarding the
"organizational type" (there is no benchmark requirement that the standard-setting organization is a
membership organization that is open to all groups and individuals) and concerns regarding
membership voting balance (like the board, the membership vote should be equally weighted
between economic, social, and environmental interests). The missing benchmarks are central to
ensuring that a standard-setting organization that purports to represent social and environmental
interests in fact does so. Comments on specific benchmarks: Openness-Organizational type:
Membership organizations (i.e. organizations governed by members) are open to all major interest
groups, organizations and individuals. In all cases, the standards-setting organization should be a
membership organization and it should be open to all interest groups, organizations, and individuals.
The benchmark should explicitly state this. The benchmark should require that a standard-setting
organization is a membership-based and open to all major interest groups, organizations, and
individuals. This is the only way to ensure balanced stakeholder representation and a credible and

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
Decline comment until benchmarks and process are better defined.

If yes, please explain indicate which systems comply and how they are compliant.
Decline comment until benchmarks and process are better defined.

If not, please explain how the existing systems are deficient.
Decline comment until benchmarks and process are better defined.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
Include LEED for Homes retroactively as well: If approved, the revised credits would apply to LEED
2009. The approved revised credit would be available as an alternative compliance path for all pre-
LEED 2009 rating systems that include explicit reference to the Forest Stewardship Council (LEED for
New Construction and Major Renovation v2.2, LEED for Schools 2008, LEED for Commercial Interiors
v2.0, LEED for Existing Buildings v2.0, and LEED and Core and Shell v2.0) ----AND LEED FOR HOMES.
Why is LEED for Homes only requiring certification for Tropical Wood? 2.1 "Tropical Wood" certified
by a system recognized by USGBC as conforming to its Forest Certification System Benchmark.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
Overall I believe it is a good draft. There are some things I don't understand: 1. In the structure of a
certification I understand the desire to require membership from several types of interested parties
to ensure the interests of all are taken into consideration. I don't fully understand the definition of
"economic" members. Not all owners of forests actually own forests for a traditional definition of
economic interest. I'd suggest adding wording that better differentiates from a profit-seeking
organization from those that do not seek profits. 2. I think the Level of Standard Setting needs to be
thought out a little. I've never understood how the FSC systems works and is policed, and I don't
believe it does or is. Just seems to loosely worded to work. 3. Isn't dispute resolution best served
closer to the certification level? My company is part of another organization, the Architectural
Woodwork Association. Their related Quality Certification Program has an arbitration solution to
disputes, but it is relevant only to projects. The standard, though, as are all standards just like yours,
is created through concensus and future updates NOT through dispute resolution programs. Do you
have such a program for LEED?

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
From my knowledge I believe so.

If yes, please explain indicate which systems comply and how they are compliant.

I believe FSC, SFI and PEFC likely do. As to how, I'm not certain I have the time for all the detail.
Likely you're getting an earfull from plenty of others plus you have staff to verify this. I don't know
about CSA, but I'd guess they do. American Tree Farm might, but I'm not as certain.

If not, please explain how the existing systems are deficient.

My only big concern here is with FSC. They were created to help fight the ravishing of the rain
forests yet it seems most of their standards exist elsewhere. Meanwhile they will certify forests that
have no local or national standards. How do they do that? I've never understood why you allied
yourself so closely to an organization that is so non-inclusive. CARB in California does a much better
job if including all stakeholders in their standard development process. FSC just resists any input and
constructive criticism. That's one reason I like the fact you folks are finally doing this.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
No, the requirements for balanced and equal representation need to aligned with ANSI Essentail
Requirements: Due process requirements for American National Standards Edition: January 2003;
ISO /IEC Guide 59:1994. Do not adopt FSC governance system. This benchmark is too closely aligned
with the FSC program and should be modified to avoid system bias.

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?

Not appropriate for commentors to rate existing systems against a proposed set of benchmarks.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
No. The Criteria for Governance - Openness - Organizational type: "Membership organizations (i.e.
organizations governed by members) are open to all major interest groups, organizations and
individuals." should be changed. Proposed Revision: Membership organizations (i.e. organizations
governed by members) open to all major interest groups, organizations and individuals. USGBC
should maintain a strong performance standard for Wood Certification in the LEED rating system. As
a reflection of the USGBC's core values, the standard should require continuous improvement
through market transformation and must retain rigorous social and environmental requirements
founded on the best available objective science. A strong Certified Wood Credit is important
because the health of our forest eco-systems and their inhabitants is vital to the health of our planet
and our civilization. Forests cover 30% of the world's land area and store over 50% of the world's
carbon. The Certified Wood credit is the only LEED credit that explicitly establishes criteria for all
three core elements of Sustainability and the Triple Bottom Line: Environment, Economics and
Social Equity. While the intent of moving to a performance based criteria for the credit language is
acceptable, the verification process for certification is critical for the Benchmark to be successful. It

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
yes

If yes, please explain indicate which systems comply and how they are compliant.
The Forest Stewardship Council is a member organization.

If not, please explain how the existing systems are deficient.
The SFI BOD is elected by the existing board in a closed process. Thus the social and environmental
decision-makers are hand-selected by the existing board members."
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
NO SFI - ONLY FSC Wood should be considered
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
How will LEED applicants be able to determine that a particular rating system meets the established
benchmark/ criteria? As an architect, how will I have confidence in specifying a certification
providor? Will there be a list on the USGBC website? On a past job, we specified a certification
system--not FSC--and lost the credit as a result. As a consequence, we have been leery of pursuing
the certified wood credit

If not, please explain how the existing systems are deficient.
I think the whole comment process is very unfriendly, and it is QUITE DIFFICULT to really understand
the proposed changes. Keith Hayes, keithhayes@brsarch.com
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
Overall the proposed benchmarks related to governance are appropriate; however some need to be
modified or clarified in order for them to have maximum benefit to the LEED standard. These are:
Proposed Benchmark - Governance and Board Structure: 1) Forest owners, producers and all entities
participating in the forest product supply chain limited to economic chamber/ sector; 2) Economic
chamber/ sector afforded no more than 1/3 vote. We caution the USGBC on its definition of
"economic" members. For example, under this definition, an organization like The Nature
Conservancy, who sits on the Board of FSC US, would qualify as "economic" as they are a forest
owner. TNC, while a forest owner, does not maintain economic gain as a top priority in owning
forest land, instead they value the environmental services over all other aspects of forest
management. Family forest owners often value aesthetics, wildlife habitat and family legacy over
economic gain, and cannot be considered on the same level as forest product companies, which are
meant to comprise the "Economic" sector. Loggers are important community members. They are
often a first point of contact for the public and landowners and represent an important role in the
labor force. The USGBC should recognize that, board members such as TNC, family forest owners,

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
While the clarification and modifications above are needed, the major forest certification programs
in North America all have strong governance structures in place.

If yes, please explain indicate which systems comply and how they are compliant.
Proposed Benchmark - Compliance w/ international normative institutions: Scheme is consistent
with ISO and/or ISEAL codes of good governance, or their equivalent. SFI Inc follows all relevant ISO
guidelines in both the accreditation and labeling aspects of SFI's program. From the July 2008 APQ -
Certification bodies must follow International Standard ISO 19011:2002, Guidelines for Quality
and/or Environmental Management Systems Auditing, in auditing to the SFI Standard and
International Organization for Standardization (ISO) 17021:2006 conformity assessment-
requirements for bodies providing audit and certification of management systems; and all SCC and
ANAB requirements. Proposed Benchmark - Organizational type: Membership organizations are
open to all major interest groups, organizations and individuals. SFI Inc is a fully independent non-
profit organization devoted to improving responsible forest management through the
comprehensive SFI program. Its volunteer Board of Directors represents environmental, social and
economic interests equally. The three-chamber structure of SFI Inc.'s Board of Directors ensures that
the SFI program represents economic, environmental and social needs equally. Board members
include representatives of environmental, conservation, professional and academic groups,
If not, please explain how the existing systems are deficient.

FSC certifications occur in some countries where there are not fully endorsed standards, but draft
standards, which may not have completed a stakeholder review process. Some FSC certifications are
granted on checklists created by a certification body, yet forests can be "certified" and carry an FSC
label. Almost half of all FSC's reported certified lands happen in countries where there is no fully
endorsed FSC standard.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
Overall the proposed benchmarks related to governance are appropriate; however some need to be
modified or clarified in order for them to have maximum benefit to the LEED standard. These are:
Governance and Board Structure: 1) Forest owners, producers and all entities participating in the
forest product supply chain limited to economic chamber/ sector; 2) Economic chamber/ sector
afforded no more than 1/3 vote. The USGBC should use caution with this definition of "economic"
members. For example, under this definition, an organization like The Nature Conservancy, who sits
on the Board of FSC US, would qualify as "economic" as they are a forest owner. TNC, while a forest
owner, does not maintain economic gain as a top priority in owning forest land, instead they value
the environmental services over all other aspects of forest management. Family forest owners value
aesthetics, wildlife habitat and family legacy over economic gain, and cannot be considered on the
same level as forest product companies, which are meant to comprise the "Economic" sector.
Loggers are important community members. They are often a first point of contact for the public
and landowners and represent an important role in the labor force. The USGBC should recognize
that, board members such as TNC, family forest owners, and loggers, maintain a separate function

If not, please explain how the existing systems are deficient.
FSC has many standards around the world, and they vary widely with respect to environmental
protection and sustainability. We suggest that if FSC is accepted, USGBC must clarify which of the
standards comply and which do not.

If yes, please explain indicate which systems comply and how they are compliant.
SFI Inc follows all relevant ISO guidelines in both the accreditation and labeling aspects of SFI's
program. SFI Inc is a fully independent non-profit organization devoted to improving responsible
forest management through the comprehensive SFI program. SFI certification is open to all types of
landowners, including non profit organizations, academic institutions, family forest landowner and
public agencies. Its volunteer Board of Directors represents environmental, social and economic
interests equally. The three-chamber structure of SFI Inc.'s Board of Directors ensures that the SFI
program represents economic, environmental and social needs equally. Board members include
representatives of environmental, conservation, professional and academic groups, independent
professional loggers, small family forest owners, public officials, labor and the forest products
industry. The SFI Board is broken out by Economic, Environmental and Social sectors. The social
sector represents a wide variety of stakeholders, which are inherently different than the economic
or environmental sectors. These currently include, but are not limited to, public officials, such as
State Foresters, labor representatives, academics and community level representatives. Clause 5 of
Bylaws of the SFI, Inc states that 'In order to ensure that no Sector of the Board of Directors can
Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?

While the clarification and modifications above are needed; the major forest certification programs
at play in North America all have strong governance structures in place.

If not, please explain how the existing systems are deficient.
USGBC needs to be impartial! Keep overall perspective for USGBC to hold would be this: If it can be
proven that ANY Certification does NOT result in forests being renewed it is not worth consideration
for inclusion. There are great sources available to do this. Use the knowlege and experience of our
University's Forestry departments and our National Forest Products Lab for starters. We have many
foresters who are brilliant and could help write meaningful guidelines and assessments for for this
Certified Wood Credit. Use them to your advantage. Also, including people from the building
industry in a sub-committee within MR would be useful. Then we could finally have the people who
have to use the credit involved in writing a credit that works really well. We also need to look at
having a credit for all the building plans and books printed on Certified Paper. We also need to have
a credit just becuase you used wood as opposed to finite resources. More credit needs to be given
to use wood as it is CARBON NEGATIVE and really isn't that what sustainable building is about?
Suggesting the use of Steel, Concrete and other finite materials in place of wood is wrong when you
compare the generation of carbon in the creation of these other building materials to wood. The

If yes, please explain indicate which systems comply and how they are compliant.
There are 56+ Certifications that we know of at AWI (Architectural Wood Work Institute). Many of
these were used as a basis for FSC to write theirs. USGBC is NOT in for forestry business and should
wisely distance itself from being a judge of this. It should be assigned to Yale to look at all of them
and compare them to each other for their acceptability. Out of 56+ certifications it should be
possible to find at a minimum, 20 of them do in fact do a wonderful job of sustainable forestry
management.

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
SFI, American Tree Farm System, CSA, IBAMA, many of the 27 western European Contries have
individual certifications addressing their local regions goverance, culture, environment, etc. These
are mostly covered by PEFC.

Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
For the most part. This is a very good beginning to something that makes sense. Allowing only one
certification system when many great ones are already in use is widely seen as an implication of
exclusivity and an illegal restraint of trade. There is the threat of a class action lawsuit brewing
which would be very bad for USGBC. Thank you for using Yales great document on this issue to get
back on track to effectively writing criterial for the Certified wood Credit. Encourage responsible
forest management. Many systems already do that. If we don't include them, is misleads users of
LEED into thinking other certifications are not seriously doing that. Additionally, this leads LEEDP-
AP's into thinking they only have to write the letters "FSC" after the wood they select to get it and
the availability is not there. For example, FSC says they have 220million acres certified but in reality,
only a small fraction of that has timber used for building materials. Most are for paper production
crops and conservation (state, county, etc)It has created a huge availability issue.

If yes, please explain indicate which systems comply and how they are compliant.

The FSC provides one example of a certification system with an open membership where the vote in
equally weighted between economic, social and environmental interests. In addition, it is critical
that the Boards be elected by the membership, not selected by the Board itself.

Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.

I concur with the comments of the FSC-US. It is critical that the governance structure of any
certification organizatiion be an open membership organization and that there be a balance of
different interest groups, i.e. economic, environmrntal and social sectors in order to avoid a self-
certifying system where those being regulated cannot dominate the standard setting process.

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
Yes, I think the FSC's Governance system would exceed the Governance requirements being
proposed in these USGBC benchmarks.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
No, the proposed requirement of "balanced" government violates the USGBC's own standards for
consensus decision-making and violates ISO, ISEAL and ANSI decision-making standards. It would
jeopardize the acceptance of LEED by government agencies and otherwise defeat the Council's goal
of increasing the integrity and acceptance of the forest certification provision. The proposal on
board structure and governance would allow a standard to be adopted without a consensus, which
is defined by ISO as "general agreement, characterized by the absence of sustained opposition to
substantial issues by any important part of the concerned interests and by a process that involves
seeking to take into account the views of all parties concerned and to reconcile any conflicting
argument." Consensus is not the same as unanimity, and one way to achieve consensus is to use
super-majority voting rules to ensure an important interest is not dominated. The proposal would
achieve the opposite, however: it would allow a standard to be adopted despite the opposition -
sustained or not - of a majority of an interest group. The proposal's isolation of perceived economic
interests is also improper, as discussed by others. If this were corrected and the voting changed to
require at least a majority of each interest group (preferably 2/3), then the process could be viewed

If not, please explain how the existing systems are deficient.

An additional issue the Council must address is FSC's certification under proprietary standards
developed by the auditors. These are inconsistent with ISO, ANSI, and ISEAL, but do offer a source of
certifications in countries lacking the infrastructure to develop regional standards.

If not, please explain how the existing systems are deficient.

The need for social representation is not consistent across all forestry certification ("FC") systems.
However, the major FC programs operating in North America have a foundation of well-developed
set of laws, regulations and agreements that support social considerations.

If yes, please explain indicate which systems comply and how they are compliant.
.PEFC is a global umbrella organization for the assessment of and mutual recognition of national FC
schemes developed in a multi-stakeholder process. Among their principles is to recognize the
importance of economic, social and environmental realities.

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
The major Forestry Certification ("FC") programs operating in North America all have strong
governance structures in place.

Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
.Overall, the proposed benchmarks related to governance are appropriate. We support balanced
representation in achieving sustainable forest management.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
No. The USGBC should maintain a strong performance standard for Wood Certification in the LEED
rating system. As a reflection of the USGBC's core values, the standard should require continuous
improvement through market transformation and must retain rigorous social and environmental
requirements founded on the best available objective science. While the intent of moving to a
performance based criteria for the credit language is acceptable, the verification process for
certification is critical for the Benchmark to be successful. It must be objective and transparent. In
addition, the membership should be presented with the process before voting on the final revisions.

If yes, please explain indicate which systems comply and how they are compliant.
The Forest Stewardship Council is a member organization.

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
Yes

If not, please explain how the existing systems are deficient.
The SFI BOD is elected by the existing board in a closed process. Thus the social and environmental
decision-makers are hand-selected by the existing board members.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.


No. Perkins + Will feels that the USGBC should maintain a strong performance standard for Wood
Certification in the LEED rating system. As a reflection of the USGBC's core values, the standard
should require continuous improvement through market transformation and must retain rigorous
social and environmental requirements founded on the best available objective science. A strong
Certified Wood Credit is important because the health of our forest eco-systems and their
inhabitants is vital to the health of our planet and our civilization. Forests cover 30% of the world's
land area and store over 50% of the world's carbon. The Certified Wood credit is the only LEED
credit that explicitly establishes criteria for all three core elements of Sustainability and the Triple
Bottom Line: Environment, Economics and Social Equity. While the intent of moving to a
performance based criteria for the credit language is acceptable, the verification process for
certification is critical for the Benchmark to be successful. It must be objective and transparent. In
addition, the membership should be presented with the process before voting on the final revisions.

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?

No. The Criteria for Governance - Openness - Organizational type: "Membership organizations (i.e.
organizations governed by members) are open to all major interest groups, organizations and
individuals." should be changed. Proposed Revision: Membership organizations (i.e. organizations
governed by members) open to all major interest groups, organizations and individuals

If yes, please explain indicate which systems comply and how they are compliant.
Yes. "The Forest Stewardship Council is a member organization."
If not, please explain how the existing systems are deficient.
The SFI BOD is elected by the existing board in a closed process. Thus the social and environmental
decision-makers are hand-selected by the existing board members.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
Balance Governing board structure 1) Forest owners, producers and all entities participating in the
forest product supply chain limited to economic chamber/sector; 2) Economic chamber/sector
afforded no more than 1/3 vote. **PROPOSED Add 3) Board Elections are an open process.
Establishment of the governing body (Board of Directors) should be an open process, conducted by
vote of the membership, and the membership should be open to all interested parties. The SFI BOD
is elected by the existing board in a closed process. Thus the social and environmental decision-
makers are hand-selected by the existing board members. Forest extent No specific benchmark -
Not considered an issue that certification can effectively address. **PROPOSED Proposed Revision:
Forest conversion to plantations or non-forest shall not occur except: limited areas, not High
Conservation Value Forest and leads to long-term conservation benefits. Consider conversion of
abandoned agriculture and treeless lands into forest with proven long term conservation benefits
only. Carbon storage No specific benchmark - No measurable requirements found in existing
schemes. **PROPOSED Proposed Revision: Maintain and appropriately enhance forest resources
and their contribution to global carbon cycles according to the best available science and emerging

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
Yes, FSC.

If yes, please explain indicate which systems comply and how they are compliant.
The FSC standard complies with all benchmarks with exception of the proposed carbon storage
change above in comment 1.

If not, please explain how the existing systems are deficient.

The SFI BOD is made up of six members of each chamber (balanced). But, the voting rules are set up
such that each vote is calculated independent of the chamber representation. Thus, although BOD
decisions require 80% of those present, and each chamber requires a minimum of two
representatives for quorum, there are cases where the economic chamber can have more than one-
third vote (i.e. six economic members, two social, and two environmental present equals ten total
(good for quorum), and in this case the economic chamber would constitute sixty percent of the
vote). Regarding public input, SFI has a single, non-variable standard (does not comply). ATFS does
not comply with 6 of the benchmark criterium. ATFS also does not comply with the proposed
changes in comment 1. CSA does not comply with 2 of the benchmark criterium. CSA also does not
comply with the proposed changes in comment 1. SFI does not comply with 2 of the benchmark
criterium. SFI also does not comply with the proposed changes in comment 1. PEFC does not comply
with 2 of the benchmark criterium. PEFC complies with the proposed changes in comment 1 with
exception of keeping board elections open.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
SFPA supports the benchmarks for the Governance section with the exception of language
discussing board structure and board decision-making. Numerous types of forest certification
systems exist, all of which are designed from a variety of social, economic and environmental
circumstances. Using such narrowly scoped language will limit LEED's ability to adopt and utilize
other forest certification systems.

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
Credible forest certification systems should qualify for the majority of the benchmarks set for LEED
2009.

If yes, please explain indicate which systems comply and how they are compliant.
No Comment

If not, please explain how the existing systems are deficient.
No comment.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
The proposed benchmarks appear to assume that "balance" can only be obtained through a
"Chamber"system. Yet, those certification schemes with chamber systems fail to achieve balance
and by not involving intergovernmental processes and outcomes fail to obtain global legitimacy
since they represent no one other than their dues payign members. this is especially a problem for
developing countries.

If not, please explain how the existing systems are deficient.

It isn't that that a system complies or does not comply it is that the benchmark is inadquate.
"Balance" needs to be defined based on its outcome not on a particular structure. One can obtain
balance by relying on internationaly accepted processes for all standards whereby the democratic
goverance of the standard is assured. Or one can claim balance based on a particular mix of votes
and be completely out of balance because the participants do not themselves represent a balanced
population. If ENGO's refuse to participate in one system and the majority of forest products
companies refuse to participate in another system one could claim that neither has balance. No
entirely private system can substitute for the legitimacy of government. Both of the largest
international systems need to reach out to and ensure participation of either governments, the only
duly authorized political institutions on the planet or base their standards on the outcomes of
government processes.

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
It seems as if the Governance requirements were developed along the lines of FSC. Since FSC has no
place for government involvement it appears that USGBC is taking on and incorporating this
vulnerability into its system.
If not, please explain how the existing systems are deficient.
See above

If yes, please explain indicate which systems comply and how they are compliant.
See above

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
See above

Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.


(Same comment for all four sections of the proposed benchmarks:) If the proposed benchmarks do
not exclude SFI or other PEFC certification systems, then I think the proposal is okay. If they exclude
these systems, LEED is creating another forest certification system on top of those that already
exist, and it seems to be doing so even though benchmarks are nonexistent, or at least uncommon,
elsewhere in the LEED ratings. I don't know the answer to the following, but are there benchmarks
for harvesting of bamboo, or for modes of transport within the 500-mile radius, or for the
manufacture of bike racks, or for recycling of metals? If, politically, benchmarks are the best way to
appease the FSC-only crowd, then I support them. But, sooner or later, the FSC-only folks are going
to have to accept that there are other schemes that generate sustainable wood products. We
should be rewarding the use of forest products, not acting to restrict them.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
No,I don't believe so. While I do think that the idea to move sustainable wood requirements beyond
the provenance of any one organization is sound, I don't believe the proposed LEED changes are
specific or tangible enough and risk watering down the intent of the standard. For instance, just
because an organization is "open" to all member types does not necessarly mean that they will be
included. Also, just having a formal appeals process does not guarantee that such a process will be
fair.

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
Not sure.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.

The sole inclusion of FSC materials is restrictive, because of the lack of material available in the
marketplace. The LEED-H program, in order to be effective, must have other options that the FSC
Certified Material. The percentage of lumber to other framing materials is far greater. There is far to
little FSC Dimensional lumber in the marketplace to satisfy the potential marketplace.
Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?

I believe that the SFI and CSA standards adhere to the same stringent forestry practices as the FSC.

If not, please explain how the existing systems are deficient.
The FSC oftentimes certifies forests in areas where accredited standards do not exist.

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
Major forest certification programs in NA all have strong goverance structures in place.

If yes, please explain indicate which systems comply and how they are compliant.

SFI Inc follows all relevant ISO guidelines in both accreditation and labeling. The SFI program is open
to all types of landowners, including non profit organizations, academic institutions, family forest
landowner and public agencies. It is important to me in the interest of promoting responsible forest
management that the largest block of forest land owned by family forest landowners be recognized.

Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
The USGBC should recognize that board members such as The Nature Conservancy, family forest
owners, and loggers, maintain a separate function when participating on boards of forest
certification programs. The PEFC has an established endorsement process with set criteria and
requirements that all programs must met in order for a national certification program to be
endorsed. The USGBC should focus on whether or not the certification program's standard setting
process is credible.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
Yes. Many of the proposed benchmarks are appropriate and consistent with internationally
recognized protocol for various certification systems, however some of the benchmarks are
prejudicial towards one certification system and should be adjusted to remove such bias. Also,
governance could be improved by creating benchmarks for "procurement" and "continuous
improvement."

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
Yes.

If yes, please explain indicate which systems comply and how they are compliant.
Several systems such as PEFC, CSA, FSC, SFI and Tree Farm.

If not, please explain how the existing systems are deficient.
No comment.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.

The USGBC benchmark is seriously flawed and perpetuates the existing bias favoring the Forest
Stewardship Council (FSC) governance system. As proposed, a minority viewpoint could overrule a
majority view. The proposal is not compatible with ANSI requirements on governance, balance or
dominance. A true consensus or majority vote are core essentials not met by the benchmark as
proposed. Balanced representation and a transparent consensus based decision process are
essential, but not contained in the benchmark as currently written. Labor should not be part of
"economic." The need for "social representation" should be limited to developing countries.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
While RMS believes balanced representation is essential to defining truly sustainable forest
management, the USGBC benchmarks on this issue as proposed do little more than adopt the bias
inherent in the Forest Stewardship Council (FSC) governance system. As proposed, the voting rules
do not require a consensus or a majority vote from each interest group or a consensus or majority
vote from the whole group. The result is that it becomes possible for a majority viewpoint to be
overruled by a minority view. Similarly, it would allow one sector to be ignored or dominated by the
others, leading to adoption of standards despite sustained opposition. This benchmark can not be
defended by the requirements of ANSI on governance, balance, or dominance, [1] and ignores ANSI,
ISO, and ISEAL standards for consensus-based decision making. RMS supports changes that seek
consensus from all chambers, or at least a modification of the benchmark as proposed to eliminate
any real or perceived FSC bias. Also, the need for social representation is not consistent across all
forest certification systems. For example, a forest certification system functioning in the United
States and/or Canada has the foundation of a well developed set of laws, regulations, treaties and
agreements that support social considerations. In addition, there is a well established judicial system

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
Not fully

If not, please explain how the existing systems are deficient.
As proposed, the voting rules do not require a consensus or a majority vote from each interest
group or a consensus or majority vote from the whole group. The result is that it becomes possible
for a majority viewpoint to be overruled by a minority view. Similarly, it would allow one sector to
be ignored or dominated by the others, leading to adoption of standards despite sustained
opposition. This benchmark can not be defended by the requirements of ANSI on governance,
balance, or dominance, [1] and ignores ANSI, ISO, and ISEAL standards for consensus-based decision
making. RMS supports changes that seek consensus from all chambers, or at least a modification of
the benchmark as proposed to eliminate any real or perceived FSC bias. Also, the need for social
representation is not consistent across all forest certification systems. For example, a forest
certification system functioning in the United States and/or Canada has the foundation of a well
developed set of laws, regulations, treaties and agreements that support social considerations. In
addition, there is a well established judicial system to address concerns and grievances. In countries
without this social foundation, there is more justification for the forest certification system to
address social concerns.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
Overall the proposed benchmarks related to governance are appropriate; however some need to be
modified or clarified in order for them to have maximum benefit to the LEED standard. These are: A.
Governance and Board Structure: 1)Forest owners, producers and all entities participating in the
forest product supply chain limited to economic chamber/sector; 2) Economic chamber/sector
afforded no more than 1/3 vote. Use caution with this definition of "economic" members. As
currently defined, the term does not recognize that forest owners, producers and "all entities
participating in the forest product supply chain" all maintain separate functions when participating
on boards of forest certification programs. B. Level of Standard Setting: 1) International or national-
level standards provide a performance baseline. 2) There are opportunities for development of sub-
national indicators in larger federated countries. The intent of this benchmark should be clarified. If
the USGBC seeks flexibility to adapt to local conditions, then the benchmark should be re-written to
clarify this, but should not be meant to mandate that all international forest certification programs
must develop separate local standards. USGBC should also recognize that when a certification
program has multiple standards, the standards can vary widely and it is essential for these

If not, please explain how the existing systems are deficient.
FSC "certifies" forests in areas where accredited standards do not exist. Many times, these are just
checklists created by a certification body and have not completed full public consultation, nor has it
had input from a broad range of stakeholders.

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
All of the major forest certification programs at play in North America have strong governance
structures in place, though clarification and modifications to the benchmarks in question 1 are
needed.

If yes, please explain indicate which systems comply and how they are compliant.
SFI Inc follows all relevant ISO guidelines in both the accreditation and labeling aspects of SFI's
program. SFI Inc is a fully independent non-profit organization devoted to improving responsible
forest management through the comprehensive SFI program. SFI certification is open to all types of
landowners, including non profit organizations, academic institutions, family forest landowner and
public agencies. Its volunteer Board of Directors represents environmental, social and economic
interests equally. The three-chamber structure of SFI Inc.'s Board of Directors ensures that the SFI
program represents economic, environmental and social needs equally. Board members include
representatives of environmental, conservation, professional and academic groups, independent
professional loggers, small family forest owners, public officials, labor and the forest products
industry. The SFI Board is broken out by Economic, Environmental and Social sectors. The social
sector represents a wide variety of stakeholders, which are inherently different than the economic
or environmental sectors. These currently include, but are not limited to, public officials, such as
State Foresters, labor representatives, academics and community level representatives. Clause 5 of
Bylaws of the SFI, Inc states that 'In order to ensure that no Sector of the Board of Directors can
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
The following is comment on the proposed revisions to the certified wood credit's intent and
requirements: I am a designer at an architecture firm working on LEED projects. In addition to
design work my firm also provides administrative and consulting services for LEED work. In this
capacity I have worked on in excess of 12 LEED registered projects. In the course of my work I have
been exposed to much SFI literature criticizing the USGBC and LEED certification. SFI claims to
sustainability and 'green' are often misleading and are offered as strategic marketing rather than
any genuine commitment to sustainability. The proposed change to the certified wood credit is a
disappointing response from the USGBC to the lobbying efforts of a certification body whose origins
and current representatives are the most wealthy commercial logging and forestry product
corporations. I understand that the inception of LEED building certification involved a difficult and
complex balancing act between effective environmental actions and realistic approaches to the
market. The goal most communicated by the USGBC is market transformation. Within the last
several years LEED certification have seen unprecedented growth. Now that LEED has this
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
No. I feel that the USGBC should maintain a strong performance standard for Wood Certification in
the LEED rating system. As a reflection of the USGBC's core values, the standard should require
continuous improvement through market transformation and must retain rigorous social and
environmental requirements founded on the best available objective science. A strong Certified
Wood Credit is important because the health of our forest eco-systems and their inhabitants is vital
to the health of our planet and our civilization. Forests cover 30% of the world's land area and store
over 50% of the world's carbon. The Certified Wood credit is the only LEED credit that explicitly
establishes criteria for all three core elements of Sustainability and the Triple Bottom Line:
Environment, Economics and Social Equity. While the intent of moving to a performance based
criteria for the credit language is acceptable, the verification process for certification is critical for
the Benchmark to be successful. It must be objective and transparent. In addition, the membership
should be presented with the process before voting on the final revisions No. The Criteria for
Governance - Openness - Organizational type: "Membership organizations (i.e. organizations
governed by members) are open to all major interest groups, organizations and individuals." should
Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
yes

If yes, please explain indicate which systems comply and how they are compliant.
The Forest Stewardship Council is a member organization

If not, please explain how the existing systems are deficient.
The SFI BOD is elected by the existing board in a closed process. Thus the social and environmental
decision-makers are hand-selected by the existing board members

If yes, please explain indicate which systems comply and how they are compliant.
Yes, FSC is compliant as previously described.

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
The FSC certification is the only comprehensive certification system.

If not, please explain how the existing systems are deficient.
NA

Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.


The proposed benchmark allows for other certification systems outside FSC to be considered for the
LEED credit. The primary difference between FSC and other certifications has to do with the way
decisions are made and who is supporting the systems. The FSC standard is oriented toward
environmental issues from economic, social and ecosystems perspectives. Other certification
systems come from the producer perspective and focus around forest management practices. The
FSC certification should be recognized as the only comprehensive environmental certification.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
In theory and in general terms, Marvin supports the proposed changes to the LEED forest
certification credit language and the forest certification system benchmark. Most notably, the
change in language to allow all systems that meet a defined benchmark is good. Marvin has long felt
that preclusion of credits for SFI, Tropical Forest Foundation's Verified Reduced Impact Logging
Standard, or other qualified sustainable forestry programs does not help promote the progress of
green or environmental initiatives. This previous restrictive wood certification policy, in our eyes,
does not promote USGBC or LEED as a progressive program truly engaged in developing and
growing sustainable environmental manufacturing and building practices. With that being said, this
proposed change to the program better positions USGBC to lead and broaden the environmental
responsibility push in the construction industry. Allowing other qualified and approved wood
certification programs is a good start. However, Marvin has some concern to supporting the changes
carte blanche due to the ambiguity in some of the language, particularly as it relates to the
benchmarks. Creating a benchmark that generically models FSC requirements, therefore still
denying other certification programs, diminishes the opportunity that this credit revision truly

If not, please explain how the existing systems are deficient.


FSC should be named as the benchmark in the standard, and other forestry standards should meet
that standard. That is what the ISO governance calls out - a membership-based representing all
interested parties - on a platform of solid universal standards. FSC stands for sustainably grown and
harvested wood/bamboo products. It represents verifiable, substantiated acceptable forest
management practices reflecting values inherent in biodiversity, social and economic justice without
any need to explain what it means. That is one of the most important distinctions that set FSC apart
from other and many less robust standards. The naming of other forest industry standards will imply
they are accepted under the proposed USGBC benchmarks (now ambiguous and open to
interpretation), and will only confuse the designer and general contractor and other LEED users, and
worse undercut the market transformation. In closing, we find many areas of concern in the draft
wood benchmark document. The US-FSC has submitted comprehensive comments (8/28/08) which
we have reviewed and are in support of.

If yes, please explain indicate which systems comply and how they are compliant.


FSC should be named as the benchmark in the standard, and other forestry standards should meet
that standard. That is what the ISO governance calls out - a membership-based representing all
interested parties - on a platform of solid universal standards. FSC stands for sustainably grown and
harvested wood/bamboo products. It represents verifiable, substantiated acceptable forest
management practices reflecting values inherent in biodiversity, social and economic justice without
any need to explain what it means. That is one of the most important distinctions that set FSC apart
from other and many less robust standards. The naming of other forest industry standards will imply
they are accepted under the proposed USGBC benchmarks (now ambiguous and open to
interpretation), and will only confuse the designer and general contractor and other LEED users, and
worse undercut the market transformation. In closing, we find many areas of concern in the draft
wood benchmark document. The US-FSC has submitted comprehensive comments (8/28/08) which
we have reviewed and are in support of.
Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?


FSC should be named as the benchmark in the standard, and other forestry standards should meet
that standard. That is what the ISO governance calls out - a membership-based representing all
interested parties - on a platform of solid universal standards. FSC stands for sustainably grown and
harvested wood/bamboo products. It represents verifiable, substantiated acceptable forest
management practices reflecting values inherent in biodiversity, social and economic justice without
any need to explain what it means. That is one of the most important distinctions that set FSC apart
from other and many less robust standards. The naming of other forest industry standards will imply
they are accepted under the proposed USGBC benchmarks (now ambiguous and open to
interpretation), and will only confuse the designer and general contractor and other LEED users, and
worse undercut the market transformation. In closing, we find many areas of concern in the draft
wood benchmark document. The US-FSC has submitted comprehensive comments (8/28/08) which
we have reviewed and are in support of.

Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.


FSC should be named as the benchmark in the standard, and other forestry standards should meet
that standard. That is what the ISO governance calls out - a membership-based representing all
interested parties - on a platform of solid universal standards. FSC stands for sustainably grown and
harvested wood/bamboo products. It represents verifiable, substantiated acceptable forest
management practices reflecting values inherent in biodiversity, social and economic justice without
any need to explain what it means. That is one of the most important distinctions that set FSC apart
from other and many less robust standards. The naming of other forest industry standards will imply
they are accepted under the proposed USGBC benchmarks (now ambiguous and open to
interpretation), and will only confuse the designer and general contractor and other LEED users, and
worse undercut the market transformation. In closing, we find many areas of concern in the draft
wood benchmark document. The US-FSC has submitted comprehensive comments (8/28/08) which
we have reviewed and are in support of.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
General comments: There are strong benchmarks in the governance section requiring balance in
board structure and decision-making. However, there are some concerns regarding the
"organizational type" (there is no benchmark requirement that the standard-setting organization is a
membership organization that is open to all groups and individuals) and concerns regarding
membership voting balance (like the board, the membership vote should be equally weighted
between economic, social, and environmental interests). The missing benchmarks are central to
ensuring that a standard-setting organization that purports to represent social and environmental
interests in fact does so. Comments on specific benchmarks: Openness-Organizational type:
Membership organizations (i.e. organizations governed by members) are open to all major interest
groups, organizations and individuals. In all cases, the standards-setting organization should be a
membership organization and it should be open to all interest groups, organizations, and individuals.
The benchmark should explicitly state this. The benchmark should require that a standard-setting
organization is a membership-based and open to all major interest groups, organizations, and
individuals. This is the only way to ensure balanced stakeholder representation and a credible and
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.

Based on the comments in Credit Language Revision section, we feel it is unnecessary to comment
on specific benchmarks. However, we encourage USGBC to ensure that its final benchmarks are
written to avoid any unfair bias toward one certification system over another. As the different
certification systems are working to address the challenges in certification for the hardwood
community, we urge USGBC to keep the door open for an assessment process that assures a fair and
balanced review of each certification system.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
Several benchmarks within the governance section appropriately address important issues such as
public disclosure of funding sources and continual standards improvement. We appreciate the
opportunity to comment on those benchmarks which we feel establish inappropriate program
requirements. The American Tree Farm System (ATFS) believes in the value of diverse and balanced
participation in the development and management of a sustainable forest certification system. We
do not believe that the governing board structure and governing board decision-making benchmarks
appropriately capture the spirit of balanced representation. We believe that this benchmark unfairly
excludes forest certification systems with a governing board structure that does not follow a sector
based system. Under the current benchmark language, family forest landowners representing their
community of small, private landowners on a forest certification system's governing board would be
considered members of the economic sector as forest owners. Family forest landowners are an
important part of their communities and are as much a part of the social sector as the economic.
The requirements for a balanced governing board structure and decision-making procedures would
be improved by the elimination of specific requirements for each stakeholder sector. The
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
A. In general, yes. However, the USGBC, as an organization, is not developing the LEED tools under
an accredited standards development process, but it is making efforts to change how internationally
recognized building codes and standards are developed. This poses a challenge because the USGBC
is trying to inject its specific interests and concerns via their LEED tools into a very credible codes
and standards development system. The USGBC is surely aware of the detail and technical rigour
that goes into any standards development process as it moves to try and get LEED accepted as a
standard within the building and construction sector. It is our belief that the USGBC is attempting to
ensure its values regarding green buildings and sustainable development are incorporated into the
manufacturing and use of a particular material. However, if this is the intent, and to ensure
openness, equity and transparency between all materials, the USGBC must be involved in
developing the quality control, environmental and social standards for every component of the
building. Clearly, this is currently not the approach of the USGBC. In this regard, the business of
determining benchmarks and performance criteria should be undertaken by a nationally or

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
Yes. All four systems used in Canada -- the Canadian Standards Association's Sustainable Forest
Management Standard (CSA), the Forest Stewardship Council (FSC), the Programme for the
Endorsement of Forest Certification schemes (PEFC), and the Sustainable Forestry Initiative (SFI) -
comply with the governance benchmarks.

If yes, please explain indicate which systems comply and how they are compliant.

All four forest certification standards in Canada - CSA, FSC, PEFC and SFI - meet the objectives of
inclusiveness, fairness, consensus and transparency. Various other benchmarking exercises such as
that conducted by the Central Point of Expertise on Timber have concluded that the predominant
North American forest certification standards are compliant. The four programs all provide for
compliance with international normative institutions. All the systems encourage a diverse and open
membership, and have clear and established governance structures and decision-making processes.
All of the systems are reviewed on a regular basis, as well. Each standard has been recognized in an
international context as well.

If not, please explain how the existing systems are deficient.
N/A
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.

Yes, generally the requirements around system governance are appropriate. We would make the
following specific suggestion: - "Balance - Governing board structure". This requirement should be
for a balanced representation of all interests (not just the economic sector).

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
Yes. The major credible and recognized systems used in Canada (CSA, FSC, PEFC and SFI) all comply
with the proposed governance requirements.
If yes, please explain indicate which systems comply and how they are compliant.

The general concepts under "Governance" are reflected in all systems (CSA, FSC, PEFC, SFI).
Decisions are made with representation from a balance of social, economic and environmental
interests. All the systems have standards that apply to public and private lands, can be used for both
large and small forest areas, and include environmental objectives and performance measures. They
all meet common international requirements, are developed in a multi-stakeholder process, and are
endorsed by the global programs FSC International and the Programme for the Endorsement of
Forest Certification schemes (PEFC).

If not, please explain how the existing systems are deficient.
Not applicable.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
Balance - Governing board decision-making: Globally, forest certification schemes / standards are
developed in various socio-economic as well as political conditions. Therefore USGBC should define
an objective and result to be achieved rather than to prescribe a mechanism of how to achive the
result (such a mechansim also poses the danger of potentially violating national laws). Instead of
defining a three chamber system (established and promoted by FSC) USGBC should define that the
standard setting body / forum shall have procedures which provide for balance representation of
interest categories (and provide a list of categories which USGBC sees as important and relevant
stakeholders) and that the formal approval of the standard shall be based on the evidence of
consensus amongst the stakeholders. It should be left to the standard setting body and its
stakeholders to define a practical and the most appropriate procedures to achieve this objective.
ISO practices and documents (e.g. ISO Guide 59) should be referred to. Level of Standard Setting:
The issue should be clarified. USGBC should differentiate between the requirements for the
standard setting and structure / content of the forest management standards. Concerning the
standard setting procedures and "level of the standard setting" USGBC should recognize that it is
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.

No. Openness - Organizational type - Membership organizations (i.e. organizations governed by
members) are open to all major interest groups, organizations and individuals. Proposed Revision:
Membership organizations (i.e. organizations governed by members) open to all major interest
groups, organizations and individuals Balance - Governing board structure -1) Forest owners,
producers and all entities participating in the forest product supply chain limited to economic
chamber/sector; 2) Economic chamber/sector afforded no more than 1/3 vote. Proposed Revision:
Add 3) Board Elections are an open process

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
No

If not, please explain how the existing systems are deficient.
FSC comes close, but needs to work on being open to diverse size of ownership.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
The requirements are good, however; access to approved programs for small and medium sized
private landowners must always be taken into account. Most private landowners have no interest in
participating unless it is cost effective, less time consuming or the cost is passed on to others in the
form of higher prices for wood.

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
Undecided

If yes, please explain indicate which systems comply and how they are compliant.
I think most can adapt to reasonable benchmarks.

If not, please explain how the existing systems are deficient.
unsure
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.

Wisconsin Division of Forestry believes this benchmark is too closely aligned with the FSC program
and should be modified to avoid system bias. The benchmark unfairly excludes forest certification
systems with a governing board structure that does not follow a sector based system. The
requirements for a balanced governing board structure and decision-making procedures would be
improved by the elimination of specific requirements for each stakeholder sector. The benchmark
addressing openness by ensuring that processes and standards are accessible to all ownership sizes
and types establishes an inappropriate program requirement. Forest certification systems vary in
their scope and purpose.

If not, please explain how the existing systems are deficient.

FSC-US could fail in respect to "Openness - Organizational Type". Although FSC bylaws require the
system to be open and accessible to all landowners, FSC-US policies have made participation by the
U.S. Forest Service next to impossible. FSC-US is going through a process to possibly recognize USFS
land, but the sincerity of the effort could be challenged on the basis of delays and technical barriers
that opponents have put up. FSC bylaws also do not allow Governmental representatives (including
state and federal agencies) to be voting members of FSC.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
Balance - Governing board structure. This benchmark should apply to all sectors/interests. We
suggest that it focus on the intent of securing a balanced representation of all interest groups. As
each CSA Technical Committee has its own Terms of Reference (TOR), we are assuming that this
benchmark applies to the forestry program (which shall have a TOR that meets the benchmark).
Balance - Governing board decision-making. We suggest rewording this benchmark to "Balloted
decisions are supported by at least 1/3 of each interest-based chamber/sector". This will clarify that
the words "approval from 1/3rd of each sector" do not necessarily have to be found in the
organization's terms of reference, as long as that intent is achieved. For example in the CSA system,
a Technical Committee develops and maintains the standard in an inclusive process. Interests
represented on the Technical Committee include forestry academics and researchers, forest
companies, environmental groups, consumers, labour unions, Aboriginal people and government
regulators. Consensus decisions from a balanced membership matrix are sought and unanimous
votes are aimed for. Should a "no" vote be cast, all attempts must be made to reconcile it. No
balloted decision is approved if it doesn't have the support of the majority of each interest category.

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
Yes, standard development systems in particular have strong processes in place to ensure standards
are developed in a balanced and fair way.

If yes, please explain indicate which systems comply and how they are compliant.
CSA was established in 1919 and has a long, rich history in the development of consensus-based
standards using internationally recognized and accredited standards development processes. The
CSA system meets all the governance requirements of the proposed LEED benchmarks. In addition,
it provides independence and transparency between the process of developing the standard, the
approval of the standard and accreditation of the certifiers. Because it was developed for a country
where the vast majority of forest operations occur on public lands, public input requirements in the
CSA system are particularly strong. Over 55 public consultation groups operate in CSA certified
forests across Canada. They participate at the local community level in the development and
monitoring of CSA Sustainable Forest Management Plans and ongoing forestry discussions.
Additionally, they often participate in the development of various forestry plans required under
provincial regulations. Committee members represent a variety of interests, including other land
users (trappers, fishermen, gatherers, recreationalists etc.), local communities, businesses, forest
workers, Aboriginal people, environmental groups, technical experts, researchers and academia,
government agencies, and forest managers. This high degree of public involvement reflects the

If not, please explain how the existing systems are deficient.
Not Applicable
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
It is important to recognize that several systems currently being used voluntarily do not represent
true performance standards. Any system that does not result in consistent implementation is not
truly a performance standard. Implicit in establishing a performance standard must be the concepts
of consistently meeting a set of independently developed requirements, regardless of the candidate
certification holder. Where performance levels are determined locally by the candidate certification
holder, consistency, transparency and independence are surrendered along with no small degree of
credibility. This is dangerous ground, as having ineffective systems at play within the LEED program
can only subvert the environmental, social and market advantages of a well-developed and credible
third-party certification requirement. It could also ultimately constitute a liability to the program if a
clear threshold of certification performance cannot be articulated. Some critical parameters for a
credible certification system include: (1) Balanced development - the standard has been developed
with broad-based stakeholder involvement, and not dominated by any one perspective, particularly
the forest sector that it is intended to certify. A true test of this is the social and environmental
"licences" provided by widespread endorsement of a certification scheme by the industry's most
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.

No. 2/3 of the input is from individuals and organizations that have no economic interest in the
growth, manufacturing or distribution of the certified products. In the eastern U.S., landowners and
industry are separate, and do not represent the same interests.

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
Only FSC.

If yes, please explain indicate which systems comply and how they are compliant.
The benchmark IS the FSC governance structure!

If not, please explain how the existing systems are deficient.
PEFC: At least 8 of the 12 PEFC board members represent landowners or forest products industries;
twice as many as would be allowed under the LEED (FSC) benchmark.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
LEED Certified Wood, Forest Certification System Benchmark The following comments represent the
position of the State of Oregon by and through the Oregon Department of Forestry, Oregon Forest
Resources Institute, and the Oregon Department of Energy. More information relevant to these
comments is available upon request. The State of Oregon does not support elements of the
proposed forest certification system benchmark that essentially restate Forest Stewardship Council
standards. The USGBC is encouraged to coordinate with the international Programme for the
Endorsement of Forest Certification (PEFC). PEFC already has a mature system for evaluating forest
certification systems in place and has established itself as the dominant global organization for this
purpose. Rather than developing a redundant new system for evaluating certification systems,
USGBC should consider developing an alliance with PEFC. The Oregon Board of Forestry has also
developed draft Oregon principles and recommended elements for the evaluation of voluntary,
market-based, forest management certification systems. The USGBC is encouraged to consult these
principles and elements and incorporate them where applicable into the proposed Benchmarks.
Important Oregon principles applicable to Governance are described below: Governance
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
I have spent over 40 years at every level of the Forest Products industry, and currently work for an
international non-profit trade association. I understand the issues in a unique way due to a unique
and long experience. First I agree with approving as many responsible forest certification scheme's
as possible. If an American Lumber Standard can apply to innumerable lumber grading agencys of
many very different softwood species across a huge number of mills, you had better not think the
industry will support LEED if they insist on pnly one. What I wish to add to your understanding is
this. The forests in true danger of destruction, usually by burning, are tropical and subtropical
forests. If LEED finds it necessary to rate such long distance sources of solid wood products less
valuable in construction in the most valuable market on earth, you make the products of those
forests worth less, and thereby put the match book into the hands of those who otherwise burn
those forests. Making LEED valuable in the United States, the products of such forests makes those
endangered forests worth cultivating and managing for both sustainable, and profitable operation.
You need to be aware that actions you take in deciding such value can make the difference in poor

If not, please explain how the existing systems are deficient.

What remains deficient is LEED requiring FSC certification from mills in British Columbia when
except for a miniscule piece of First Nations property, FSC has yet to even provide the criterea for
certification of forests in BC. I am sick to death of telling people the Western Red Cedar mills in my
industry have no FSC certified lumber, when we have such Canadian government control of BC
forests they are all being managed for sustainability, and have been for decades. SFI and CSA have
certified virtually all of my industries mills production, so it is not for a desire of the mill owners to
act responsibly, it has been, and continues to be a lack of FSC to get the job done in British
Columbia, for a long time.

If yes, please explain indicate which systems comply and how they are compliant.
If you do not understand the differences in the four forest certification systems, bring them all into
the discussion, and don't expect people who do not represent them, like me, to explain their
requirements for forest certification. Since 90% of all the certified forests in the world are here in
North America, a question you might ask is just how much forest in North America wasn't being, and
is still not being, sustainably managed. I never hear of any, and I'm in a position to know.

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?

Have you consulted the USDA Forest Products Laboratory (www.FPL.FS.FED.US) who are actual
experts with science behind them, to make the necessary decisions ? If not you are not well
informed about the issues, this is a U.S. Taxpayer owned resource filled with immense, and often
very relevant knowledge of what is needed to continued forest health in the forests of North
America, and often elsewhere on this planet. Chris Risbrudt, Director of the Forest Products
Laboratory would be worth inviting to this discussion. I am a member of a committee at the Forest
Products Laboratory, and have been for a number of years, this on line form is unsuitable to more
that can be said on these topics.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
I believe that all American grown wood should be included in and approved for LEED use. Studies
and reports, year after year, show that America is growing more wood than is being harvested. We
also know that the sound forestry practices that occur in the US allow for healthy forests that
remove carbon from the air. When a tree is healthy and growing carbon is taken from the air and
replaced with oxygen. When a tree stops growing and eventually starts to decay, this processed is
reversed, which is just one reason to keep the forests healthy by tree removal. Not to mention that
wood itself is recyclable, re-usable and biodegradable. I think it is unfair to say only those that PAY
the FSC the big bucks to have their forests or wood certified are worthy of having thier wood used in
LEED building projects. What if the closest FSC certified wood for a particular projcet is 500 miles
away, but a sawmill 5 miles down the road has the exact same wood, cut from a forest in which Best
Management Practices were used, but does not have specific certification from the Forest
Stewardship Council. How can one agree that it is a better decision to waste the fuel it takes to drive
500+ miles to get the FSC certified wood, than to use the wood available, close by, that is just as

If not, please explain how the existing systems are deficient.
N/A

Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
Overall, yes. The General Concepts and Policy Criteria are appropriate. However, a number of the
benchmarks are quite specific and prescriptive. This does not appear to be in keeping with the
USGBC stated objective for transparency. As an example, under "Governance", the benchmarks
described for "Governing board structure" and the "Governing board decision-making" criteria are
quite specific. While such structure can support the general concept of "Balance" the USGBC seeks,
it is not difficult to imagine other organizational structure that would be able to achieve that
balance. For instance, the USGBC's own Board structure recognizes twelve different Membership
Groups It is thus suggested that the benchmarks should be written in a way that describes the
desired outcome or result rather than a specific means to achieve the General Concept identified.

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?

Yes. It is believed that the four standards we are familiar with in British Columbia (Canadian
Standards Association - CSA, Forest Stewardship Council - FSC, Sustainable Forestry Initiative - SFI,
Programme for the Endorsement of Forest Certification schemes - PEFC) all comply with the
Governance requirements although they may accomplish them in slightly different fashions.

If yes, please explain indicate which systems comply and how they are compliant.

The four standards in use in British Columbia (Canadian Standards Association - CSA, Forest
Stewardship Council - FSC, Sustainable Forestry Initiative - SFI, Programme for the Endorsement of
Forest Certification schemes - PEFC) have all been found to be equivalent against performance
objectives and principles of transparency, inclusiveness and consensus decision making.
Independent government sponsored reviews of these schemes such as the one done in the UK have
reached the same conclusions. These four systems are compliant with international norms such as
ISO, they have open membership, are governed by established transparent rules, structures and
decision making processes. These standards all undergo regular reviews and updates that are
available to the public and stakeholders for comments.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
WTCA - Representing the Structural Building Components Industry comment: With respect to the
benchmarks involving the governing board structure, WTCA proposes that the board follow a
consensus standard development procedure (e.g. ANSI, ASTM, etc.). This would mean the board is
comprised of three groups: general interest, users and producers. With respect to the benchmarks
involving the governing board decision-making, WTCA proposes a similar ANSI consensus standard
development process. The decisions and issues that require a board vote should be categorized by
minimum voting criteria: simple majority, two-thirds majority or consensus to pass. While we are
not an advocate of this, if the governing board structure and decision-making benchmarks remain as
written, WTCA proposes that the terminology "economic chamber/sector" be defined to eliminate
ambiguity surrounding the requirement. As written, it is difficult to discern is meant by this term.
With respect to the entire Governance section, it is clear that the benchmarks presented are largely
based on FSC certification criteria, which WTCA believes is inappropriate. If the process of evaluating
forest certification programs is to be done in an unbiased manner, the criteria or benchmarks
cannot be based on or driven by FSC.

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
WTCA - Representing the Structural Building Components Industry has no comment.

If yes, please explain indicate which systems comply and how they are compliant.
WTCA - Representing the Structural Building Components Industry has no comment.

If not, please explain how the existing systems are deficient.
WTCA - Representing the Structural Building Components Industry has no comment.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.

Expand representation of forest owners, producers and all entities participating in the forest
product supply chain to more thatn jsut the economic chamber/sector in order to achieve a greater
balanced represetrnation with repsect to Governance. Since approval requires at least 1/3 approval
from each chamber/sector each chamber/sector should be blananced in some manner to relfect
overall representation. There appears to be a great deal of alignment with the FSC program which
should be removed to avoid system bias.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.

Yes. We support the benchmark approach and general concept and policy criteria as outlined but we
do feel that overall the goverance benchmarks are too prescriptive. We believe that the benchmark
assessment should focus on the objectives of inclusiveness, fairness, consensus and transparency.
Prescriptive benchmarks should be relied on only where attainment of objectives are not evident.
The benchmark as currently worded is too closely aligned with the FSC Program and should be
modified to avoid system bias.

If yes, please explain indicate which systems comply and how they are compliant.
Other benchmarking exercises such as the Central Point of Expertise on Timber in the UK have
concluded that the predominant North American forest certification standards are compliant.
International governments (eg. Germany, France, Japan, New Zealand, Switzerland) have reached
similiar conclusions and recognize all four standards in operation in North America.

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
All four standards used in Canada (CSA, SFI, PEFC, FSC) measure up to the objectives of
inclusiveness, fairness, consensus and transparency.

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
This should be determined through an independent evaluation, conducted by experts familiar with
all certification systems

Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
Benchmark for organizational type - Should read more clearly that organization must be member-
based organization. As currently written, does not specify this is a requirement, but rather IF the
organization is member-based, then membership must be open. Further, organization is
independent of any one sector or interest group. No benchmark created for governing body - should
specify that the board is elected by membership Benchmark on governing board structure - should
specify that social sector/chamber and environmental sector/chamber hold balance of the other 2/3
of the vote. Elections of board members should also be by balanced chamber representation.
Benchmark on board decision-making- should specify environmental and social interests must be
represented in decision-making (i.e. not and/or). The balance should not be limited to balloted
decisions. That is, decisions related to standards framework and major policy issues should be made
by the membership through balanced chamber representation. Benchmark on Sources of funding
made publicly available - Should that major source of funding cannot be tied to any one interest
group/sector. Benchmark on Draft standards available for public comment - The Yale review did not
take into account the actual standards writing process, only the public consultation process (under

If yes, please explain indicate which systems comply and how they are compliant.
This should be determined through an independent evaluation, conducted by experts familiar with
all certification systems

If not, please explain how the existing systems are deficient.
This should be determined through an independent evaluation, conducted by experts familiar with
all certification systems
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
1. Hardwood sourced from the United States should not be subject a certification system because it
meets the benchmark requirements 2. If a certification system is required, all current systems
should be included
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
Points for USBGC consideration include: Ø Balanced representation is essential to defining truly
sustainable forest management. The USGBC benchmarks on this issue simply propose to adopt the
bias inherent in the Forest Stewardship Council (FSC) governance system. As proposed, voting rules
that do not require a consensus or a majority vote from each interest group or a consensus or
majority vote from the whole group, would be favored. The result is that it becomes possible for a
majority viewpoint to be overruled by a minority view. This benchmark can not be defended by the
requirements of ANSI on governance, balance, or dominance. Ø Some FSC standards do reflect true
consensus, where participants agreed on a consensus decision rule at the outset. Many, however,
are able to reach apparent consensus, but only because of the lack of any semblance of broad
participation by economic interests. Narrow participation, in turn, has produced standards that are
either economically unsustainable or are protective of participants in unique circumstances. The
result does not promote sustainable forestry, and thus, is contrary to USGBC's interests. Ø The
interests of all entities in the supply chain are not aligned. In most cases, their interests are
competing. It is inappropriate to pre-determine an economic grouping of interests, and therefore,

If yes, please explain indicate which systems comply and how they are compliant.

The need for social representation is not consistent across all forest certification systems. For
example, a forest certification system functioning in the United States and/or Canada has the
foundation of a well developed set of laws, regulations, treaties and agreements that support social
considerations. In addition, there is a well established judicial system to address concerns and
grievances. In countries without this social foundation, there is more justification for the forest
certification system to address social concerns.

If not, please explain how the existing systems are deficient.
This benchmark is too closely aligned with the FSC program and should be modified to avoid system
bias.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.

Some of the benchmarks need clarification: Governance & Board Structure: Small private forest
owners need to be represented as the majority of the forest land in the East is owned by non-
industrial private landowners. Level of Standard Setting: National-level standards need to ensure
flexibility for different parts of the country and types of terrane and timber, i.e., hardwood and
softwood. Dispute Resolution: This resolution should be removed since dispute resolution should be
at the certification level, not standards level.

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
Yes.

If yes, please explain indicate which systems comply and how they are compliant.
The American Tree Farm System is comprised of small family-owned forestland owners. Third party
certification is now available to those landowners who receive yearly surveillance audits and re-
certification audits every 5 years. This ability to certify small portions are land is very important to
companies who rely on fiber from these lands for their mills, especially in the hardwood arena. This
is the only system which directly benefits small landowners and makes certification affordable. SFI
Inc. is a non-profit organization with strict standards and open to all types of forestland owners. This
program focuses on economic, environmental and social needs. More appropriate for large
companies, the standard is reviewed every 5 years.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
Yes,

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
Yes,

If yes, please explain indicate which systems comply and how they are compliant.

As far as the Department of Natural Resources experience, both FSC and SFI are compliant with the
governance benchmarks. Both are compliant with international and national regulations, are open,
balance, independent, include public input and comments and are transparent and stable.

If not, please explain how the existing systems are deficient.
There are compliant.

If yes, please explain indicate which systems comply and how they are compliant.

The four standards used in British Columbia and Canada - CSA, FSC, PEFC and SFI - all measure up to
the objectives of inclusiveness, fairness, consensus and transparency. The four programs all provide
for compliance with international normative institutions. They have open membership, and clear
and established governance structures and decision-making processes. And they all remain current
and relevant through a regular standard review cycle (approximately every 5 years). International
governments, notably the United Kingdom, Germany, France, European Union, Japan, New Zealand
and Switzerland, have reached similar conclusions through their research of these standards, and
recognize all four standards in operation in North America.

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?

Yes. The four standards used in British Columbia and Canada - the Canadian Standards Association's
Sustainable Forest Management Standard (CSA), the Forest Stewardship Council (FSC), the
Programme for the Endorsement of Forest Certification schemes (PEFC), and the Sustainable
Forestry Initiative (SFI) - all comply with the Governance objectives.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
Yes. We support the benchmark approach as outlined but feel that overall governance benchmarks
are too prescriptive.Benchmark assessment should focus on the objectives of inclusiveness, fairness,
consensus and transparency and should therefore be relied on only where attainment of objectives
are not evident.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
Please note the SFI comment to this point.

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?

PEFC incuding CSA and SFI have strong governance structures in place. PEFC include oversight by all
vital stakeholders - member countries, non governmental organisations, landowners, social groups
and others. Within each group's framework, the national governing bodies from individual countries
and regions develop standards with substantial opportunity for public review.

If yes, please explain indicate which systems comply and how they are compliant.

The PEFC Council has: PEFC National Governing Bodies which are independent legal entities
representing countries and national or sub-national schemes operating on their territories.

If not, please explain how the existing systems are deficient.
-

If not, please explain how the existing systems are deficient.
FSC "certifies" forests in areas where accredited standards do not exist. Many times, these are just
checklists created by a certification body and have not completed full public consultation, nor has it
had input from a broad range of stakeholders.

Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
Overall the proposed benchmarks related to governance are appropriate; however some need to be
modified or clarified in order for them to have maximum benefit to the LEED standard. These are:
Governance and Board Structure: 1) Forest owners, producers and all entities participating in the
forest product supply chain limited to economic chamber/ sector; 2) Economic chamber/ sector
afforded no more than 1/3 vote. The USGBC should use caution with this definition of "economic"
members. For example, under this definition, an organization like The Nature Conservancy, who sits
on the Board of FSC US, would qualify as "economic" as they are a forest owner. TNC, while a forest
owner, does not maintain economic gain as a top priority in owning forest land, instead they value
the environmental services over all other aspects of forest management. Family forest owners value
aesthetics, wildlife habitat and family legacy over economic gain, and cannot be considered on the
same level as forest product companies, which are meant to comprise the "Economic" sector.
Loggers are important community members. They are often a first point of contact for the public
and landowners and represent an important role in the labor force. The USGBC should recognize
that, board members such as TNC, family forest owners, and loggers, maintain a separate function

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?

While the clarification and modifications above are needed; the major forest certification programs
at play in North America all have strong governance structures in place.

If yes, please explain indicate which systems comply and how they are compliant.
SFI Inc follows all relevant ISO guidelines in both the accreditation and labeling aspects of SFI's
program. SFI Inc is a fully independent non-profit organization devoted to improving responsible
forest management through the comprehensive SFI program. SFI certification is open to all types of
landowners, including non profit organizations, academic institutions, family forest landowner and
public agencies. Its volunteer Board of Directors represents environmental, social and economic
interests equally. The three-chamber structure of SFI Inc.'s Board of Directors ensures that the SFI
program represents economic, environmental and social needs equally. Board members include
representatives of environmental, conservation, professional and academic groups, independent
professional loggers, small family forest owners, public officials, labor and the forest products
industry. The SFI Board is broken out by Economic, Environmental and Social sectors. The social
sector represents a wide variety of stakeholders, which are inherently different than the economic
or environmental sectors. These currently include, but are not limited to, public officials, such as
State Foresters, labor representatives, academics and community level representatives. Clause 5 of
Bylaws of the SFI, Inc states that 'In order to ensure that no Sector of the Board of Directors can
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
Wisconsin Division of Forestry believes this benchmark is too closely aligned with the FSC program
and should be modified to avoid system bias. The benchmark unfairly excludes forest certification
systems with a governing board structure that does not follow a sector based system. The
requirements for a balanced governing board structure and decision-making procedures would be
improved by the elimination of specific requirements for each stakeholder sector. The benchmark
addressing openness by ensuring that processes and standards are accessible to all ownership sizes
and types establishes an inappropriate program requirement. Forest certification systems vary in
their scope and purpose.

If not, please explain how the existing systems are deficient.

Wisconsin Division of Forestry believes FSC-US could fail in respect to "Openness - Organizational
Type". Although FSC bylaws require the system to be open and accessible to all landowners, FSC-US
policies have made participation by the U.S. Forest Service next to impossible. FSC-US is going
through a process to possibly recognize USFS land, but the sincerity of the effort could be challenged
on the basis of delays and technical barriers that opponents have put up. FSC bylaws also do not
allow Governmental representatives (including state and federal agencies) to be voting members of
FSC.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.


The proposed benchmarks relating to governance are not sufficient as there is no adequate system
for determining consensus on issues. In fact, it's contrary to logical and democratic procedure. It is a
bias and deficiency coming from the Forest Stewardship Council systsem. It is imperative that the
rules be changed to be inclusive of all interests, not just selected ones or some narrow group of
participants , and consensus based on the largest group possible. Sustainable forestry is neither
advanced nor promoted when it is not held to an appropriate standard of broad participation by all
interests. There are other inherent biases that represent too much alignment with one certification
program and not all of them. The social standards are not consistent across georgraphical and
political boundaries. North American political, legal, judicial, and regulatory programs are well
established and controlled, which are much different than other countries with much less
established and sophisticateds systems. The benchmarks should give recognition to the better
established programs and accept their standards.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
Overall the proposed benchmarks related to governance are appropriate; however some need to be
modified or clarified in order for them to have maximum benefit to the LEED standard. These are: ·
Governance and Board Structure: 1) Forest owners, producers and all entities participating in the
forest product supply chain limited to economic chamber/ sector; 2) Economic chamber/ sector
afforded no more than 1/3 vote. The USGBC should use caution with this definition of "economic"
members. For example, under this definition, an organization like The Nature Conservancy, who sits
on the Board of FSC US, would qualify as "economic" as they are a forest owner. TNC, while a forest
owner, does not maintain economic gain as a top priority in owning forest land, instead they value
the environmental services over all other aspects of forest management. Family forest owners value
aesthetics, wildlife habitat and family legacy over economic gain, and cannot be considered on the
same level as forest product companies, which are meant to comprise the "Economic" sector.
Loggers are important community members. They are often a first point of contact for the public
and landowners and represent an important role in the labor force. The USGBC should recognize
that, board members such as TNC, family forest owners, and loggers, maintain a separate function

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?

While the clarification and modifications above are needed; the major forest certification programs
at play in North America all have strong governance structures in place.

If yes, please explain indicate which systems comply and how they are compliant.
SFI Inc follows all relevant ISO guidelines in both the accreditation and labeling aspects of SFI's
program. SFI Inc is a fully independent non-profit organization devoted to improving responsible
forest management through the comprehensive SFI program. SFI certification is open to all types of
landowners, including non profit organizations, academic institutions, family forest landowner and
public agencies. Its volunteer Board of Directors represents environmental, social and economic
interests equally. The three-chamber structure of SFI Inc.'s Board of Directors ensures that the SFI
program represents economic, environmental and social needs equally. Board members include
representatives of environmental, conservation, professional and academic groups, independent
professional loggers, small family forest owners, public officials, labor and the forest products
industry. The SFI Board is broken out by Economic, Environmental and Social sectors. The social
sector represents a wide variety of stakeholders, which are inherently different than the economic
or environmental sectors. These currently include, but are not limited to, public officials, such as
State Foresters, labor representatives, academics and community level representatives. Clause 5 of
Bylaws of the SFI, Inc states that 'In order to ensure that no Sector of the Board of Directors can

If not, please explain how the existing systems are deficient.
FSC "certifies" forests in areas where accredited standards do not exist. Many times, these are just
checklists created by a certification body and have not completed full public consultation, nor has it
had input from a broad range of stakeholders.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
We support the benchmark approach and recognize that the General Concepts have identified the
key elements of an appropriate governance assessment. However, we believe that the Policy
Criteria and Benchmarks as listed are too prescriptive in some areas, specifically: Balance -
Governing board structure: Limiting "all entities participating in the forest products supply chain" to
the economic chamber is too prescriptive. Forest labour organizations and First Nations are
examples of entities that are often part of the forest products supply chain but they also bring social
values to the governing structure. Balance - Governing board decision-making: The wording of this
benchmark is too prescriptive. The benchmark assessment should focus on the objective of
inclusiveness for all sectors involved without prescribing the balloting mechanism. In the CSA
certification process we have strived for consensus and balloting has generally not been necessary.
Balance - Funding: Again, this is too prescriptive and specific. The benchmark should focus on
whether sufficient resources are available for a fair and inclusive process, which may or may not
include funding.

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?

Yes, the CSA User Group members can confirm that the concepts of openness, balance, public input
and continual improvement have been an integral part of the development of the CSA SFM Standard
as well as in the implementation of CSA SFM certification at the forest management unit level.

If yes, please explain indicate which systems comply and how they are compliant.

CSA has a long history, dating back to 1919, in the development of consensus-based standards using
internationally recognized and accredited standards development processes. The CSA SFM
certification program meets all the governance requirements of the proposed LEED benchmarks. In
addition, it provides independence and transparency between the process of developing the
standard, the approval of the standard and accreditation of the certifiers. About 95% of forest land
in Canada is publically owned. In recognition of this fact the CSA SFM standard was developed with a
mandatory requirement for public involvement that is unmatched by any other forest certification
standard in the world. The individual members of the CSA User Group consult with over 50 public
advisory groups across Canada on a regular basis during the implementation and maintenance of
CSA SFM certification at the forest management unit level. Advisory groups consist of a broad range
of stakeholders including local community members, businesses, forest workers, Aboriginal people,
environmental groups, technical experts, researchers and academics, government agencies and
forest managers.

If not, please explain how the existing systems are deficient.
The CSA User Group believes that the CSA SFM standard is not deficient.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
The USGBC should use caution in defining "economic" chamber membership. The proposed
definition could include many groups or individuals with their major emphasis in non-economic
values. The SFI Program follows all relevant ISO guidelines in both the accreditation and labeling
aspects of its program. It is a fully independent non-profit organization with a voluntary Board of
Directors ensuring representation from economic, environmental and social sectors.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
I strongly support Leeds' efforts to ensure that approved forest Certification Systems are open to all
organizations and interest groups. The issue of forest certification is too important to allow for or
encourage turf battles and partioning of landowners and interst groups. The objective should simply
be the promotion of responsible on the ground forest management across all ownership groups and
sizes.

If not, please explain how the existing systems are deficient.


All of the current programs (FSC, SFI and Tree Farm)can lead to good forest management. However
many of the current criteria and indicators may be too expensive to be cost effective and add little
to the actual managment on the ground. A major concern is the tendency in continual improvement
to add indicators rather than focus limited resources on critical areas of concern. A primary problem
with FSC is their willingness to certifiy vast hectares of intensively managed and clonal forest
comprised of exotic species in other parts of the world while holding the US to unworkable
limitations on plantation managment and clearcut size of native species from traditional breeding
and tree improvement. In reality this means that eucalyptus logs grown from clones in intensivley
managed short rotation forests harvested from from clearcuts 7 year old stands of hundreds of ha in
size are deemed Ok while native slash and loblolly pine logs that are 30-40 years of age are
considered not acceptible if harvested from a block greater than 40 acres in size. This cast a concern
of credibilty across Leeds that tarnishes all credible certifications.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.

Dividing the governance into various camps and assigning limiting voting powers to the individuals
within those camps results in a fractured assembly that limits the ability of those people who are
most affected by forest policies to have their opinions counted. For example, forest landowners are
limited to serve only on the economic committee and it is jsut the collective vote of that committee
that carries forward for or against the respective votes of the various other committees, some
memebers of which having no (or little)direct consequence of the overall vote outcome. In other
words, the structure of the governing body results in a system that dilutes the input of those who
would ostensibly have the most to offer.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
It is unclear from the proposal but ... 1) I would like to express my support for opening LEED
recognition to all credible forest certification systems including FSC, SFI and American Tree Farm
where the land has undergone an independent third party certification process and 2) Furthermore,
each of these recognized certification systems must be open and accessible to all organizations,
individuals and landowners. Thank you.

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
See #1

If yes, please explain indicate which systems comply and how they are compliant.
See #1

If not, please explain how the existing systems are deficient.
See #1

If not, please explain how the existing systems are deficient.

We support the more detailed comments of the Hardwood Federation, which submitted comments
on behalf of a unified hardwood industry, and we incorporate those comments by reference.
Certification does not work for the vast majority of hardwood businesses. Further, while no
certification system has yet been able to represent the majority of small non-industrial hardwood
owners, we encourage USGBC to ensure that its final benchmarks are written to avoid any bias
toward one certification system over another. Also, we urge USGBC to adopt an assessment process
that assures a fair and balanced review of each certification system. Thank you.

If not, please explain how the existing systems are deficient.
None.

If yes, please explain indicate which systems comply and how they are compliant.
None.

Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.


The NRLA questions the practical application of some of the benchmarks relating to governance
outlined in the proposed changes and whether additional certification standards would be eligible to
meet the requirements. Of particular concern would be the limitation that the governing board of a
certification system contain "no more than 1/3 vote" of representatives of the forest products
industry. This limitation could potentially exclude some of the largest forest management systems in
the U.S. from the LEED standards. The NRLA contends that balanced representation and a consensus-
based decision making process are essential to defining truly sustainable forest management.
Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?

The NRLA is encouraged by the proposed benchmarks and believes they are a sign of movement in a
positive direction. With minor amendments to the proposed benchmarks, several additional existing
internationally recognized certification systems should meet the requirements. The NRLA would
emphasize that should these existing certification systems meet the newly created benchmarks they
should be eligible and awarded equal credit as FSC under MR 7. The NRLA encourages the USGBC to
maintain an open dialogue with the forest products industry and work collaboritaviely to maximize
the sustainable managment of the world's forests.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
There are strong benchmark categories in this section requiring balance in board structure and
decision-making. However, we have great concerns regarding the "organizational type" (there is no
benchmark requirement that the standard-setting organization is a membership organization that is
open to all groups and individuals) and concerns regarding membership voting balance (like the
board, the membership vote should be equally weighted between economic, social, and
environmental interests). The missing benchmarks are central to ensuring that a standard-setting
organization that purports to represent social and environmental interests in fact does so. The only
way to ensure balanced stakeholder representation is to ensure a member-based organization,
open to all parties, and with a governing body elected by the membership. Boards that elect
succeeding board members suffer from lack of transparency and checks and balances. This
benchmark should be changed to read: the governing body (Board of Directors) should be elected
by an open membership with few exceptions for appointment to the board for special needs. A
benchmark is needed to establish that membership voting is weighted per interest group (economic,
social, and environmental) to ensure equal representation of interests in decision-making.

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?

The only certification system that meets these requirements is the Forest Stewardship Council.

If yes, please explain indicate which systems comply and how they are compliant.
The Forest Stewardship Council (FSC): - Meets all ISO and ISEAL codes of good governance. FSC has
completely separated the Accreditation unit (ASI) from the organization. - Is a membership-based
organization with equal representation from its three chambers (environmental, social and
economic). All decision-making within FSC gives an equal voice to each of these chambers, ensuring
that no one interest group can overpower the process. - Organizations and individuals with a
commercial vested interest in commercial forest product organizations (including forest owners) are
placed within FSC's economic chamber. - Sources of funding are made publicly available. - FSC's 10
Principles and 56 Criteria provide the international baseline of requiremetns that all FSC-certified
forests worldwide must meet. These Principles and Criteria may then be further elaborated at a
regional level to reflect the local ecology and social circumstances of that region. This is one of the
strengths of the FSC system, as it allows regional standards to address issues of concern to
stakeholders in specific regions. If you create one generic standard to cover different forest regions,
the requirements must be so general as to limit their ability to truly ensure forests are being
managed responsibly. For example, a forest in northern Canada and one in Southern U.S. are

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
The SFI program meets the governance requirements of the proposed USGBC benchmarks. A "side
by side" comparison of the exisiting forest certification programs needs to be examined so that an
"apples to apples" comparison is made.

Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.

The USGBC should clearly define what "economic members" means. Economic motivators, drivers
and management objectives (consumptive vs non-consumptive) are different depending on if they
are NIPF landowners, ENGOs, State & Federal Government Agencies or the Forest Industry. The
USGBC needs to recognize these different motivators and management objectives when allocating
the % make-up of potential board membership.

If yes, please explain indicate which systems comply and how they are compliant.

1) The SFI program is based on ISO guidelines: a) specific performance measures/indicators &
approved external auditing standards b) continuous improvement emphasis 3) SFI certification is
open to all types of forestry landowners/supply chain entities 3) The SFI Board is made up by 1/3
representation from environmental, social & economic interest groups 5) The SFI Standard is
reviewed every 5 years (current revision period will begin in 2009/10)

If not, please explain how the existing systems are deficient.
FSC certification operates under several different "Standards" depending on the particular
geographical area/region. These FSC "Standards" do not require a full public disclosure, input &
review process by interested stakeholder entities.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
Please open LEED recognition to all reputable forest certification systems including FSC, SFI and
American Tree Farm. Lands under these programs are subject to an independent third party
certification process. Each of these systems must be open to all organizations,individuals and
landowners. Thanks for your consideration.




Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
Overall the proposed benchmarks related to governance are appropriate; however some need to be
modified or clarified in order for them to have maximum benefit to the LEED standard. These are:
Governance and Board Structure: 1) Forest owners, producers and all entities participating in the
forest product supply chain limited to economic chamber/ sector; 2) Economic chamber/ sector
afforded no more than 1/3 vote. Georgia-Pacific believes balanced and diverse participation in the
development and management of a sustainable forest certification system are essential. As
proposed, voting rules that do not require a consensus or a majority vote from each interest group
or a consensus or majority vote from the whole group would be favored. The result is that it
becomes possible for a majority view point to be overruled by a minority view. Similarly, it would
allow one sector to be ignored or dominated by the others, leading to adoption of standards despite
sustained opposition. This benchmark can not be defended by the requirements of ANSI on
governance, balance, or dominance, and ignores ANSI, ISO, and ISEAL standards for consensus-based
decision making. Recommended Benchmark: The governing board is a balanced structure with each
stakeholder sector having equal membership and equal influence on decision making. The

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
The major forest certification programs at play in North America all have strong governance
structures in place.

If yes, please explain indicate which systems comply and how they are compliant.

There are many different forest certification systems around the world, each with a slightly different
focus. Each system has unique strengths due the range of national land ownership patterns and
governmental structures. Georgia-Pacific acknowledges all of the recognized forest certification
organizations including systems which recognize and certify procurement practices. We view
competition among these organizations as vital to continually improving the practice of sustainable
forestry on all lands, but not all programs are applicable or relevant for all landowners and every
region of the world.

If not, please explain how the existing systems are deficient.
No comment
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.

Missouri Forest Products Association believes balanced representation and consensus-based
decision process are essential to defining truly sustainable forest management. As proposed, voting
rules that do not require a consensus or a majority vote from each interest group or a consensus or
majority vote from the whole group would be favored. This benchmark is too closely aligned with
the FSC program and should be modified to avaoid system bias.

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
The existing certification systems (FSC, PEFC, SFI, Tree Farm, CSA) should be able to meet the
majority of the benchmarks as drafted.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.

In my opinion, all credible forest certification systems such as Forest Stewardship Council,
Sustainable Forestry Initiative and American Tree Farm System that have undergone an independent
third party certification process for their land should be recognized by LEED.

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
Yes, FSC, SFI & the American Tree Farm System comply with the benchmarks.

If yes, please explain indicate which systems comply and how they are compliant.
Through the reveiw process and thrid party verfication systems each implement.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
I would like to express my support for opening LEED recognition to all credible forest certification
systems including FSC, SFI and American Tree Farm where the land has undergone an independent
third party certification process Furthermore, each of these recognized certification systems must
be open and accessible to all organizations, individuals and landowners




Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
I would like to see LEED open up its recognition to all credible certification systems including FSC,
SFI, and American Tree Farm where the management of the land is certified by an independent third
party auditor. Having been involved with certification with all three groups I've listed, I can attest to
the fact that each one of the certification bodies promote sustainability, protection of
environmentally sensitive areas, and adherence to local, state, and federal laws and regulations.

If not, please explain how the existing systems are deficient.

Each of these certification systems must be open and accessible to all organizations, individuals, and
landowners who promote sustainable and environmentally protective management.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
Our original suggestion was that if the USGBC elected to develop its own framework for assessing
forest certification systems, that such a framework closely follow the criteria and requirements as
outlined in Yale's "Prescriptive Benchmark" and the WWF/World Bank Framework. Unfortunately,
the proposed LEED Certified Wood, Forest Certification System Benchmark does not come close to
following the two credible frameworks mentioned above. As such, The Nature Conservancy believes
that the USGBC's current proposal does not present a credible framework of benchmarks to assess
certification. The current proposal includes many ambiguous benchmarks, leaves out important
forest management and chain-of-custody criteria, and provides no definition of a credible process
for assessing the various certification systems. Some of our specific concerns are as follows:
Governance: The benchmark on balance of board structure is a valuable one. The benchmark
related to Openness - Organizational type does not specifically require certification systems to be
membership-based organizations. This is an important hallmark of openness and stakeholder
participation. This also relates to the Openness -- Establishment of governing body, and the
requirement should be that boards of certification systems be elected by membership, not self-
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.

I would like to express my support for opening LEED recognition to all credible forest certification
systems including FSC, SFI and American Tree Farm where the land has undergone an independent
third party certification process and 2) Furthermore, each of these recognized certification systems
must be open and accessible to all organizations, individuals and landowners. Thank you.

If not, please explain how the existing systems are deficient.

I would like to express my support for opening LEED recognition to all credible forest certification
systems including FSC, SFI and American Tree Farm where the land has undergone an independent
third party certification process and 2) Furthermore, each of these recognized certification systems
must be open and accessible to all organizations, individuals and landowners. Thank you.

If not, please explain how the existing systems are deficient.
Each of the recognized certification systems mentioned above must be open and accessible to all
organizations, individuals and landowners.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
I would like to express my support for opening LEED recognition needs to be open to all credible
forest certification systems (such as FSC, SFI and American Tree Farm) where the land has
undergone an independent third party certification process.

Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
Overall the proposed benchmarks related to governance are appropriate; however some need to be
modified or clarified in order for them to have maximum benefit to the LEED standard. These are: A.
Governance and Board Structure: 1) Forest owners, producers and all entities participating in the
forest product supply chain limited to economic chamber/sector; 2) Economic chamber/sector
afforded no more than 1/3 vote. Use caution with this definition of "economic" members. As
currently defined, the term does not recognize that forest owners, producers and "all entities
participating in the forest product supply chain" all maintain separate functions when participating
on boards of forest certification programs. B. Level of Standard Setting: 1) International or national-
level standards provide a performance baseline. 2) There are opportunities for development of sub-
national indicators in larger federated countries. The intent of this benchmark should be clarified. If
the USGBC seeks flexibility to adapt to local conditions, then the benchmark should be re-written to
clarify this, but should not be meant to mandate that all international forest certification programs
must develop separate local standards. Also recognize that when a certification program has
multiple standards, the standards can vary widely and it is essential for these differences be

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
All of the major forest certification programs at play in North America have strong governance
structures in place, though clarification and modifications to the benchmarks in question 1 are
needed.

If yes, please explain indicate which systems comply and how they are compliant.
SFI Inc follows all relevant ISO guidelines in both the accreditation and labeling aspects of SFI's
program. SFI Inc is a fully independent non-profit organization devoted to improving responsible
forest management through the comprehensive SFI program. SFI certification is open to all types of
landowners, including non profit organizations, academic institutions, family forest landowner and
public agencies. Its volunteer Board of Directors represents environmental, social and economic
interests equally. The three-chamber structure of SFI Inc.'s Board of Directors ensures that the SFI
program represents economic, environmental and social needs equally. Board members include
representatives of environmental, conservation, professional and academic groups, independent
professional loggers, small family forest owners, public officials, labor and the forest products
industry. The SFI Board is broken out by Economic, Environmental and Social sectors. The social
sector represents a wide variety of stakeholders, which are inherently different than the economic
or environmental sectors. These currently include, but are not limited to, public officials, such as
State Foresters, labor representatives, academics and community level representatives. Clause 5 of
Bylaws of the SFI, Inc states that 'In order to ensure that no Sector of the Board of Directors can
If not, please explain how the existing systems are deficient.
FSC "certifies" forests in areas where accredited standards do not exist. Many times, these are just
checklists created by a certification body and have not completed full public consultation, nor has it
had input from a broad range of stakeholders.

Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.




As a consulting forester I work with many different landowner groups of which some are certified
under the American Tree farm program,SFI and FSC. I would like to support opening LEED
recognition to all credible forest certification systems where there land has undergone third party
certifications and audits. I also believe all certification systems should be open to all classifications of
owners such as industry,private landowners and investment organizations who do a credible job
managing there timberlands. Thank You

If not, please explain how the existing systems are deficient.

Using one certification system (FSC) will limit the amount of certified available wood product for the
market place. By having other credible systems then owners or users can choose the products that
meet their needs and be assured of a steady supply of certified wood product.

Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.

It is imperative that LEEDS recognize and adopt other forest certification systems not only FSC but
SFI and American Tree Farm AMTF or others. These systems use independent third party
certification and as such provide for more available building resources and thus a choice for the
consumer or user. These various systems are available to all landowners, individuals and groups and
provide for healthy competition.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
To promote good forest practices on as much property as possible, bona fide forest certification
systems should be open and available to all entities who adhere to the standards of sustainability
and good forest health. These entities should include NIPF landowners with small acreages,
organizational investors in timberland, large forest industry companies, as well as others falling in
that range. Additionally, LEED should recognize those forest certification systems (ATFS, FSC, SFI)
that are third-party audited to sustainability and forest management standards. Each sector of
timberland owner has characteristics important to the overall status and quality of timber and
timberland in the U.S. and other countries. If certain entities are not allowed to participate, then
there will be little incentive for them to practice good forestry, which will ultimately hurt the
industry.

Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
Overall the proposed benchmarks related to governance are appropriate; however some need to be
modified or clarified in order for them to have maximum benefit to the LEED standard. These are: A.
Governance and Board Structure: 1) Forest owners, producers and all entities participating in the
forest product supply chain limited to economic chamber/sector; 2) Economic chamber/sector
afforded no more than 1/3 vote. Use caution with this definition of "economic" members. As
currently defined, the term does not recognize that forest owners, producers and "all entities
participating in the forest product supply chain" all maintain separate functions when participating
on boards of forest certification programs. B. Level of Standard Setting: 1) International or national-
level standards provide a performance baseline. 2) There are opportunities for development of sub-
national indicators in larger federated countries. The intent of this benchmark should be clarified. If
the USGBC seeks flexibility to adapt to local conditions, then the benchmark should be re-written to
clarify this, but should not be meant to mandate that all international forest certification programs
must develop separate local standards. Also recognize that when a certification program has
multiple standards, the standards can vary widely and it is essential for these differences be

If yes, please explain indicate which systems comply and how they are compliant.
no comment

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
no comment

If not, please explain how the existing systems are deficient.
no comment

If not, please explain how the existing systems are deficient.
All PEFC systems have fundamental shortcomings, with a high degree of inconsistency on key issues
around the world for their "affiliated systems".

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
Only FSC
If yes, please explain indicate which systems comply and how they are compliant.
See info in #1 above

Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
We provide the following comments as a member of USGBC, a longstanding supporter of the LEED
program, and as pioneers of forest certification globally (starting in 1989). In addition, we
participated as a member of the technical sub-TAG that provided input for the USGBC process on
the certified wood credit. First we have a few general comments and, in a few cases, questions that
USGBC must consider as it comes closure on these issues. 1. LEED (and the USGBC) have been
leaders in sustainability around the globe for a number of years. Rainforest Alliance, and many other
conservation non-profit organizations, has strongly supported LEED. The question for USGBC staff
and members is to what extent the organization wishes to continue leading (as per the first "L" in
LEED), versus taking a position on forest certification (or any other topic) in which LEED is in essence
endorsing the status quo in terms of environmental, and for that matter social, performance. The
content, and application, of benchmarks must not dilute the integrity of LEED or support for LEED.
Will USGBC member, and the conservation community, be able to keep up its level of support for
LEED (and USGBC) if the benchmarks reflect more of a "status quo" approach to forest management

Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
Overall the proposed benchmarks related to governance are appropriate; however some need to be
modified or clarified in order for them to have maximum benefit to the LEED standard. These are: A.
Governance and Board Structure: 1) Forest owners, producers and all entities participating in the
forest product supply chain limited to economic chamber/sector; 2) Economic chamber/sector
afforded no more than 1/3 vote. Use caution with this definition of "economic" members. As
currently defined, the term does not recognize that forest owners, producers and "all entities
participating in the forest product supply chain" all maintain separate functions when participating
on boards of forest certification programs. B. Level of Standard Setting: 1) International or national-
level standards provide a performance baseline. 2) There are opportunities for development of sub-
national indicators in larger federated countries. The intent of this benchmark should be clarified. If
the USGBC seeks flexibility to adapt to local conditions, then the benchmark should be re-written to
clarify this, but should not be meant to mandate that all international forest certification programs
must develop separate local standards. Also recognize that when a certification program has
multiple standards, the standards can vary widely and it is essential for these differences be

If yes, please explain indicate which systems comply and how they are compliant.
SFI Inc follows all relevant ISO guidelines in both the accreditation and labeling aspects of SFI's
program. SFI Inc is a fully independent non-profit organization devoted to improving responsible
forest management through the comprehensive SFI program. SFI certification is open to all types of
landowners, including non profit organizations, academic institutions, family forest landowner and
public agencies. Its volunteer Board of Directors represents environmental, social and economic
interests equally. The three-chamber structure of SFI Inc.'s Board of Directors ensures that the SFI
program represents economic, environmental and social needs equally. Board members include
representatives of environmental, conservation, professional and academic groups, independent
professional loggers, small family forest owners, public officials, labor and the forest products
industry. The SFI Board is broken out by Economic, Environmental and Social sectors. The social
sector represents a wide variety of stakeholders, which are inherently different than the economic
or environmental sectors. These currently include, but are not limited to, public officials, such as
State Foresters, labor representatives, academics and community level representatives. Clause 5 of
Bylaws of the SFI, Inc states that 'In order to ensure that no Sector of the Board of Directors can

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
All of the major forest certification programs at play in North America have strong governance
structures in place, though clarification and modifications to the benchmarks in question 1 are
needed.

If not, please explain how the existing systems are deficient.
FSC "certifies" forests in areas where accredited standards do not exist. Many times, these are just
checklists created by a certification body and have not completed full public consultation, nor has it
had input from a broad range of stakeholders.

Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.




1) Opening Leed recognition to all credible forest certification Systems including FSC, SFI and Tree
Farm where the land has undergone an independent third party certification., and 2) All recognized
certification systems must be accessible to all organizations, individuals and landowner groups.

Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
I strongly support expanding LEED recognition to all credible forest certification systems including
FSC, SFI, and American Tree Farm where the property has undergone an independent third party
certification process.
If not, please explain how the existing systems are deficient.


All recognized certification systems must be accessible to all organizations, individuals and
landowner groups.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
Perhaps. Oregon SIC believes that there may be a variety of ways that the proposed benchmarks will
be implemented. Some of these potential outcomes will establish appropriate requirements while
some may not. There needs to be greater clarity (or the language will need to be modified) to have
maximum benefit to the LEED standard. For example: Governance and Board Structure: 1) Forest
owners, producers and all entities participating in the forest product supply chain limited to
economic chamber/ sector; 2) Economic chamber/ sector afforded no more than 1/3 vote. The
definition of "economic" members is unclear. For example, under this definition, organizations like
The Nature Conservancy would qualify as "economic" as they own forestland. Presumably that
would disqualify them from the environmental chamber. Level of Standard Setting: 1)
International or national-level standards provide a performance baseline. 2) There are opportunities
for development of sub-national indicators in larger federated countries. Without knowing what the
intent of this benchmark is, it is difficult to suggest revisions. Clearly benchmarks should recognize
local conditions, the presence (or absence) of an overarching standard notwithstanding. Oregon SIC
would also point out that the issue of consistency is paramount in the Northwest. Many feel that

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?

While the clarification and modifications above are needed; the major forest certification programs
at play in North America all have strong governance structures in place.

If yes, please explain indicate which systems comply and how they are compliant.
Oregon SIC only has expertise in the SFI Program and believes it is fully compliant with the intent of
USGBC's proposed changes, though it is less clear if any system would meet the actual letter of the
proposed changes.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.

The USGBC benchmarks are a good start, yet improvements are needed. In general, forest
certification programs should demonstrate multi-stakeholder involvement in governance and
standard setting. In North America, FSC, SFI and ATFS should qualify and be recognized. USGBC
should be cautious in assigning stakeholders to chambers as each interest group's interests rarely
fall solely into environmental, economic or social interests. Assigning interest groups to chambers
should be transparent and provide an equal voice for all membership organizations.

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
Yes.

If not, please explain how the existing systems are deficient.
N/A

If yes, please explain indicate which systems comply and how they are compliant.

FSC, SFI and ATFS all have multi-stakeholder governance and standard setting procedures and would
meet most (if not all) the policy criteria set forth in the proposed Benchmark.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.

No, all credible forest certification systems including FSC, SFI and American Tree Farm that have
been independent third party certified should be open for LEED recognition. These certification
systems must be open and accessible to all organizations, individuals and landowners.

If not, please explain how the existing systems are deficient.
With the recent changes in land ownership, LEED recognition should be open to all credible forest
certification systems including FSC, SFI and American Tree Farm that have been independent third
party certified. Each of the above listed certification systems must be open and accessible to all
organizations, individuals and landowners.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.

These benchmarks could likely serve an urban wood certifcation system. Any benchmarks specific to
commodity forest management should be adapted to serve the urban timber potential as well.

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
Urban forests are currently certified by the National Arbor Day Foundation. The most common and
recognizable program, Tree City USA, awards annual certificates to municipalities for sound
community tree management. The Growth Award, provides Tree City USA communities an
opportunity to be recognized for continual improvements in community forest management
including wood reclamation. There are complementary programs for campuses, utility rights-of-way
and military lands.

If not, please explain how the existing systems are deficient.

However, the Tree City USA program currently does not address urban timber harvesting in a
significant way and therefore would not meet the benchmarks for USGBC wood certification.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
We appreciate the commitment of the USGBC to promoting best practices in forest certification. We
encourage you to consider how to include and promote the use of wood from urban trees as part of
creative waste wood utilization programs across the nation. The Tree City USA program which we
have helped to manage for 31 years in partnership with the US Forest Service and the National
Association of State Foresters recognizes and certifies more than 3000 communities that meet core
standards of tree management and care. We are exploring how we can adapt the program to help
enhance the management standards and the wood quality and availability for potential certification
for LEED. We apprecaite your attention and would be willint to work with the USGBC to identify
leaders in the urban forest community to assist in developing these appropriate certification
standards.
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.




All creditable forest certification systems including FSC, SFI, and American Tree Farm program
should be allowed. Additionally these sytems should be open to landowners of all types.

If yes, please explain indicate which systems comply and how they are compliant.

The three primary forest certification systems in the US are FSC, SFI, and ATFS, in no particular order
of importance. Each system has sufficient governance requirements and oversight sufficient to
satisfy the USGBC benchmarks. All have diverse stakeholders in important decision-making
capacities and are sufficiently open, balanced, and transparent.

If not, please explain how the existing systems are deficient.
Not applicable.

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
Yes.

Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
Yes
Do the proposed USGBC benchmarks relating to forest certification system Governance establish
appropriate program requirements? Please explain and/or suggest how the requirements might
be improved.
The proposed benchmarks are not specific enough in the language and leave the possibility for
substantial interpretation. Moreover, the means in which the various Certification bodies will be
evaluated is not clear. Clear quantitative criteria need to be established before the credit can be
considered for modification.

Do any of the existing systems comply with the Governance requirements as established in the
USGBC benchmarks?
Yes and no.

If not, please explain how the existing systems are deficient.
While FSC has led the way in establishing Wood certification practices in the Industry, now that it
has been established, the baseline needs to be raised. FSC certified lumber companies should strive
for carbon neutrality, use low emitting manufacturing processes, clean vehicles and high efficiency
milling techniques.
USGBC Response
Thank you for your comments. First, for the Organization Type benchmark, USGBC has elected not
to require a qualifying scheme to be a member-based organization. Second, the revised Governance
Structure benchmark requires balanced representation of social, environmental, and economic
interests as well as allocating a maximum of 1/3 of all votes to any entities with a commercial
interest in the sale of forest products. USGBC believes this balanced participation is a crucial step in
pursuit of comprehensive sustainability.




Thank you for your comments. USGBC agrees with your concern. As such, the Decision-making
benchmark has been revised to require the promotion of consensus-based decision-making.




Thank you for your comments. USGBC firmly believes that locally sourced materials, such as wood
from felled trees, are critical features of a green building. Materials and Resources credits for
Materials Reuse and Local Materials award points for the inclusion of this material type. At the
present time, Forest Certification System Benchmarks are intended to set requirements for
exemplary sustainable forest management, regardless of the nature and location of the practice.
Outside of a materials life cycle analysis, USGBC will not determine whether uncertified, local wood
materials are more or less preferable than certified wood materials from a further origin. Knowing
that building projects will likely use wood from beyond a 500 mile radius, the Certified Wood credits
are intended to motivate project teams to select wood products that – at their origin – are raised
and harvested with exemplary practices. The revised benchmarks and corresponding Conformance
Assessment Process are intended to more clearly present USGBC’s definition and expectation of
exemplary forest certification schemes.
Thank you for your comments. USGBC agrees that any revision to LEED credits should motivate
market transformation and should advance more sustainable practices. As such, the proposed
changes to the Certified Wood credits are intended to motivate change, in this instance the forest
certification market. The USGBC benchmarks are intended to be an objective and transparent
collection of standards against which forest certification schemes will be evaluated to determine
which meet USGBC's level of rigor and then gain recognition in LEED.

Regarding the verification process, please see the accompanying draft Conformance Assessment to
learn how USGBC intends to evaluate the forest certification schemes against the finalized
benchmarks.

And, regarding your proposed revision to the Organization Type benchmark, it is revised to read:
"The certification scheme is a membership-based organization open to all organizations and
individuals who demonstrate commitment to the scheme's guiding principles."




Thank you for your comments. For the issue of governance structure, USGBC considers it to be
exemplary when a scheme balances representation among social, environmental, and economic
interests. As such, the "Governing structure" benchmark requires this equal representation.
exemplary when a scheme balances representation among social, environmental, and economic
interests. As such, the "Governing structure" benchmark requires this equal representation.




Thank you for your comments. Rest assured that USGBC does not intend to decrease the rigor of
the Certified Wood credits. The proposed changes and accompanying Forest Certification Scheme
Benchmarks are meant to increase the transparency by which USGBC chooses one or more scheme
for recognition in those credits. The rigor of the benchmarks ensures that wood used to earn a
point in the credit will continue to come from exemplary forest management practices.




Thank you for your comments. USGBC agrees that any revision to LEED credits should motivate
market transformation and should advance more sustainable practices. As such, the proposed
changes to the Certified Wood credits are intended to motivate change, in this instance the forest
certification market. The USGBC benchmarks are intended to be an objective and transparent
collection of standards against which forest certification schemes will be evaluated to determine
which meet USGBC's level of rigor and then gain recognition in LEED.

USGBC invites you to review the revisions made to the benchmarks and the comments and
responses related to each you have listed in their relevant section.




Thank you for your comments. USGBC agrees that the benchmarks on the economic and all other
chambers are crucial to ensuring that any system recognized in LEED is truly exemplary. Please take
a moment to review the revisions to learn how USGBC has clarified and expanded upon the previous
benchmarks.
Thank you for your comments. USGBC has reviewed the comments you reference and replied
directly to them.




Thank you for your comments. This second public comment period presents revised benchmarks
that are intended to be clearer and more comprehensive than those presented during the first
public comment period.

Due to the potential of high variability in the funding sources, USGBC has elected not to
prescriptively require certain funding limitations. The "Funding" benchmark does, however, require
complete transparency regarding a scheme's funding sources. Any conclusions drawn from that
transparency would be subjective if not informative.




Thank you for your comments. USGBC agrees that any revision to LEED credits should motivate
market transformation and should advance more sustainable practices. As such, the proposed
changes to the Certified Wood credits are intended to motivate change, in this instance the forest
certification market. The USGBC benchmarks are intended to be an objective and transparent
collection of standards against which forest certification schemes will be evaluated to determine
which meet USGBC's level of rigor and then gain recognition in LEED.

Regarding the verification process, please see the accompanying draft Conformance Assessment to
learn how USGBC intends to evaluate the forest certification schemes against the finalized
benchmarks.
Regarding the verification process, please see the accompanying draft Conformance Assessment to
learn how USGBC intends to evaluate the forest certification schemes against the finalized
benchmarks.




Thank you for your comments. The situation you describe would be of concern between the
certification body and the client as to what extent they would be required to perform in order to
achieve certification. This benchmark can not address every potential scenario a certification
scheme may face.




Thank you for your comments. To learn how USGBC will evaluate and select compliant forest
certification schemes, please see the accompanying Conformance Assessment Process document.
USGBC will not intend for this process to be another level of certification. Instead, the organization
is undergoing a process to a) define what it believes to be exemplary forest certification elements
and b) determine which forest certification schemes conform to those elements. USGBC does not
intend to burden the forest certification schemes with any additional cost whereby they would need
to pass those costs onto those that seek their certification.
Thank you for your comments. In responses to your Governance-related comments, USGBC
recognizes the importance of including a benchmark on "organization type" and has included it in
the revised collection of benchmarks. Additionally, there is now a benchmark that requires the
certification scheme to be equally weighted among the economic, social, and environmental
interests.

Regarding your comments on other benchmark sections, please see the comments and responses in
the relevant section.




Thank you for your comments. The revised benchmarks, namely the "Governance structure"
benchmark, ensures that the economic and social groupings are equally represented in the
governing body.

Regarding your assertion about regulations in developed countries, USGBC recognizes that social
and labor laws may be more robust in those countries. If that is the case, the Required benchmarks
in the Indigenous Rights and Labor categories are not required of schemes in countries with
documented laws that meet or exceed the benchmarks' stringency.
Thank you for your comments. Rest assured that USGBC does not intend to decrease the rigor of
the Certified Wood credits. The proposed changes and accompanying Forest Certification Scheme
Benchmarks are meant to increase the transparency by which USGBC chooses one or more scheme
for recognition in those credits. The rigor of the benchmarks ensures that wood used to earn a
point in the credit will continue to come from exemplary forest management practices.

To clarify, the previous and current public comment period are not the actual member ballot period.
Instead, public comment periods present proposed developments to LEED and seek input from all
interested members of the general public.




Thank you for your comments. USGBC believes that the collection of benchmarks for forest
certification schemes make up the organization’s definition of exemplary forest certification and, in
broader terms, exemplary standards setting. The proposed revisions are not intended to satisfy
industry needs but instead transparently maintain a high bar for forest certifications schemes if they
are to gain recognition in LEED. USGBC understands the transformative nature of LEED and intends
for the credits to recognize extraordinary features in the design, construction, and operations of
buildings and neighborhoods.

The revisions to the benchmarks are intended to elaborate their purposes and more clearly indicate
how they will be used. Please see the two core benchmarks in the Standards Substance that present
the central sustainability traits required of an acceptable forest certification scheme: “Ecosystem
structure, function, and forest successional stages” as well as “Community benefit.”
Thank you for your comments. USGBC believes that the collection of benchmarks for forest
certification schemes make up the organization’s definition of exemplary forest certification and, in
broader terms, exemplary standards setting. The proposed revisions are not intended to satisfy
industry needs but instead transparently maintain a high bar for forest certifications schemes if they
are to gain recognition in LEED. USGBC understands the transformative nature of LEED and intends
for the credits to recognize extraordinary features in the design, construction, and operations of
buildings and neighborhoods.

The revisions to the benchmarks are intended to elaborate their purposes and more clearly indicate
how they will be used. Please see the two core benchmarks in the Standards Substance that present
the central sustainability traits required of an acceptable forest certification scheme: “Ecosystem
structure, function, and forest successional stages” as well as “Community benefit.”




Thank you for your comments. The revised benchmarks clarify and elaborate on issue of
governance balance and consensus. The “Governing structure” benchmark requires balanced
representation of social, environmental, and economic interests; it goes onto recognize that labor
unions might not be a part of the “economic” group when it defines that group as having a
commercial interest in the sale of forest products. The “Decision-making” benchmark now includes
explicit requirement for the promotion of consensus-based decision making.

Regarding your concern about economically unsustainable forest certification, USGBC views
economic viability as a core component of sustainable forestry. The “Economic viability” benchmark
in the Standards Substance section provides the opportunity for certifiers to balance economic with
social and environmental considerations in assessing the long-term impacts of management, and
encourages certification decisions that include guidance on an operation's economic viability.

Last, USGBC does not intend for the benchmarks on social aspects to hinder forest certification
schemes that primarily operate in countries with robust social and labor laws. Please see the
accompanying Conformance Assessment Process document to learn how USGBC plans to evaluate
forest certification schemes against the finalized benchmark.
Thank you for your comments. The “Decision-making” benchmark now includes explicit
requirement for the promotion of consensus-based decision making. And USGBC does not intend
for the benchmarks on social aspects to hinder forest certification schemes that primarily operate in
countries with robust social and labor laws. Please see the accompanying Conformance Assessment
Process document to learn how USGBC plans to evaluate forest certification schemes against the
finalized benchmark.
Thank you for your comments. The revised benchmarks clarify and elaborate on issue of
governance balance and consensus. The “Governing structure” benchmark requires balanced
representation of social, environmental, and economic interests; it goes onto recognize that labor
unions might not be a part of the “economic” group when it defines that group as having a
commercial interest in the sale of forest products. The “Decision-making” benchmark now includes
explicit requirement for the promotion of consensus-based decision making.

Regarding your concern about economically unsustainable forest certification, USGBC views
economic viability is a core component of sustainable forestry. The “Economic viability” benchmark
in the Standards Substance section provides the opportunity for certifiers to balance economic with
social and environmental considerations in assessing the long-term impacts of management, and
encourages certification decisions that include guidance on an operation's economic viability.

Last, USGBC does not intend for the benchmarks on social aspects to hinder forest certification
schemes that primarily operate in countries with robust social and labor laws. Please see the
accompanying Conformance Assessment Process document to learn how USGBC plans to evaluate
forest certification schemes against the finalized benchmark.
Thank you for your comments. For this public comment period, the benchmarks have been clarified
and elaborated to better convey the expectation of each. Please be assured that the finalized
benchmarks will ensure that wood used to earn a point in the Certified Wood credit will continue to
come from exemplary forest management practices and will not decrease the stringency of the
current credit.
Thank you for your comments. USGBC does not intend for any benchmark to be biased towards a
particular forest certification scheme. Instead, USGBC intends for the benchmarks collectively
present the organization's definition of exemplary forest certification in all aspects of a certification
scheme.

The benchmarks have been clarified and elaborated in response to previous public comments such
as the "Decision-making" benchmark of the Governance section; it requires that the scheme
promote consensus-based decision-making.

Additionally, the "Economic viability" benchmark has been added to the Standards Substance
section to provide the opportunity for certifiers to balance economic with social and environmental
considerations in assessing the long-term impacts of management, and to encourage certification
decisions that include guidance on an operation's economic viability.




Thank you for your comments and support of a benchmark-based forest certification assessment
process.




Thank you for your comments. The revised benchmarks clarify and elaborate on issue of
governance balance and consensus. The “Governing structure” benchmark requires balanced
representation of social, environmental, and economic interests; it goes onto recognize that labor
unions might not be a part of the “economic” group when it defines that group as having a
commercial interest in the sale of forest products. The “Decision-making” benchmark now includes
explicit requirement for the promotion of consensus-based decision making.

Regarding your concern about economically unsustainable forest certification, USGBC views
economic viability as a core component of sustainable forestry. The “Economic viability” benchmark
in the Standards Substance section provides the opportunity for certifiers to balance economic with
social and environmental considerations in assessing the long-term impacts of management, and
encourages certification decisions that include guidance on an operation's economic viability.

Third, USGBC does not intend for the benchmarks on social aspects to hinder forest certification
schemes that primarily operate in countries with robust social and labor laws. The Required
benchmarks in the Indigenous Rights and Labor categories are not required of schemes in countries
with documented laws that meet or exceed the benchmarks' stringency. Please see the
Thank you for your comments. The revised benchmarks clarify and elaborate on issue of
governance balance and consensus. The “Governing structure” benchmark requires balanced
representation of social, environmental, and economic interests; it goes onto recognize that labor
unions might not be a part of the “economic” group when it defines that group as having a
commercial interest in the sale of forest products. The “Decision-making” benchmark now includes
explicit requirement for the promotion of consensus-based decision making.

Regarding your concern about economically unsustainable forest certification, USGBC views
economic viability as a core component of sustainable forestry. The “Economic viability” benchmark
in the Standards Substance section provides the opportunity for certifiers to balance economic with
social and environmental considerations in assessing the long-term impacts of management, and
encourages certification decisions that include guidance on an operation's economic viability.

Third, USGBC does not intend for the benchmarks on social aspects to hinder forest certification
schemes that primarily operate in countries with robust social and labor laws. The Required
benchmarks in the Indigenous Rights and Labor categories are not required of schemes in countries
with documented laws that meet or exceed the benchmarks' stringency. Please see the
Thank you for your comments. USGBC recognizes that entities participating in the forest product
supply chain may serve different functions on the board of a forest certification scheme. USGBC
also believes, however, that forest certification should govern forest production, not be governed by
it, and it is essential that there be adequate checks and balances to ensure commitment to high
environmental and social performance.

Regarding "Level of Standard Setting," this benchmark has been identified as a Distinguishing
benchmark. No international scheme currently requires sub-national indicators and it was unclear
what providing "opportunities" would entail. USGBC supports schemes that have formally
established procedures and standards that comply with the USGBC benchmarks as well as the
development of additional indicators that are tailored to local environments (as per its designation
of being a Distinguishing benchmark) as long as the baseline of required standards and procedures
meet USGBC benchmarks.

USGBC has elected to keep the Dispute Resolution benchmark, as it is an element in its definition of
exemplary forest certification. While USGBC agrees that such disputes often take place at the
certification level, the procedural aspect of this benchmark warranted its continued inclusion in the
Governance section.
Thank you for your comments. To clarify, the proposed Forest Certification Scheme Benchmarks are
the key ingredients to help USGBC determine which schemes meet its expected level of rigor and,
therefore, should be recognized within LEED.




Thank you for your comments. USGBC agrees that any revision to LEED credits should motivate
market transformation and should advance more sustainable practices. As such, the proposed
changes to the Certified Wood credits are intended to motivate change, in this instance the forest
certification market. The USGBC benchmarks are intended to be an objective and transparent
collection of standards against which forest certification schemes will be evaluated to determine
which meet USGBC's level of rigor and then gain recognition in LEED.

Regarding the verification process, please see the accompanying draft Conformance Assessment to
learn how USGBC intends to evaluate the forest certification schemes against the finalized
benchmarks.
Thank you for your comments. Your insight on the American Tree Farm System and the Sustainable
Forestry Initiative are appreciated. Once the benchmarks are finalized, USGBC will use its
Conformance Assessment Process to determine which schemes meet the expected level of rigor and
therefore gain recognition in LEED.




Thank you for your comments. USGBC believes that recognizing more forest certification schemes
than the current credit is warranted only if those schemes meet the requirements of the
benchmarks. USGBC maintains that the Certified Wood credits are not central to achieving LEED
certification but are instead opportunities to earn one extra point as the result of an extraordinary
building design, construction, and/or operation feature. If more than one scheme meets the
requirements of the benchmarks, USGBC will recognize them with LEED knowing that the expanded
recognition is the sign of an evolving and increasingly stringent forest certification industry.
Thank you for your comments. USGBC agrees that any revision to LEED credits should motivate
market transformation and should advance more sustainable practices. As such, the proposed
changes to the Certified Wood credits are intended to motivate change, in this instance the forest
certification market. The USGBC benchmarks are intended to be an objective and transparent
collection of standards against which forest certification schemes will be evaluated to determine
which meet USGBC's level of rigor and then gain recognition in LEED.

Regarding the verification process, please see the accompanying draft Conformance Assessment to
learn how USGBC intends to evaluate the forest certification schemes against the finalized
benchmarks.




Thank you for your comments. The Forest Certification Scheme Benchmarks posted for this 2nd
Public Comment Period are revised to be clearer, better aligned with USGBC's Guiding Principles,
and more consistently present stringent requirements. Additionally, the benchmarks are meant to
increase the transparency by which USGBC chooses one or more scheme for recognition in those
credits. The rigor of the benchmarks ensures that wood used to earn a point in the credit will
continue to come from exemplary forest management practices.
Thank you for your comments. The Forest Certification Scheme Benchmarks posted for this 2nd
Public Comment Period are revised to be clearer, better aligned with USGBC's Guiding Principles,
and more consistently present stringent requirements. Additionally, the benchmarks are meant to
increase the transparency by which USGBC chooses one or more scheme for recognition in those
credits. The rigor of the benchmarks ensures that wood used to earn a point in the credit will
continue to come from exemplary forest management practices.




Thank you for your comments. To clarify, USGBC is proposing benchmarks precisely to avoid biases
towards any particular scheme. The benchmarks were created and refined with the constant view
towards the organization's own definition of exemplary forest certification, not towards the level of
rigor found in the various schemes. USGBC does not expect schemes to meet every benchmark,
thus indicating where even an acceptable scheme has room to improve if it wishes to completely
meet USGBC's definition.

The revised benchmarks clarify and elaborate on issue of governance balance and consensus. The
“Governing structure” benchmark requires balanced representation of social, environmental, and
economic interests; it goes onto recognize that labor unions might not be a part of the “economic”
group when it defines that group as having a commercial interest in the sale of forest products. The
“Decision-making” benchmark now includes explicit requirement for the promotion of consensus-
based decision making.

Regarding your concern about economically unsustainable forest certification, USGBC views
economic viability as a core component of sustainable forestry. The “Economic viability” benchmark
in the Standards Substance section provides the opportunity for certifiers to balance economic with
social and environmental considerations in assessing the long-term impacts of management, and
encourages certification decisions that include guidance on an operation's economic viability.




Thank you for your comments. USGBC has produced prescriptive benchmarks to ensure that any
forest certification scheme that meets a benchmark does so to the fullest extent and, therefore,
fulfilling that part of USGBC's definition of exemplary forest certification.

USGBC recognizes and respects the precedent set by CPET and has considered its methodology and
findings during this process. That work will continue to be consulted as USGBC evaluates the forest
certification schemes itself.
Thank you for your comments. USGBC has produced prescriptive benchmarks to ensure that any
forest certification scheme that meets a benchmark does so to the fullest extent and, therefore,
fulfilling that part of USGBC's definition of exemplary forest certification.

USGBC recognizes and respects the precedent set by CPET and has considered its methodology and
findings during this process. That work will continue to be consulted as USGBC evaluates the forest
certification schemes itself.




Thank you for your comments and important questions. Please see the accompanying Conformance
Assessment Process document to learn how USGBC will evaluate the various forest certification
schemes against its finalized benchmarks. LEED project team members will not be responsible for
this assessment, but will instead learn which supplies of certified wood products can help them earn
a point in the Certified Wood credit.




Thank you for your comments. USGBC agrees that any revision to LEED credits should motivate
market transformation and should advance more sustainable practices. As such, the proposed
changes to the Certified Wood credits are intended to motivate change, in this instance the forest
certification market. The USGBC benchmarks are intended to be an objective and transparent
collection of standards against which forest certification schemes will be evaluated to determine
which meet USGBC's level of rigor and then gain recognition in LEED.

Regarding the verification process, please see the accompanying draft Conformance Assessment to
learn how USGBC intends to evaluate the forest certification schemes against the finalized
Thank you for your comments. USGBC agrees that any revision to LEED credits should motivate
market transformation and should advance more sustainable practices. As such, the proposed
changes to the Certified Wood credits are intended to motivate change, in this instance the forest
certification market. The USGBC benchmarks are intended to be an objective and transparent
collection of standards against which forest certification schemes will be evaluated to determine
which meet USGBC's level of rigor and then gain recognition in LEED.

Regarding the verification process, please see the accompanying draft Conformance Assessment to
learn how USGBC intends to evaluate the forest certification schemes against the finalized
benchmarks.




Thank you for your comments. The responses to each of your points are as follows:
1. The Organization type benchmark has been revised to require that schemes be member-based
organizations.
2. The revised Governance structure benchmark includes the explicit requirement of having
balanced representation of social, environmental, and economic interests. The Required benchmark
on "Decision-making" requires approval from at least 1/3 of each of the three sectors, while the
Distinguishing benchmark requires majority approval.
3. The Decision-making benchmark has been broadened to require consensus in all decision-making
processes.
4. Due to the potential of high variability in the funding sources, USGBC has elected not to
prescriptively require certain funding limitations. The "Funding" benchmark does, however, require
complete transparency regarding a scheme's funding sources.
5. USGBC believes that if all Governance benchmarks are met, the scheme ensures that all levels are
independent of undue and unbalanced influence.
6. USGBC believes that the benchmarks in the Governance section set requirements for the
transparency, balance, and consensus-based decision-making and that an overarching benchmark
for these issues is not necessary.
prescriptively require certain funding limitations. The "Funding" benchmark does, however, require
complete transparency regarding a scheme's funding sources.
5. USGBC believes that if all Governance benchmarks are met, the scheme ensures that all levels are
independent of undue and unbalanced influence.
6. USGBC believes that the benchmarks in the Governance section set requirements for the
transparency, balance, and consensus-based decision-making and that an overarching benchmark
for these issues is not necessary.




Thank you for your comments. The responses to each of your points are as follows:
1. Organizational type: This benchmark has been revised to be a Required benchmark and stipulate
that the scheme to be a member-based organization.
2. Establishment of governing body: This is now a Distinguishing benchmark that, in order to be
earned, requires elections with votes from the scheme's membership.
3. Governing board structure: Please see the revised benchmark, whereby the governance structure
is required to have balanced representation of social, environmental, and economic interests and,
to your points, all entities with a commercial interest in the sale of forest products are allocated a
maximum of 1/3 of all votes.
4. Level of standard setting: This is now a Distinguishing benchmark, allowing a scheme to set itself a
part if it has developed sub-national standards.
5. Consultation: The revised benchmark now explicitly requires that complying schemes solicit input
on draft standards and standards revisions and that all new or revised standards are made available
for public comment.
6. Accessibility to diverse ownership types: The benchmark has been re-written to clearly indicate
that the schemes have standards and procedures to allow small-scale and/or low intensity operators
equitable access to markets for certified products.




Thank you for your comments. LEED for Homes was inadvertently not included on the list of rating
systems to which the revisions would apply. Additionally, LEED for Homes requires certification for
Tropical Wood because that source is viewed is being most at risk of containing wood grown,
harvested, and transported with unsustainable methods. Although certification is not a guarantee
of sustainable forestry, it is seen as being a very reliable indicator.
Thank you for your comments. LEED for Homes was inadvertently not included on the list of rating
systems to which the revisions would apply. Additionally, LEED for Homes requires certification for
Tropical Wood because that source is viewed is being most at risk of containing wood grown,
harvested, and transported with unsustainable methods. Although certification is not a guarantee
of sustainable forestry, it is seen as being a very reliable indicator.




Thank you for your comments. The responses to each of your main points are as follows:
1. Regarding the Governance structure benchmark, it has been revised to group all entities with a
commercial interest in the sale of forest products into the economic chamber, thus recognizing that
some owners do not seek profits.
2. Regarding the Level of Standard Setting benchmark, this is now a Distinguishing benchmark,
allowing a scheme to set itself a part if it has developed sub-national standards.
3. To clarify, the dispute resolution benchmark is applied to forest certification schemes, not LEED.
Additionally, the Accreditation and Auditing section also contains a benchmark on dispute
resolution, that one – however – pertaining to disputes at the certification level. USGBC
understands that disputes may occur during the standard-making process and wishes to recognize
schemes that feature policies for addressing those disputes.
4. Regarding your last point on FSC, USGBC intends for this collection of benchmarks to display its
definition of exemplary forest certification so that all schemes can learn the ways in which they may
be deficient. In doing so, USGBC wishes to motivate continued evolution in the forest certification
industry.




Thank you for your comments. To clarify, USGBC is proposing benchmarks precisely to avoid biases
towards any particular scheme. The benchmarks were created and refined with the constant view
towards the organization's own definition of exemplary forest certification, not towards the level of
rigor found in the various schemes. USGBC does not expect schemes to meet every benchmark,
thus indicating where even an acceptable scheme has room to improve if it wishes to completely
meet USGBC's definition.
Thank you for your comments. To clarify, USGBC is proposing benchmarks precisely to avoid biases
towards any particular scheme. The benchmarks were created and refined with the constant view
towards the organization's own definition of exemplary forest certification, not towards the level of
rigor found in the various schemes. USGBC does not expect schemes to meet every benchmark,
thus indicating where even an acceptable scheme has room to improve if it wishes to completely
meet USGBC's definition.




Thank you for your comments. USGBC agrees that any revision to LEED credits should motivate
market transformation and should advance more sustainable practices. As such, the proposed
changes to the Certified Wood credits are intended to motivate change, in this instance the forest
certification market. The USGBC benchmarks are intended to be an objective and transparent
collection of standards against which forest certification schemes will be evaluated to determine
which meet USGBC's level of rigor and then gain recognition in LEED.

Regarding the verification process, please see the accompanying draft Conformance Assessment to
learn how USGBC intends to evaluate the forest certification schemes against the finalized
benchmarks.




Thank you for your comments. The proposed credit changes to the certified wood credits and the
accompanying Forest Certification Scheme Benchmarks are intended to ultimately identify a scheme
whose supply of wood comes from exemplary forest management practices. USGBC intends to
maintain the high standards of the current credits.
Thank you for your feedback and important questions. First, we apologize for your confusion during
the public comment process. USGBC intends to put forth the clearest documents and messages
possible, and it is hoped that the second public comment period will feature information that is
clearer than before.

Second, LEED project team members will not be required to determine which forest certification
scheme meets the requirements of the benchmarks. USGBC will undertake this effort, as described
in the Conformance Assessment Process document that accompanies the revised benchmarks.
Please review it to learn more.
Thank you for your feedback and important questions. First, we apologize for your confusion during
the public comment process. USGBC intends to put forth the clearest documents and messages
possible, and it is hoped that the second public comment period will feature information that is
clearer than before.

Second, LEED project team members will not be required to determine which forest certification
scheme meets the requirements of the benchmarks. USGBC will undertake this effort, as described
in the Conformance Assessment Process document that accompanies the revised benchmarks.
Please review it to learn more.




Thank you for your comments. USGBC recognizes that entities participating in the forest product
supply chain may serve different functions on the board of a forest certification scheme. USGBC
also believes, however, that forest certification should govern forest production, not be governed by
it, and it is essential that there be adequate checks and balances to ensure commitment to high
environmental and social performance.

Regarding "Level of Standard Setting," this benchmark has been identified as a Distinguishing
benchmark. No international scheme currently requires sub-national indicators and it was unclear
what providing "opportunities" would entail. USGBC supports schemes that have formally
established procedures and standards that comply with the USGBC benchmarks as well as the
development of additional indicators that are tailored to local environments (as per its designation
of being a Distinguishing benchmark) as long as the baseline of required standards and procedures
meet USGBC benchmarks.

USGBC has elected to keep the Dispute Resolution benchmark, as it is an element in its definition of
exemplary forest certification. While USGBC agrees that such disputes often take place at the
certification level, the procedural aspect of this benchmark warranted its continued inclusion in the
Governance section.
Thank you for your comments. USGBC recognizes that entities participating in the forest product
supply chain may serve different functions on the board of a forest certification scheme. USGBC
also believes, however, that forest certification should govern forest production, not be governed by
it, and it is essential that there be adequate checks and balances to ensure commitment to high
environmental and social performance.

Regarding "Level of Standard Setting," this benchmark has been identified as a Distinguishing
benchmark. No international scheme currently requires sub-national indicators and it was unclear
what providing "opportunities" would entail. USGBC supports schemes that have formally
established procedures and standards that comply with the USGBC benchmarks as well as the
development of additional indicators that are tailored to local environments (as per its designation
of being a Distinguishing benchmark) as long as the baseline of required standards and procedures
meet USGBC benchmarks.

USGBC has elected to keep the Dispute Resolution benchmark, as it is an element in its definition of
exemplary forest certification. While USGBC agrees that such disputes often take place at the
certification level, the procedural aspect of this benchmark warranted its continued inclusion in the
Governance section.
Thank you for your comments. The responses to each of your main points are as follows:
1. Please be assured that USGBC will remain impartial during this credit revision process. USGBC has
made the Forest Certification System Benchmarks to be its definition of exemplary forest
certification. The current Materials and Resources Technical Advisory Group features a broad range
of expertise, including those who have worked on LEED-certified buildings. Last, USGBC recognizes
the inherent value of wood products (certified or not) and is considering the best manner to
acknowledge that value in the LEED rating systems.
2. USGBC will use its finalized Conformance Assessment Process to determine which schemes meet
the organization’s level of expectations. Please read that accompanying document to learn how
USGBC will utilize experts to conduct the initial assessment.
3. USGBC is aware of the multiplicity of forest certification schemes and is prepared to conduct
evaluations at the level at which the schemes are distinct.
4. Thank you for your initial support of these proposals. USGBC understands that, since the original
selection of FSC for the Certified Wood credits, the forest certification industry has significantly
evolved to include many robust certification schemes. The production of the benchmarks allows
USGBC to put forth its own exemplary forest certification and evaluate existing schemes against it.
USGBC intends to maintain the Certified Wood credits as indicators of extraordinary building
features and therefore will use the benchmarks to determine which schemes meet its expectations
of exemplary forest certification.
Thank you for your comments. The "Organization type" benchmark has been revised to be a
Required benchmark and stipulate that the scheme to be a member-based organization. The revised
"Governance structure" benchmark requires balanced representation between economic, social,
and environmental groups.




Thank you for your comments. To address your concerns, the "Decision-making" benchmark has
been revised to include the explicit requirement that schemes promote consensus-based decision
making. And, regarding certification under proprietary standards developed by the auditors, the
Level of Standard Setting benchmark is now a Distinguishing benchmark, allowing a scheme to set
itself a part if it has developed sub-national standards.
Thank you for your comments. To address your concerns, the "Decision-making" benchmark has
been revised to include the explicit requirement that schemes promote consensus-based decision
making. And, regarding certification under proprietary standards developed by the auditors, the
Level of Standard Setting benchmark is now a Distinguishing benchmark, allowing a scheme to set
itself a part if it has developed sub-national standards.




Thank you for your comments and support of the Governance benchmarks. Please be assured that
USGBC does not intend for the benchmarks on social aspects to hinder forest certification schemes
that primarily operate in countries with robust social and labor laws. Please see the accompanying
Conformance Assessment Process document to learn how USGBC plans to evaluate forest
certification schemes against the finalized benchmark.




Thank you for your comments. USGBC agrees that any revision to LEED credits should motivate
market transformation and should advance more sustainable practices. As such, the proposed
changes to the Certified Wood credits are intended to motivate change, in this instance the forest
certification market. The USGBC benchmarks are intended to be an objective and transparent
collection of standards against which forest certification schemes will be evaluated to determine
which meet USGBC's level of rigor and then gain recognition in LEED.

Regarding the verification process, please see the accompanying draft Conformance Assessment to
learn how USGBC intends to evaluate the forest certification schemes against the finalized
Thank you for your comments. USGBC agrees that any revision to LEED credits should motivate
market transformation and should advance more sustainable practices. As such, the proposed
changes to the Certified Wood credits are intended to motivate change, in this instance the forest
certification market. The USGBC benchmarks are intended to be an objective and transparent
collection of standards against which forest certification schemes will be evaluated to determine
which meet USGBC's level of rigor and then gain recognition in LEED.

Regarding the verification process, please see the accompanying draft Conformance Assessment to
learn how USGBC intends to evaluate the forest certification schemes against the finalized
benchmarks.




Thank you for your comments. USGBC agrees that any revision to LEED credits should motivate
market transformation and should advance more sustainable practices. As such, the proposed
changes to the Certified Wood credits are intended to motivate change, in this instance the forest
certification market. The USGBC benchmarks are intended to be an objective and transparent
collection of standards against which forest certification schemes will be evaluated to determine
which meet USGBC's level of rigor and then gain recognition in LEED.

Regarding the verification process, please see the accompanying draft Conformance Assessment to
learn how USGBC intends to evaluate the forest certification schemes against the finalized
benchmarks.
Thank you for your comments, proposed revisions, and analysis of the certification schemes. For
revisions on the benchmarks in other sections, please see the revisions of those sections as well as
the relevant comments and responses. The "Organization type" benchmark now requires that a
scheme be a member-based organization.
Thank you for your comments. The "Governing structure" benchmark has been revised to require
balanced representation of social, environmental, and economic interests. USGBC hopes that this
addresses your concern about this benchmark.




Thank you for your comments and insight. The responses to your main points are as follows:
1. The "Governing structure" benchmark has been revised to explicitly reference the involvement of
governmental entities.
2. USGBC has drafted the Forest Certification Scheme Benchmarks to the ensure balance to the
fullest extent possible. USGBC intends for the rigorous benchmarks, when combined with a
thorough evaluation of each scheme, to identify schemes that fulfill its expectations of exemplary
forest certification. Your suggested revision of defining "Balance" based on its outcome not
structure will be seriously considered. USGBC is grateful for the suggestion.
Thank you for your comments. The proposed Forest Certification Scheme Benchmarks are meant to
indicate what USGBC believes to be exemplary forest certification and be used to determine which
schemes meet those exemplary expectations. Exclusion from LEED will only occur if a scheme does
not meet a certain threshold of benchmarks. USGBC recognizes that many forest certification
schemes have developed since the initial inclusion of FSC into LEED. As such, the benchmarks will
evaluate them all against the same criteria.




Thank for your comments. Rest assured that USGBC does not intend to decrease the rigor of the
Certified Wood credits. The proposed changes and accompanying Forest Certification Scheme
Benchmarks are meant to increase the transparency by which USGBC chooses one or more scheme
for recognition in those credits. The stringency of the benchmarks ensures that wood used to earn a
point in the credit will continue to come from exemplary forest management practices.

USGBC recognizes that prescriptive benchmarks do not guarantee performance. This challenge is
similarly found in LEED. However, USGBC is confident that the benchmarks are clear enough to
evaluate whether or not a certification scheme meets the requirement in action.




Thank you for your comments. To clarify, the LEED for Homes prerequisite on tropical wood
requires FSC-certified wood because USGBC recognized that certification scheme to have the
greater presence in tropic regions. Nonetheless, the proposed credit revision now removes explicit
FSC reference (whether it be in the prerequisite or credits) to recognize any schemes that meet the
requirements of the benchmarks.
requirements of the benchmarks.




Thank you for your comments. USGBC believes that its Forest Certification System Benchmarks put
forth requirements that are both of exemplary rigor but also generally reflect how current
certification schemes generally structure themselves and operate. While the benchmarks set forth
high requirements, they do recognize the intricacies of certification scheme structure, such as the
family forest owner example you provide.




Thank you for your comments. USGBC is proposing benchmarks precisely to avoid biases towards
any particular scheme. The benchmarks were created and refined with the constant view towards
the organization's own definition of exemplary forest certification, not towards the level of rigor
found in the various schemes. USGBC does not expect schemes to meet every benchmark, thus
indicating where even an acceptable scheme has room to improve if it wishes to completely meet
USGBC's definition.
Thank you for your comments. To clarify, USGBC is proposing benchmarks precisely to avoid biases
towards any particular scheme. The benchmarks were created and refined with the constant view
towards the organization's own definition of exemplary forest certification, not towards the level of
rigor found in the various schemes. USGBC does not expect schemes to meet every benchmark,
thus indicating where even an acceptable scheme has room to improve if it wishes to completely
meet USGBC's definition.

The "Decision-making" benchmark has been revised to explicitly require the compliant scheme to
promote consensus. Additionally, in the "Governing structure" benchmark, economic has been
refined to only include those groups with a commercial interest in the sale of forest products.

Thank you for your comments. The "Decision-making" benchmark has been revised to require
forest certification schemes to promote consensus-based decisions. This will prevent a majority
opinion to be overruled by a minority view point.

And USGBC does not intend for the benchmarks on social aspects to hinder forest certification
schemes that primarily operate in countries with robust social and labor laws. Please see the
accompanying Conformance Assessment Process document to learn how USGBC plans to evaluate
forest certification schemes against the finalized benchmark.
Thank you for your comments. USGBC recognizes that entities participating in the forest product
supply chain may serve different functions on the board of a forest certification scheme. USGBC
also believes, however, that forest certification should govern forest production, not be governed by
it, and it is essential that there be adequate checks and balances to ensure commitment to high
environmental and social performance.

Regarding "Level of Standard Setting," this benchmark has been identified as a Distinguishing
benchmark. No international scheme currently requires sub-national indicators and it was unclear
what providing "opportunities" would entail. USGBC supports schemes that have formally
established procedures and standards that comply with the USGBC benchmarks as well as the
development of additional indicators that are tailored to local environments (as per its designation
of being a Distinguishing benchmark) as long as the baseline of required standards and procedures
meet USGBC benchmarks.

USGBC has elected to keep the Dispute Resolution benchmark, as it is an element in its definition of
exemplary forest certification. While USGBC agrees that such disputes often take place at the
certification level, the procedural aspect of this benchmark warranted its continued inclusion in the
Governance section.
Thank you for your comments. Please be assured that the proposed credit changes and the
accompanying Forest Certification Scheme Benchmarks are not the result of lobbying efforts.
Instead, USGBC intends to independently indicate what it expects in an exemplary forest
certification scheme.

USGBC continues to strive for market transformation for buildings and all aspects of a building. This
includes certified wood products. By releasing benchmarks, and therefore indicating where non-
compliant schemes are deficient, USGBC is attempting to inspire those schemes to address those
deficient aspects and evolve to meet USGCB’s exemplary standards.

To clarify, USGBC is not positioning itself to review forest management practices. Instead, USGBC
will review the schemes that review those practices. It is understood that this is an additional
amount of work, but USGBC is willing to accept it in order to transparently determine which scheme
(or schemes) meets its expectations. The benchmarks are very prescriptive in nature with the intent
of requiring specific structural and operational details. USGBC expects that schemes that are
compliant in policy to also be compliant in performance.
Thank you for your comments. USGBC agrees that any revision to LEED credits should motivate
market transformation and should advance more sustainable practices. As such, the proposed
changes to the Certified Wood credits are intended to motivate change, in this instance the forest
certification market. The USGBC benchmarks are intended to be an objective and transparent
collection of standards against which forest certification schemes will be evaluated to determine
which meet USGBC's level of rigor and then gain recognition in LEED.

Regarding the verification process, please see the accompanying draft Conformance Assessment to
learn how USGBC intends to evaluate the forest certification schemes against the finalized
benchmarks.
Thank you for your comments. Rest assured that USGBC does not intend to decrease the rigor of
the Certified Wood credits. The proposed changes and accompanying Forest Certification Scheme
Benchmarks are meant to increase the transparency by which USGBC chooses one or more scheme
for recognition in those credits. The stringency of the benchmarks ensures that wood used to earn a
point in the credit will continue to come from exemplary forest management practices.




Thank you for your comments. To clarify, USGBC has not yet determined whether additional
certification schemes will be recognized in LEED. The proposed Forest Certification Scheme
Benchmarks are meant to transparently indicate what USGBC expects from exemplary certification
schemes if they are to be recognized in LEED. You're invited to review the accompanying
Conformance Assessment Process to learn how USGBC will evaluate the schemes against the
finalized benchmarks.
Thank you for your comments. To clarify, USGBC has not yet determined whether additional
certification schemes will be recognized in LEED. The proposed Forest Certification Scheme
Benchmarks are meant to transparently indicate what USGBC expects from exemplary certification
schemes if they are to be recognized in LEED. You're invited to review the accompanying
Conformance Assessment Process to learn how USGBC will evaluate the schemes against the
finalized benchmarks.




Thank you for your comments. Rest assured that USGBC does not intend to decrease the rigor of
the Certified Wood credits. The proposed changes and accompanying Forest Certification Scheme
Benchmarks are meant to increase the transparency by which USGBC chooses one or more scheme
for recognition in those credits. The stringency of the benchmarks ensures that wood used to earn a
point in the credit will continue to come from exemplary forest management practices.
Thank you for your comments. The responses to your main points are as follows:
1. The “Organization type” benchmark has been revised to require a scheme to be a member-based
organization.
2. The “Establishment of governing body” is now a Distinguishing benchmark, allowing a scheme to
set itself apart if its membership elects the governing body.
3. The “Governing structure” benchmark has been revised to limit all entities with a commercial
interest in the sale of wood products to 1/3 of the total vote.
4. “Level of standard setting” is now a Distinguishing benchmark, allowing a scheme to set itself
apart if it has developed sub-national standards.
5. The “Public input-Consultation” benchmark has been revised to seeking public input on both draft
and revised standards.
Thank you for your comments. The responses to your main points are as follows:
1. The “Organization type” benchmark has been revised to require a scheme to be a member-based
organization.
2. The “Establishment of governing body” is now a Distinguishing benchmark, allowing a scheme to
set itself apart if its membership elects the governing body.
3. The “Governing structure” benchmark has been revised to limit all entities with a commercial
interest in the sale of wood products to 1/3 of the total vote.
4. “Level of standard setting” is now a Distinguishing benchmark, allowing a scheme to set itself
apart if it has developed sub-national standards.
5. The “Public input-Consultation” benchmark has been revised to seeking public input on both draft
and revised standards.




Thank you for your comments. USGBC does not intend for any benchmark to be biased towards a
particular forest certification scheme. Instead, USGBC intends for the benchmarks collectively
present the organization's definition of exemplary forest certification in all aspects of a certification
scheme.




Thank you for your comments. The "Accessibility to diverse ownership types" benchmarks to place
requirements on schemes that primarily focus on large forestry operations, requiring that those
schemes "allow small-scale and/or low intensity operators equitable access to markets for certified
forest products, and/or schemes have developed policies or other measures to improve small
producer market access." There is not a similar restriction on placing size limits.




Thank you for your comments. The responses to your initial four points are as follows:
A. To clarify, the Forest Certification Scheme Benchmarks are not intended to be a collection of
standards or codes. Instead they are the indication of how USGBC defines exemplary forest
certification and the criteria against which it – as an independent organization – will select which
schemes meets its definition. USGBC is very aware of the rigor used to develop a standard and is
applying the same scrutiny to this process.
B. Your points are well-stated and seriously considered. We hope that you will find the benchmark
revisions to satisfactorily address your concerns.
C. Certain benchmarks will be mandatory while others will be voluntary but carry with them a point
value to achieve a defined threshold. Please see the revised benchmarks for the mandatory
Thank you for your comments. The responses to your initial four points are as follows:
A. To clarify, the Forest Certification Scheme Benchmarks are not intended to be a collection of
standards or codes. Instead they are the indication of how USGBC defines exemplary forest
certification and the criteria against which it – as an independent organization – will select which
schemes meets its definition. USGBC is very aware of the rigor used to develop a standard and is
applying the same scrutiny to this process.
B. Your points are well-stated and seriously considered. We hope that you will find the benchmark
revisions to satisfactorily address your concerns.
C. Certain benchmarks will be mandatory while others will be voluntary but carry with them a point
value to achieve a defined threshold. Please see the revised benchmarks for the mandatory
benchmarks and those that carry a point value. The “Governing structure” benchmark does not
require that government be a part of the governance structure; if it is, it is contained within a group
that is allocated 1/3 of all votes.
D. USGBC believes that the group in this example would move to an economic chamber, because it
now has a commercial interest in the sale of wood products. To be sure, however, USGBC will not
evaluate the applicability of this benchmark on this real-world example, but whether or not a forest
certification scheme contains the prevision(s) outlined in the benchmarks.




Thank you for your comments. USGBC agrees with your suggested modification of the "Governing
structure" benchmark. It has been revised to require balanced representation of social,
environmental, and economic interests.
Thank you for your comments. Regarding your comments on the "Governing structure" benchmark,
USGBC has revised this benchmark to indicate the participant categories, require balance among
them, and allocate a maximum of 1/3 of all votes to governmental or for-profit forest owners,
producers, and other entities with a commercial interest in the sale of forest products.

Regarding your "Level of Standard Setting" comments, the benchmark is now a Distinguishing
benchmark that allows a scheme to stand out from others.

For those comments on benchmarks of other sections, please refer to those sections for relevant
comments and responses.




Thank you for your comments. The "Governing structure" benchmark has been revised to require
balanced representation of social, environmental, and economic interests. This balanced
representation, as well as limiting entities with a commercial interest in forest products to 1/3 of all
votes, are meant to ensure that board elections are open to the various participant categories.
USGBC hopes that this addresses your concern about this benchmark.
Thank you for your comments. The "Accessibility to diverse ownership types" benchmark has been
revised to read "Certification scheme standards and procedures allow small-scale and/or low
intensity operators equitable access to markets for certified forest products, and/or schemes have
developed policies* or other measures to improve small producer market access." USGBC hopes
this addresses your concern.




Thank you for your comments. USGBC does not intend for any benchmark to be biased towards a
particular forest certification scheme. Instead, USGBC intends for the benchmarks collectively
present the organization's definition of exemplary forest certification in all aspects of a certification
scheme. USGBC believes that some restrictions on the commercial interest sector are necessary.
Additionally, the openness to all ownership sizes and types aligns with USGBC’s Guidance Principle
of “Ensuring inclusiveness” and is therefore seen as a necessary benchmark. And, last, the revised
benchmark on “Governing structure” recognizes and allows for governmental participation.




Thank for your comments. The "Governing structure" benchmark has been revised to require
balance of three major interest groups: social, environmental, and economic interests. The
benchmark has also been revised to require support from at least 1/3 of each interest-based sector.
Last, USGBC appreciates your explanation of CSA’s qualifications and looks forward to completely
reviewing the scheme to determine if it complies with the benchmarks.
Thank for your comments. The "Governing structure" benchmark has been revised to require
balance of three major interest groups: social, environmental, and economic interests. The
benchmark has also been revised to require support from at least 1/3 of each interest-based sector.
Last, USGBC appreciates your explanation of CSA’s qualifications and looks forward to completely
reviewing the scheme to determine if it complies with the benchmarks.




Thank you for your comments. USGBC agrees that any certification scheme that meets its high
expectations must, at the least, contain the elements you describe. The Forest Certification Scheme
Benchmarks are intended to clearly indicate USGBC’s definition of exemplary forest certification.
Thank you for your comments. USGBC agrees that any certification scheme that meets its high
expectations must, at the least, contain the elements you describe. The Forest Certification Scheme
Benchmarks are intended to clearly indicate USGBC’s definition of exemplary forest certification.




Thank you for your comments. The revised Forest Certification Scheme Benchmarks indicate what
USGBC expects from exemplary forest certification. One element of this expectation is balanced
representation of all sectors that are involved with forestry, whether or not they have a commercial
interest in the sale of wood products. USGBC does not intend for any benchmark to be biased
towards a particular forest certification scheme.




Thank you for your comments and well-articulated points. On the whole, USGBC agrees with the
Governance elements you have described and intends for them to be reflected in the revised
benchmarks. It is worth noting, however, that USGBC has developed the benchmarks without
considering any one scheme. Instead, the benchmarks indicate what USGBC expects from
exemplary forest certification regardless of the certifying scheme.
Thank you for your comments and well-articulated points. On the whole, USGBC agrees with the
Governance elements you have described and intends for them to be reflected in the revised
benchmarks. It is worth noting, however, that USGBC has developed the benchmarks without
considering any one scheme. Instead, the benchmarks indicate what USGBC expects from
exemplary forest certification regardless of the certifying scheme.




Thank you very much for your comments. The responses to each of your four points are as follows:
1. To clarify, USGBC is not rating forest management practices in North America or abroad. Instead,
it is capitalizing on the already existent expertise in the forest certification schemes to ensure that
wood certified as exemplary forest management will help earn a point in the LEED rating system.
USGBC understands that FSC certification is primarily focused on the areas you mention and hopes
that the previous version of the Certified Wood credits (with their explicit reference to FSC)
indirectly increased the desire to protect those forests.
2. USGBC will use the finalized benchmarks to determine if the certification schemes you mention
meet the organization’s definition of exemplary forest certification.
3. It is reassuring to know that North American forest management practices are already
sustainable. Please refer to the accompanying Conformance Assessment Process document to learn
how USGBC proposes to evaluate the certification schemes against the benchmarks.
4. Thank you very much for recommending the USDA Forest Products Laboratory and the associated
expert. USGBC will seriously consider consulting them in the midst of its evaluation process.
Thank you for your comments and insight. USGBC will seriously consider your comments. When
the Certified Wood credits were first created, FSC certification was seen as the most rigorous
scheme and therefore was solely recognized within LEED. USGBC recognizes and appreciates,
however, that other certification schemes have evolved since the credits’ origin. As such, all
schemes will now be evaluated against a single set of benchmarks that collectively define USGBC’s
view of exemplary forest certification. USGBC also recognizes the inherent value in wood,
regardless of its level of certification. With this recognition in mind, USGBC will begin a broader
examination of whether (and how) wood in general can have a point-earning position in LEED.




Thank you for your comments. The responses to each of your points are as follows:
1. The Governance benchmarks you reference have been revised to provide some increased
flexibility, so long as there is balanced representation among social, economic, and environmental
interests. USGBC understands that its own membership structure is different from that described in
the benchmarks but does not want to list more than those already indicated, lest the benchmarks
become to prescriptive.
2. Your specific commentary on these certification schemes is helpful. In the end, a forest
certification system will be deemed compliant by an independent, third-party evaluation of its
criteria against the Forest Certification Scheme Benchmarks requirements. Please refer to the
accompanying Conformance Assessment Process document to learn more about USGBC's intended
evaluation process.
interests. USGBC understands that its own membership structure is different from that described in
the benchmarks but does not want to list more than those already indicated, lest the benchmarks
become to prescriptive.
2. Your specific commentary on these certification schemes is helpful. In the end, a forest
certification system will be deemed compliant by an independent, third-party evaluation of its
criteria against the Forest Certification Scheme Benchmarks requirements. Please refer to the
accompanying Conformance Assessment Process document to learn more about USGBC's intended
evaluation process.




Thank you for your comments. The responses to each of your main points is as follows:
1. The benchmark has been revised to generally require the promotion of consensus-based decision
making.
2. The benchmark has been revised to require approval from at 1/3 of the representatives from the
three major stakeholder groups.
3. The benchmark now clearly defines what groups are included in this sector.
4. USGBC does not intend for any benchmark to be biased towards a particular forest certification
scheme. Instead, USGBC intends for the benchmarks collectively present the organization's
definition of exemplary forest certification in all aspects of a certification scheme, independent of
any one scheme's previously established guidelines.
Thank you for your comments. The responses to each of your main points is as follows:
1. The benchmark has been revised to generally require the promotion of consensus-based decision
making.
2. The benchmark has been revised to require approval from at 1/3 of the representatives from the
three major stakeholder groups.
3. The benchmark now clearly defines what groups are included in this sector.
4. USGBC does not intend for any benchmark to be biased towards a particular forest certification
scheme. Instead, USGBC intends for the benchmarks collectively present the organization's
definition of exemplary forest certification in all aspects of a certification scheme, independent of
any one scheme's previously established guidelines.




Thank you for your comments. USGBC does not intend for any benchmark to be biased towards a
particular forest certification scheme. Instead, USGBC intends for the benchmarks collectively
present the organization's definition of exemplary forest certification in all aspects of a certification
scheme, independent of any one scheme's previously established guidelines.




Thank you for your comments. USGBC has produced prescriptive benchmarks to ensure that any
forest certification scheme that meets a benchmark does so to the fullest extent and, therefore,
fulfilling that part of USGBC's definition of exemplary forest certification.

Additionally, USGBC does not intend for any benchmark to be biased towards a particular forest
certification scheme. Instead, USGBC intends for the benchmarks collectively present the
organization's definition of exemplary forest certification in all aspects of a certification scheme,
independent of any one scheme's previously established guidelines.

Lastly, USGBC recognizes and respects the precedent set by CPET and has considered its
methodology and findings during this process. That work will continue to be consulted as USGBC
evaluates the forest certification schemes itself.
Lastly, USGBC recognizes and respects the precedent set by CPET and has considered its
methodology and findings during this process. That work will continue to be consulted as USGBC
evaluates the forest certification schemes itself.




Thank you for your comments. The responses to each of your main points are as follows:
1. Please see the accompanying draft Conformance Assessment to learn how USGBC intends to
evaluate the forest certification schemes against the finalized benchmarks.
2. The “Organization type” benchmark has been revised to require that the certification scheme is a
member-based organization.
3. In conjunction with the revision to the “Organization type” benchmark, the “Establishment of
governing body” benchmark has been revised to require the governing body be elected by the
scheme’s membership.
4. The “Governing structure” benchmark has been revised to limit all those with a commercial
interest in the sale of wood products to 1/3 of all votes.
5. The “Decision-making” benchmark now requires that decisions must be approved by at least 1/3
of the social, environmental, and economic sectors.
6. USGBC has respectfully elected not revise the “Funding” benchmark per your suggestion.
7. USGBC is confident that its prescriptive benchmarks throughout the Governance section
accomplish the characteristics you describe.
8. Without further direction on ways to ensure transparency in this benchmark, USGBC has
respectfully maintained its content from the previous version.
9. While USGBC intends for the benchmarks to require specific actions, it has respectfully decided
not to incorporate this specific requirement into the “Accessibility of diverse owner types”
benchmark.
10.




Thank you for your comments. USGBC believes that meeting the requirements of exemplary forest
certification is necessary regardless of geography. And your specific commentary on the inclusion of
other schemes is helpful. In the end, a forest certification scheme will be deemed compliant by an
independent, third-party evaluation of its criteria against the Forest Certification Scheme
Benchmarks.
Thank you for your comments. The responses to each of your main points are as follows:
1. The “Decision-making” benchmark has been revised to require a certification scheme to promote
consensus-based decision making.
2. USGBC views economic viability as a core component of sustainable forestry. The “Economic
viability” benchmark in the Standards Substance section provides the opportunity for certifiers to
balance economic with social and environmental considerations in assessing the long-term impacts
of management, and encourages certification decisions that include guidance on an operation's
economic viability.
3. The “Governing-structure” benchmark now more clearly describes what entities will belong in the
economic sector.
4. USGBC does not intend for the benchmarks on social aspects to hinder forest certification
schemes that primarily operate in countries with robust social and labor laws. Please see the
accompanying Conformance Assessment Process document to learn how USGBC plans to evaluate
forest certification schemes against the finalized benchmark.
5. USGBC does not intend for any benchmark to be biased towards a particular forest certification
scheme. Instead, USGBC intends for the benchmarks collectively present the organization's
definition of exemplary forest certification in all aspects of a certification scheme, independent of
any one scheme's previously established guidelines.




Thank you for your comments. The responses to each of your main points are as follows:
1. The "Accessibility to diverse ownership types" benchmark requires a scheme to have "standards
and procedures allow small-scale and/or low intensity operators equitable access to markets for
certified forest products, and/or schemes have developed policies or other measures to improve
small producer market access."
2. The Level of Standard Setting benchmark is now a Distinguishing benchmark, allowing a scheme
to set itself a part if it has developed sub-national standards.
3. USGBC believes that, while relatively less common, there will be disputes at the standards-setting
level that require policies for remediating those disputes.
4. Your specific commentary on these certification schemes is helpful. In the end, a forest
certification scheme will be deemed compliant by an independent, third-party evaluation of its
criteria against the Forest Certification Scheme Benchmarks.
Thank you for your comments. Your specific commentary on these certification schemes is helpful.
In the end, a forest certification scheme will be deemed compliant by an independent, third-party
evaluation of its criteria against the Forest Certification Scheme Benchmarks.




Thank you for your comments. The responses to your main points are as follows:
1. USGBC agrees with the need to ensure your stated objectives but believes that prescriptive
benchmarks ensure adherence to USGBC's Guiding Principles and definition of exemplary forest
certification.
2. Your specific commentary on these certification schemes is helpful. In the end, a forest
certification scheme will be deemed compliant by an independent, third-party evaluation of its
criteria against the Forest Certification Scheme Benchmarks.
Thank you for your comments. Your specific commentary on these certification schemes is helpful.
In the end, a forest certification scheme will be deemed compliant by an independent, third-party
evaluation of its criteria against the Forest Certification Scheme Benchmarks.




Thank you for your comments. The responses to your main points are as follows:
1. This benchmark has been revised to specify that this chamber will all “entities with a commercial
interest in the sale of forest products.”
2. USGBC understands that global certification schemes have multiple standards for particular
regions. “Level of standard setting” is now a Distinguishing benchmark, allowing a scheme to set
itself apart if it has developed sub-national standards.
3. USGBC believes that, while relatively less common, there will be disputes at the standards-setting
level that require policies for remediating those disputes.
4. Your specific commentary on this/these certification system(s) is/are helpful. In the end, a forest
certification system will be deemed compliant by an independent, third-party evaluation of its
criteria against the Forest Certification System Benchmark requirements.
itself apart if it has developed sub-national standards.
3. USGBC believes that, while relatively less common, there will be disputes at the standards-setting
level that require policies for remediating those disputes.
4. Your specific commentary on this/these certification system(s) is/are helpful. In the end, a forest
certification system will be deemed compliant by an independent, third-party evaluation of its
criteria against the Forest Certification System Benchmark requirements.




Thank you for your comments. USGBC does not intend for any benchmark to be biased towards a
particular forest certification scheme. Instead, USGBC intends for the benchmarks collectively
present the organization's definition of exemplary forest certification in all aspects of a certification
scheme. USGBC believes that some restrictions on the commercial interest sector are necessary.
Additionally, the openness to all ownership sizes and types aligns with USGBC’s Guidance Principle
of “Ensuring inclusiveness” and is therefore seen as a necessary benchmark. And, last, the revised
benchmark on “Governing structure” recognizes and allows for governmental participation.
Thank you for your comments. USGBC does not intend for any benchmark to be biased towards a
particular forest certification scheme. Instead, USGBC intends for the benchmarks collectively
present the organization's definition of exemplary forest certification in all aspects of a certification
scheme. USGBC believes that some restrictions on the commercial interest sector are necessary.
Additionally, the openness to all ownership sizes and types aligns with USGBC’s Guidance Principle
of “Ensuring inclusiveness” and is therefore seen as a necessary benchmark. And, last, the revised
benchmark on “Governing structure” recognizes and allows for governmental participation.




Thank you for your comments. The responses to your main points are as follows:
1. USGBC does not intend for any benchmark to be biased towards a particular forest certification
scheme. Instead, USGBC intends for the benchmarks collectively present the organization's
definition of exemplary forest certification in all aspects of a certification scheme, independent of
any one scheme's previously established guidelines.
2. USGBC agrees that sustainable forestry is not advanced or promoted without broad participation.
The three sectors identified in the “Governing structure” benchmark are meant to broadly include
many different participant types.
3. USGBC does not intend for the benchmarks on social aspects to hinder forest certification
schemes that primarily operate in countries with robust social and labor laws. Please see the
accompanying Conformance Assessment Process document to learn how USGBC plans to evaluate
forest certification schemes against the finalized benchmark.




Thank you for your comments. The responses to your main points are as follows:
1. This benchmark has been revised to specify that this chamber will all “entities with a commercial
interest in the sale of forest products.”
2. USGBC understands that global certification schemes have multiple standards for particular
regions. The Level of Standard Setting benchmark is now a Distinguishing benchmark, allowing a
scheme to set itself a part if it has developed sub-national standards.
3. USGBC believes that, while relatively less common, there will be disputes at the standards-setting
level that require policies for remediating those disputes.
4. Your specific commentary on this/these certification system(s) is/are helpful. In the end, a forest
certification system will be deemed compliant by an independent, third-party evaluation of its
criteria against the Forest Certification System Benchmark requirements.
Thank you for your comments. The responses to your main points are as follows:
1. This benchmark has been revised to specify that this chamber will all “entities with a commercial
interest in the sale of forest products.”
2. USGBC understands that global certification schemes have multiple standards for particular
regions. The Level of Standard Setting benchmark is now a Distinguishing benchmark, allowing a
scheme to set itself a part if it has developed sub-national standards.
3. USGBC believes that, while relatively less common, there will be disputes at the standards-setting
level that require policies for remediating those disputes.
4. Your specific commentary on this/these certification system(s) is/are helpful. In the end, a forest
certification system will be deemed compliant by an independent, third-party evaluation of its
criteria against the Forest Certification System Benchmark requirements.




Thank you for your comments. The responses to your mains points are as follows:
1. USGBC has revised the “Governing structure” to encompass all “entities with a commercial
interest in the sale of forest products” into the economic chamber.
2. USGBC believes that prescriptive benchmarks are necessary to ensure compliance with its own
definition of exemplary forest certification. To gain recognition in LEED, a forest certification
scheme does not need to fulfill every benchmark. Please see the accompanying Conformance
Assessment Process to learn how USGBC intends to evaluate the forest certification schemes against
the finalized benchmarks.
3. Your specific commentary on this certification system is helpful. In the end, a forest certification
scheme will be deemed compliant by an independent, third-party evaluation of its criteria against
Thank you for your comments. The responses to your mains points are as follows:
1. USGBC has revised the “Governing structure” to encompass all “entities with a commercial
interest in the sale of forest products” into the economic chamber.
2. USGBC believes that prescriptive benchmarks are necessary to ensure compliance with its own
definition of exemplary forest certification. To gain recognition in LEED, a forest certification
scheme does not need to fulfill every benchmark. Please see the accompanying Conformance
Assessment Process to learn how USGBC intends to evaluate the forest certification schemes against
the finalized benchmarks.
3. Your specific commentary on this certification system is helpful. In the end, a forest certification
scheme will be deemed compliant by an independent, third-party evaluation of its criteria against
the Forest Certification Scheme Benchmarks.




Thank you for your comments. Your specific commentary on this certification system is helpful. In
the end, a forest certification scheme will be deemed compliant by an independent, third-party
evaluation of its criteria against the Forest Certification Scheme Benchmarks.
Thank you for your comments. Your specific commentary on this certification system is helpful. In
the end, a forest certification scheme will be deemed compliant by an independent, third-party
evaluation of its criteria against the Forest Certification Scheme Benchmarks.




Thank you for your comments. The responses to your main points are as follows:
1. USGBC agrees with your assertion for an overall promotion of responsible forest management
and a reduction of hostilities between forest certification schemes. As such, the Forest Certification
Scheme Benchmarks are meant to independently indicate USGBC's own definition of exemplary
forest certification and transparently indicate how a particular scheme does or does not meets its
expectations.
2. Your specific commentary on this certification system is helpful. In the end, a forest certification
scheme will be deemed compliant by an independent, third-party evaluation of its criteria against
the Forest Certification Scheme Benchmarks.




Thank you for your comments. USGBC will seriously consider your points. The third party that
evaluates the forest certification systems against the benchmarks will consider the ramifications of
the governing structure on governance outcomes.




Thank you for your comments. The responses to each of your main points are as follows:
1. To clarify, USGBC has not yet determined whether additional certification schemes will be
recognized in LEED. The proposed Forest Certification Scheme Benchmarks are meant to
transparently indicate what USGBC expects from exemplary certification schemes if they are to be
recognized in LEED. You're invited to review the accompanying Conformance Assessment Process
to learn how USGBC will evaluate the schemes against the finalized benchmarks.
2. The Governance benchmark on "Accessibility to diverse owner types" conforms with your belief
that certification schemes should be open to an array of landowners, while all other benchmarks
conform with your belief about schemes being open to all organizations and individuals.
Thank you for your comments. The responses to each of your main points are as follows:
1. To clarify, USGBC has not yet determined whether additional certification schemes will be
recognized in LEED. The proposed Forest Certification Scheme Benchmarks are meant to
transparently indicate what USGBC expects from exemplary certification schemes if they are to be
recognized in LEED. You're invited to review the accompanying Conformance Assessment Process
to learn how USGBC will evaluate the schemes against the finalized benchmarks.
2. The Governance benchmark on "Accessibility to diverse owner types" conforms with your belief
that certification schemes should be open to an array of landowners, while all other benchmarks
conform with your belief about schemes being open to all organizations and individuals.




Thank you for your comments. The responses to your main points are as follows:
1. USGBC does not intend for any benchmark to be biased towards a particular forest certification
scheme. Instead, USGBC intends for the benchmarks collectively present the organization's
definition of exemplary forest certification in all aspects of a certification scheme, independent of
any one scheme's previously established guidelines.
2. Please see the accompanying draft Conformance Assessment to learn how USGBC intends to
evaluate the forest certification schemes against the finalized benchmarks.




Thank you for your comments. The "Governing structure" and "Decision-making" benchmarks have
been modified to require balanced representation and consensus-based decisions, respectively.
Second, USGBC is committed to maintaining a constructive dialogue with the forest products
industry to a) collective ensure that the inherent value of wood is recognized is green buildings and
b) community the organization's expectations of certification schemes if they are to be recognized in
LEED.
Thank you for your comments. USGBC expects exemplary forest certification standards to ensure
balanced representation and voting among all member stakeholders. This expectation of
inclusiveness adheres to USGBC's Guiding Principles and is believed to be incorporated into the
revised benchmarks. Additionally, Your specific commentary on FSC is helpful. In the end, a forest
certification scheme will be deemed compliant by an independent, third-party evaluation of its
criteria against the Forest Certification Scheme Benchmarks.
Thank you for your comments. The responses to your main points are as follows:
1. Your specific commentary on SFI is helpful. In the end, a forest certification scheme will be
deemed compliant by an independent, third-party evaluation of its criteria against the Forest
Certification Scheme Benchmarks.
2. The revised “Governing structure” includes an elaborated definition of the economic members
and hopes that it meets the intent of your suggestion.
3. Rest assured that the third-party review of each scheme will comprehensively determine the
extent to which it adheres to the finalized benchmarks.




Thank you for your comments. The responses to each of your main points are as follows:
1. To clarify, USGBC has not yet determined whether additional certification schemes will be
recognized in LEED. The proposed Forest Certification Scheme Benchmarks are meant to
transparently indicate what USGBC expects from exemplary certification schemes if they are to be
recognized in LEED. You're invited to review the accompanying Conformance Assessment Process
to learn how USGBC will evaluate the schemes against the finalized benchmarks.
2. The Governance benchmark on "Accessibility to diverse owner types" conforms with your belief
that certification schemes should be open to an array of landowners, while all other benchmarks
Thank you for your comments. The responses to each of your main points are as follows:
1. To clarify, USGBC has not yet determined whether additional certification schemes will be
recognized in LEED. The proposed Forest Certification Scheme Benchmarks are meant to
transparently indicate what USGBC expects from exemplary certification schemes if they are to be
recognized in LEED. You're invited to review the accompanying Conformance Assessment Process
to learn how USGBC will evaluate the schemes against the finalized benchmarks.
2. The Governance benchmark on "Accessibility to diverse owner types" conforms with your belief
that certification schemes should be open to an array of landowners, while all other benchmarks
conform with your belief about schemes being open to all organizations and individuals.




Thank you for your comments. The "Governing structure" and "Decision-making" benchmarks have
been modified to require balanced representation and consensus-based decisions, respectively.
Second, The Level of Standard Setting benchmark is now a Distinguishing benchmark, allowing a
scheme to set itself a part if it has developed sub-national standards. Last, USGBC recognizes that
different forest certification schemes are appropriate in different regions. As such, USGBC does not
intend to allow the non-applicability of a scheme to a particular region to inhibit its ability to meet
its definition of exemplary forest certification.
Thank you for your comments. The responses to your main points are as follows:
1. The "Governing structure" and "Decision-making" benchmarks have been modified to require
balanced representation and consensus-based decisions, respectively.
2. USGBC does not intend for any benchmark to be biased towards a particular forest certification
scheme. Instead, USGBC intends for the benchmarks collectively present the organization's
definition of exemplary forest certification in all aspects of a certification scheme, independent of
any one scheme's previously established guidelines.
3. Your specific commentary on these certification schemes is helpful. In the end, a forest
certification scheme will be deemed compliant by an independent, third-party evaluation of its
criteria against the Forest Certification Scheme Benchmarks.




Thank you for your comments. Your specific commentary on these certification schemes is helpful.
In the end, a forest certification scheme will be deemed compliant by an independent, third-party
evaluation of its criteria against the Forest Certification Scheme Benchmarks. Please see the
accompanying draft Conformance Assessment to learn how USGBC intends to evaluate the forest
certification schemes against the finalized benchmarks.




Thank you for your comments. The responses to each of your main points are as follows:
1. To clarify, USGBC has not yet determined whether additional certification schemes will be
recognized in LEED. The proposed Forest Certification Scheme Benchmarks are meant to
transparently indicate what USGBC expects from exemplary certification schemes if they are to be
recognized in LEED. You're invited to review the accompanying Conformance Assessment Process
to learn how USGBC will evaluate the schemes against the finalized benchmarks.
2. The Governance benchmark on "Accessibility to diverse owner types" conforms with your belief
that certification schemes should be open to an array of landowners, while all other benchmarks
conform with your belief about schemes being open to all organizations and individuals.




Thank you for your comments. Your specific commentary on these certification schemes is helpful.
In the end, a forest certification scheme will be deemed compliant by an independent, third-party
evaluation of its criteria against the Forest Certification Scheme Benchmarks. Please see the
accompanying draft Conformance Assessment to learn how USGBC intends to evaluate the forest
certification schemes against the finalized benchmarks.
Thank you for your comments. Your specific commentary on these certification schemes is helpful.
In the end, a forest certification scheme will be deemed compliant by an independent, third-party
evaluation of its criteria against the Forest Certification Scheme Benchmarks. Please see the
accompanying draft Conformance Assessment to learn how USGBC intends to evaluate the forest
certification schemes against the finalized benchmarks.




Thank you for your comments. USGBC has taken great lengths to clarify and elaborate the Forest
Certification Scheme Benchmarks, and it is hoped that the revisions address your concerns. The
“Organization type” now requires the compliant scheme to be a member-based organization and,
therefore, have member-based elections.




Thank you for your comments. The responses to each of your main points are as follows:
1. To clarify, USGBC has not yet determined whether additional certification schemes will be
recognized in LEED. The proposed Forest Certification Scheme Benchmarks are meant to
transparently indicate what USGBC expects from exemplary certification schemes if they are to be
recognized in LEED. You're invited to review the accompanying Conformance Assessment Process
to learn how USGBC will evaluate the schemes against the finalized benchmarks.
2. The Governance benchmark on "Accessibility to diverse owner types" conforms with your belief
that certification schemes should be open to an array of landowners, while all other benchmarks
conform with your belief about schemes being open to all organizations and individuals.




Thank you for your comments. The responses to each of your main points are as follows:
1. To clarify, USGBC has not yet determined whether additional certification schemes will be
recognized in LEED. The proposed Forest Certification Scheme Benchmarks are meant to
transparently indicate what USGBC expects from exemplary certification schemes if they are to be
recognized in LEED. You're invited to review the accompanying Conformance Assessment Process
to learn how USGBC will evaluate the schemes against the finalized benchmarks.
2. The Governance benchmark on "Accessibility to diverse owner types" conforms with your belief
that certification schemes should be open to an array of landowners, while all other benchmarks
Thank you for your comments. The responses to each of your main points are as follows:
1. To clarify, USGBC has not yet determined whether additional certification schemes will be
recognized in LEED. The proposed Forest Certification Scheme Benchmarks are meant to
transparently indicate what USGBC expects from exemplary certification schemes if they are to be
recognized in LEED. You're invited to review the accompanying Conformance Assessment Process
to learn how USGBC will evaluate the schemes against the finalized benchmarks.
2. The Governance benchmark on "Accessibility to diverse owner types" conforms with your belief
that certification schemes should be open to an array of landowners, while all other benchmarks
conform with your belief about schemes being open to all organizations and individuals.


Thank you for your comments. USGBC recognizes that entities participating in the forest product
supply chain may serve different functions on the board of a forest certification scheme. USGBC
also believes, however, that forest certification should govern forest production, not be governed by
it, and it is essential that there be adequate checks and balances to ensure commitment to high
environmental and social performance.

Regarding "Level of Standard Setting," this benchmark has been identified as a Distinguishing
benchmark. No international scheme currently requires sub-national indicators and it was unclear
what providing "opportunities" would entail. USGBC supports schemes that have formally
established procedures and standards that comply with the USGBC benchmarks as well as the
development of additional indicators that are tailored to local environments (as per its designation
of being a Distinguishing benchmark) as long as the baseline of required standards and procedures
meet USGBC benchmarks.

USGBC has elected to keep the Dispute Resolution benchmark, as it is an element in its definition of
exemplary forest certification. While USGBC agrees that such disputes often take place at the
certification level, the procedural aspect of this benchmark warranted its continued inclusion in the
Governance section.
Thank you for your comments. The responses to each of your main points are as follows:
1. To clarify, USGBC has not yet determined whether additional certification schemes will be
recognized in LEED. The proposed Forest Certification Scheme Benchmarks are meant to
transparently indicate what USGBC expects from exemplary certification schemes if they are to be
recognized in LEED. You're invited to review the accompanying Conformance Assessment Process
to learn how USGBC will evaluate the schemes against the finalized benchmarks.
2. The Governance benchmark on "Accessibility to diverse owner types" conforms with your belief
that certification schemes should be open to an array of landowners, while all other benchmarks
conform with your belief about schemes being open to all organizations and individuals.




Thank you for your comments. The responses to your main points are as follows:
1. USGBC will utilize a third-party evaluation process to objectively determine which scheme (or
schemes) adheres to the Forest Certification Scheme Benchmarks. USGBC intends to maintain the
rigor of the Certified Wood credit and ensure that earning it is the sign of an extraordinary design
feature.
2. USGBC understands the market demand ramifications of its forest certification decision and will
determine the best compromise between technical rigor and market realities.




Thank you for your comments. USGBC firmly desires the advancement and expansion of sustainable
forest management. Additionally, USGBC wishes to see the widest variety of landowners adhere to
sustainable forest management practices, as evidenced by the “Accessibility to diverse ownership
types benchmark.”
Thank you for your comments. USGBC firmly desires the advancement and expansion of sustainable
forest management. Additionally, USGBC wishes to see the widest variety of landowners adhere to
sustainable forest management practices, as evidenced by the “Accessibility to diverse ownership
types benchmark.”




Thank you for your comments. USGBC recognizes that entities participating in the forest product
supply chain may serve different functions on the board of a forest certification scheme. USGBC
also believes, however, that forest certification should govern forest production, not be governed by
it, and it is essential that there be adequate checks and balances to ensure commitment to high
environmental and social performance.

Regarding "Level of Standard Setting," this benchmark has been identified as a Distinguishing
benchmark. No international scheme currently requires sub-national indicators and it was unclear
what providing "opportunities" would entail. USGBC supports schemes that have formally
established procedures and standards that comply with the USGBC benchmarks as well as the
development of additional indicators that are tailored to local environments (as per its designation
of being a Distinguishing benchmark) as long as the baseline of required standards and procedures
meet USGBC benchmarks.

USGBC has elected to keep the Dispute Resolution benchmark, as it is an element in its definition of
exemplary forest certification. While USGBC agrees that such disputes often take place at the
certification level, the procedural aspect of this benchmark warranted its continued inclusion in the
Governance section.




Thank you for your comments. The responses to your main points are as follows:
1. Rest assured that USGBC does not intend to decrease the rigor of the Certified Wood credits. The
proposed changes and accompanying Forest Certification Scheme Benchmarks are meant to
increase the transparency by which USGBC chooses one or more scheme for recognition in those
credits. The stringency of the benchmarks ensures that wood used to earn a point in the credit will
continue to come from exemplary forest management practices.
2. USGBC’s original recognition of FSC in the Certified Wood credits acknowledged its leading role in
forest certification. Since that time, other forest certification schemes have evolved to the point
where USGBC now intends to independently indicate its expectations for exemplary forest
certification. The bar will not be lower, but will instead be transparently indicated to all certification
schemes.
3. USGBC will consider both the technical and applied rigor of a scheme’s standards.
credits. The stringency of the benchmarks ensures that wood used to earn a point in the credit will
continue to come from exemplary forest management practices.
2. USGBC’s original recognition of FSC in the Certified Wood credits acknowledged its leading role in
forest certification. Since that time, other forest certification schemes have evolved to the point
where USGBC now intends to independently indicate its expectations for exemplary forest
certification. The bar will not be lower, but will instead be transparently indicated to all certification
schemes.
3. USGBC will consider both the technical and applied rigor of a scheme’s standards.
4. Please see the accompanying draft Conformance Assessment to learn how USGBC intends to
evaluate the forest certification schemes against the finalized benchmarks.
5. USGBC is aware of the discrepancies among certification schemes belonging to a single
federation. As such, it will evaluate each to if each meets the requirements of the benchmarks.
6. USGBC places the utmost importance of ensuring that wood products are from legal sources and
expects any recognized certification scheme to provide consistent, credible assurance of that
legality.
7. USGBC appreciates your insight about the supply of FSC-certified wood. LEED is intended to
transform the market of green buildings and neighborhoods, and USGBC is encourage by your claim
that the rating system is transforming markets associated with green buildings as well.
8. USGBC will utilize third-party evaluations to determine which certification schemes meet its
expectation of exemplary forest certification. This process is not an attempt to dilute the standards
but to make the transparent and motivate continued evolution of all forest certification schemes.




Thank you for your comments. USGBC recognizes that entities participating in the forest product
supply chain may serve different functions on the board of a forest certification scheme. USGBC
also believes, however, that forest certification should govern forest production, not be governed by
it, and it is essential that there be adequate checks and balances to ensure commitment to high
environmental and social performance.

Regarding "Level of Standard Setting," this benchmark has been identified as a Distinguishing
benchmark. No international scheme currently requires sub-national indicators and it was unclear
what providing "opportunities" would entail. USGBC supports schemes that have formally
established procedures and standards that comply with the USGBC benchmarks as well as the
development of additional indicators that are tailored to local environments (as per its designation
of being a Distinguishing benchmark) as long as the baseline of required standards and procedures
meet USGBC benchmarks.

USGBC has elected to keep the Dispute Resolution benchmark, as it is an element in its definition of
exemplary forest certification. While USGBC agrees that such disputes often take place at the
certification level, the procedural aspect of this benchmark warranted its continued inclusion in the
Governance section.
certification level, the procedural aspect of this benchmark warranted its continued inclusion in the
Governance section.




Thank you for your comments. The responses to each of your main points are as follows:
1. To clarify, USGBC has not yet determined whether additional certification schemes will be
recognized in LEED. The proposed Forest Certification Scheme Benchmarks are meant to
transparently indicate what USGBC expects from exemplary certification schemes if they are to be
recognized in LEED. You're invited to review the accompanying Conformance Assessment Process
to learn how USGBC will evaluate the schemes against the finalized benchmarks.
2. The Governance benchmark on "Accessibility to diverse owner types" conforms with your belief
that certification schemes should be open to an array of landowners, while all other benchmarks
conform with your belief about schemes being open to all organizations and individuals.




Thank you for your comments. The responses to each of your main points are as follows:
1. To clarify, USGBC has not yet determined whether additional certification schemes will be
recognized in LEED. The proposed Forest Certification Scheme Benchmarks are meant to
transparently indicate what USGBC expects from exemplary certification schemes if they are to be
recognized in LEED. You're invited to review the accompanying Conformance Assessment Process
to learn how USGBC will evaluate the schemes against the finalized benchmarks.
2. The Governance benchmark on "Accessibility to diverse owner types" conforms with your belief
that certification schemes should be open to an array of landowners, while all other benchmarks
conform with your belief about schemes being open to all organizations and individuals.
transparently indicate what USGBC expects from exemplary certification schemes if they are to be
recognized in LEED. You're invited to review the accompanying Conformance Assessment Process
to learn how USGBC will evaluate the schemes against the finalized benchmarks.
2. The Governance benchmark on "Accessibility to diverse owner types" conforms with your belief
that certification schemes should be open to an array of landowners, while all other benchmarks
conform with your belief about schemes being open to all organizations and individuals.




Thank you for your comments. The responses to your main points are as follows:
1. The "Governing structure" benchmark has been revised to more clearly indicate which types of
participants are to be included in the economic sector.
2. The "Level of Standard Setting benchmark was removed due to lack of clarity. No international
scheme currently requires sub-national indicators and it was unclear what providing "opportunities"
would entail. USGBC supports schemes that have formally established procedures and standards
that comply with the USGBC benchmarks as well as the development of additional indicators that
are tailored to local environments (as per its "target benchmark") as long as the baseline of required
standards and procedures meet USGBC benchmarks.




Thank you for your comments. Your specific commentary on these certification schemes is helpful.
In the end, a forest certification scheme will be deemed compliant by an independent, third-party
evaluation of its criteria against the Forest Certification Scheme Benchmarks.
Thank you for your comments. The responses to each of your main points are as follows:
1. To clarify, USGBC has not yet determined whether additional certification schemes will be
recognized in LEED. The proposed Forest Certification Scheme Benchmarks are meant to
transparently indicate what USGBC expects from exemplary certification schemes if they are to be
recognized in LEED. You're invited to review the accompanying Conformance Assessment Process
to learn how USGBC will evaluate the schemes against the finalized benchmarks.
2. The Governance benchmark on "Accessibility to diverse owner types" conforms with your belief
that certification schemes should be open to an array of landowners, while all other benchmarks
conform with your belief about schemes being open to all organizations and individuals.




Thank you for your comments. Wood from urban sources is eligible for a credit under the Regional
Materials credit, and project teams are who use wood sourced from the project site are encouraged
to apply for an Innovation in Design credit. USGBC has created the Forest Certification Benchmarks
to evaluate the present state of certification schemes. USGBC defers to those schemes to
determine for which types of forestry their certification is intended.




Thank you for your comments. Wood from urban sources is eligible for a credit under the Regional
Materials credit, and project teams are who use wood sourced from the project site are encouraged
to apply for an Innovation in Design credit. USGBC has created the Forest Certification Benchmarks
to evaluate the present state of certification schemes. USGBC defers to those schemes to
determine for which types of forestry their certification is intended.
Thank you for your comments. Wood from urban sources is eligible for a credit under the Regional
Materials credit, and project teams are who use wood sourced from the project site are encouraged
to apply for an Innovation in Design credit. USGBC has created the Forest Certification Benchmarks
to evaluate the present state of certification schemes. USGBC defers to those schemes to
determine for which types of forestry their certification is intended.




Thank you for your comments. The responses to each of your main points are as follows:
1. To clarify, USGBC has not yet determined whether additional certification schemes will be
recognized in LEED. The proposed Forest Certification Scheme Benchmarks are meant to
transparently indicate what USGBC expects from exemplary certification schemes if they are to be
recognized in LEED. You're invited to review the accompanying Conformance Assessment Process
to learn how USGBC will evaluate the schemes against the finalized benchmarks.
2. The Governance benchmark on "Accessibility to diverse owner types" conforms with your belief
that certification schemes should be open to an array of landowners, while all other benchmarks
conform with your belief about schemes being open to all organizations and individuals.




Thank you for your comments. Your specific commentary on these certification schemes is helpful.
In the end, a forest certification scheme will be deemed compliant by an independent, third-party
evaluation of its criteria against the Forest Certification Scheme Benchmarks.




Thank you for your comments. The responses to your main points are as follows:
1. USGBC has both clarified the benchmarks and provided an accompanying Conformance
Assessment Process document to address confusion about the benchmarks and their ultimate
implementation. We hope these address your concerns.
2. You suggested next steps for FSC certification are laudable, and USGBC hopes that all certification
schemes will strive for similar goals.
Thank you for your comments. The responses to your main points are as follows:
1. USGBC has both clarified the benchmarks and provided an accompanying Conformance
Assessment Process document to address confusion about the benchmarks and their ultimate
implementation. We hope these address your concerns.
2. You suggested next steps for FSC certification are laudable, and USGBC hopes that all certification
schemes will strive for similar goals.
Public Comments
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.


Biodiversity - Plantations Limited conversion is allowed in all certification systems, including FSC
which allows 5 percent conversion. Benchmark should reflect this allowance. Biodiversity -
genetically modified organisms (GMOs) No objective definition of what a genetically modified
organism is, which could limit effective use of biotechnology that can improve the value and
quantity of replanted forests for use in wood products, pulp and biofuels, protect trees against
disease and insects and provide other environmental benefits. Forest health - Chemical use This
benchmark should use a more prescriptive approach that would support management of forest
pests, prescribe use of least toxic chemicals to achieve forest management objectives, and allow use
of registered pesticides that comply with state and federal regulations. Labor - Compensation The
justice system in the U.S. provides sufficient mechanisms for grievances and compensation.
Benchmark should clearly state other alternative mechanisms.
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
The Illinois Emerald Ash Borer Wood Utilization Committee welcomes the U.S. Green Building
Council¹s move toward a Forest Certification System Benchmark, but we want to make sure that
the new benchmarking system allows urban forests to be certified so that urban and community
trees can receive wood material credits in LEED buildings. As currently written, only forests
managed for their commodity crop value will qualify. This is not acceptable. LEED certification is
supposed to demonstrate that a building is, among other things, ³environmentally responsible.²
When certifying wood used in buildings, which is more environmentally responsible: using wood
from trees grown to be harvested as a crop (typically) hundreds of miles away from the site or using
wood (typically) from nearby trees grown for their aesthetic benefits and felled due to insect
infestation, disease, age specific decline, safety issues, or to make way for the very project seeking
certification? Commodity forests are managed for the trees¹ value when dead. Urban forests are
managed for the trees¹ value while living: improving the quality of life and saving energy costs (as
reflected in increased property values). Because urban and community trees are not grown for their

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
No urban forest management system could qualify.

If yes, please explain indicate which systems comply and how they are compliant.
-

If not, please explain how the existing systems are deficient.
Urban forests are currently certified by the National Arbor Day Foundation. The most common and
recognizable program, Tree City USA, awards annual certificates to municipalities for sound
community tree management. The Growth Award, provides Tree City USA communities an
opportunity to be recognized for continual improvements in community forest management
including wood reclamation. There are complementary programs for campuses, utility rights-of-way
and military lands. However, the Tree City USA program currently does not address urban timber
harvesting in a significant way and therefore would not meet the Forest Certification System
Benchmark for LEED Certified Wood. II. LEED Certified Wood, Credit Language Revisions "certified by
a recognized certification system" replaces "FSC-certified" LEED 2009, New Construction, Certified
Wood [Comment] LEED 2009, Commercial Interiors, Certified Wood [Comment] LEED 2009, Schools,
Certified Wood [Comment] LEED 2009, Core and Shell, Certified Wood [Comment] LEED 2009,
Existing Buildings: Operations & Maintenance, Sustainable Purchasing: Ongoing Consumables
[Comment] LEED 2009, Existing Buildings: Operations & Maintenance, Sustainable Purchasing:
Facility Alterations and Additions [Comment] LEED for Homes, Environmentally Preferable Products
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.

Technical/Standards Substance - Plantations The term "No Certification" seems too limiting, when it
is our understanding the currently approved system allows "SOME EXCEPTIONS" in their standard
today. Technical/Standards Substance - Genetically Modified Organisms We believe that USGBC
should take a technical position on this benchmark around viable business cases over the use of
Genetically Modified Organisms. Technical/Standards Substance - Continual Improvement We
believe there should be a benchmark for continual improvement as continual improvement drives
positive change and is a core element of most successful quality/environmental management
systems.
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Yes, I believe the benchmarks are sufficiently stringent to establish socially and environmentally
sustainable forestry practices.

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
Yes, I believe FSC complies.

If yes, please explain indicate which systems comply and how they are compliant.
Yes, I believe FSC complies.

If not, please explain how the existing systems are deficient.
I do not know.
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
No. It appears that this document, an exhaustive index of eighty-five key issues and policy criteria
that shape timber certification, is an attempt to implement an "inductive" approach towards
creating a new standard. However, the proposed benchmark solutions are not precise, and in some
cases unknown, lacking the definition required to create an actual condition, rather than a
theoretical concept, for measuring success. The majority of benchmarks can be classified into one of
three primary categories: A. Those with no specific benchmark (whether because the topic is
allegedly covered in another section, the topic is not considered to be significant, or it was noted
that no specific benchmark exists); B. Those with a vague or unmeasurable benchmark; and, C.
Those with a defined benchmark that challenges the USGBC's principles or the Reference System
itself. A. No listed benchmark: More than one-in-four listed policy criteria lack a stated protocol. This
is problematic because these issues distinguish status quo forestry practices from sustainable, or
even ecologically aware, activities; guidelines must be provided to maintain a vigorous standard for
all certification systems to uphold. Key issues ranging from Protected Areas, Old Growth, and
Clearcutting to Economic Viability, Traditional Knowledge and Utilization directly impact timber
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
No. First, on behalf of the American Iron and Steel Institute, Steel Framing Alliance, Steel Recycling
Institute, and other affiliated organizations, we note that some benchmarks are only guidelines until
specific measurable performance criteria are added. For example, soil and water resource protective
benchmarks allow compliance if a program exists but does not include the minimum accepted level
of compliance. The mere existence of a program does not mean the forests will be managed in a
way consistent with the goals of the USGBC. The benchmarks should be amended as needed to
include specific minimum criteria. These minimums should address items such air and water
pollution (including run-off), land-use, habitat protection, and carbon storage at a minimum.
Second, as written, all benchmarks are given equal weight. Likewise, the assumption is that any
certification system will be reviewed, item by item, giving each benchmark a "pass/fail" result. We
believe the benchmarks need to be prioritized and weighted to align with USGBC goals. Third,
nothing is included to describe the process of how the analysis will take place to determine which
certification system meets the final benchmarks or how USGBC will determine who is qualified to
make the assessment. How does a certification system become eligible for review? Are there any

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
Not applicable.

If yes, please explain indicate which systems comply and how they are compliant.
Not applicable.

If not, please explain how the existing systems are deficient.
Not applicable.
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Triple bottom line / social equity is not adequately addressed. Neither are protected areas, old-
growth, clearcutting, biotechnology, utilization, and more. Elsewhere, vague benchmarks not
delineate what constitutes compliant behavior. Ecosystem structure does not address restorative
practices or means of management. "Provide habitat diversity" is vague Species diversity:
process/metric not provided The program to protect species at risk is unknown. Management of
natural disturbances: does not account for non-chemical pest management. FSC language: do not
mimic extreme events of low frequency. For chemical use, are temporary exceptions allowed or
not? The process for obtaining them should also be provided in this line item Timber production:
what constitutes "sustainable" harvest levels? What time frame is this measured? Broader forest
conditions in projected impact? Reforest in a timely manner should provide a not to exceed
maximum time line. Soil productivity maintenance should also include a minimum threshold (to be
a benchmark) Physical infrastructure: access guidelines are delineated per FSC.. Community
benefit. Public consultation Management plan and Monitoring: revisions periodically,
management plan publically available, Impact - assess prior to work and integrated into plan

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
it is unclear due to the undefined nature of many of the benchmarks

If yes, please explain indicate which systems comply and how they are compliant.
it is unclear due to the undefined nature of many of the benchmarks

If not, please explain how the existing systems are deficient.
it is unclear due to the undefined nature of many of the benchmarks
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
The benchmark for plantations is too closely aligned with FSC and should be modified to avoid
system bias. We recommend that the USGBC use the accepted FAO definition. All certification
systems, including FSC, allow for forest conversions in certain, well-defined instances. The
prohibition of use of genetically modified organisms is too limiting and excludes sound scientific
methods. We would prefer that the USGBC take a more neutral position on this topic. Well-studied
applications of appropriate biotechnology methods for forest tree improvement have the potential
to enhance the quality, productivity, and value of plantation forests managed for wood, pulp, and
bioenergy; protect tree species from serious insect and disease problems; and provide other social,
economic, and environmental benefits. Regarding chemical use, we recommend a prescriptive
benchmark that includes: 1) Support for integrated pest management 2) Use of least toxic chemicals
necessary to achieve forest management objectives 3) Use of registered pesticides in accordance
with label requirements 4) Compliance with applicable state and federal regulations The benchmark
for aboriginal land and tenure rights is too closely aligned with FSC and should be modified to avoid
system bias. In the U.S. and Canada, the legal rights of indigenous peoples have been defined by

If not, please explain how the existing systems are deficient.
All certification systems allow conversions to occur - this needs to be recognized by the USGBC. For
example, FSC Principle 6.10 states, "Forest conversions to plantations or non-forest land uses shall
not occur, except in circumstance where conversion: 1) Entails a limited portion of the forest
management unit; 2) Does not occur on high conservation value forest areas; 3) Will enable, clear,
substantial, additional, secure, long-term conservation benefits across the forest management unit.
Five percent conversion is acceptable for FSC certification under these exception clauses, which is
significantly higher than the one-tenth of one percent US national average for forest land
conversion. FSC auditors allow varying amounts of converted land into FSC-certified forests.
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Plantations. "No certifications of plantations converted after 2007 unless change in ownership or
program to convert back to natural forest beginning in advance of the next harvest cycle. For this
purpose, the definition of plantations is consistent with the FAO definition." Points for USGBC
consideration include: ? This benchmark is too closely aligned with the FSC program and should be
modified to avoid system bias. ? For clarity, USGBC should use the accepted FAO definition. ? All
certification systems allow conversions to occur - this needs to be recognized by USGBC. For
example, FSC Principle 6.10 states, "Forest conversion to plantations or non-forest land uses shall
not occur, except in circumstances where conversion: Entails a limited portion of the forest
management unit Does not occur on high conservation value forest areas; Will enable, clear,
substantial, additional, secure, long-term conservation benefits across the forest management unit"
? Five percent conversion is acceptable for FSC certification under these exception clauses, which is
significantly higher than the one-tenth of one percent US national average for forest land
conversion. ? FSC auditors allow varying amounts of converted land into FSC-certified forests.
Recommended Benchmark: Recognize the role of plantations in afforestation and reforestation, in
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.

Social Economic considerations, land use rights, labor laws and ownership do NOT belong in a
technical standard. These should be managed outside the standard by community, corporate
stewardship and other means due to thier subjective and moral basis. LEED is a voluntary standard,
do not start to confuse or intermingle with laws and morals.
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
I want to support the Cascadia chapter in their comment on wood certification.
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
No. There are numerous gaps where no benchmarks are established at all, or are vague or
undefined. Forest Extent: Establish a standard requiring certificate holders to limit conversion of
natural forest lands to non-forest or plantations. Biodiversity: Clean up ambiguity to specifically
address forests of special value. Ecosystem diversity: "Natural" is ambigious to say the least and is
undefined in the standard; this calls out for a standard. Old growth: Must have a clear benchmark
which restricts forestry to restoration or maintenance of the old growth. Chemical Use: Benchmark
should reflect Precautionary Principals and reference the Stockholm POP exclusively. In
summary,there is widespread ambiguity throughout this section which calls for the development of
clear, sold standards not open to interpretation. FSC should serve as the benchmark.
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.

Thank you for providing the opportunity to comment on the proposed benchmark for forest
certification, which will lead to significant changes in the LEED® MR 7 wood credit. We appreciate
the time and energy that has gone into this effort. In lieu of providing corresponding comments to
your proposal, we have reviewed and support of the comments made by the following
organizations: FSC U.S Initiative. Cascadia Green Building Council Northern California Chapter of the
USGBC Sierra Club Rainforest Alliance Columbia Forest Products encourages your consideration of
comments posted by the above listed organizations and urges you to make the necessary changes
and additions to the MR TAG's current proposal.

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
FSC is the closest.

If yes, please explain indicate which systems comply and how they are compliant.
See comment reference above to other contributors.

If not, please explain how the existing systems are deficient.

Also See comment above regarding other contributors comments which COlumbia supports.
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Several of the benchmarks relating to Technical/Standards Substance do establish appropriate
program requirements. However some do not. Below I list 8 benchmarks that I believe are not
appropriate and I suggest improvements. Ecosystem Diversity Ecosystem structure, function and
forest successional stages. It is unclear whether the benchmark "maintain natural ecosystem
structure and function" is intended to mean a more or less natural pre-disturbance condition
throughout the forest; or whether structural elements are to be retained within the forest to a
degree insufficient to retain functions for species protection and diversity. A better bench mark
would be, "Provisions for natural ecosystem structure and function." Forest product use can be
maintained at a subsistence level from naturally occurring forests with little change to structure and
function. Forest products can also be produced at a commercial production level by selective
extraction. But, these practices are not sustainable at the level of world demand. Active
management for wood fiber production is necessary to sustainably meet demand for renewable
forest products. Intensive management minimizes the number of acres that need to be disturbed
from natural conditions and avoids non-sustainable practices on marginal lands. With stream

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
I am not prepared to comment on any particular forest certification system. It was my impression
from the materials supplied by USGBC that the Council was interested in comments on the
proposed benchmarks. I assumed that once the benchmarks were established, USGBC would use
them to assess individual forest certification systems and make a decision as to whether or not
individual systems qualified for certified wood credits under LEED. It seems out of place to be asked
to comment on which certification systems qualify when USGBC has not yet completed their
benchmarks for judging qualifications. Benchmarks should be established independent and separate
from judging any one certification system. Otherwise the benchmarks are open to bias for or against
one or another forest certification system. I am concerned that many of the benchmarks presented
for review by USGBC appear to be pulled directly from the current status quo wood credit certifier,
Forest Stewardship Council. I refer specifically to the Governing board structure, Plantations,
Chemical use, Aboriginal land and tenure rights and Acceptable non-certified sources for percent-
based claims. This practice, of course, creates an immediate bias in the comment process. USGBC
would be better served by following Yale University's lead in their assessment of current

If yes, please explain indicate which systems comply and how they are compliant.
USGBC benchmarks should include provisions to encourage and recognize continuous improvement
in environmental performance. Continuous improvement is an important attribute of some
certification systems. Research, education and training can lead to improved performance in
environmental protection and forest productivity at less cost with less effort. Field practitioners,
given the right incentives, learn rapidly and have a remarkable ability to quickly convert desired
outcomes into on-the-ground results.
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Plantations:This benchmark is too closely aligned with the FSC program and should be modified to
avoid system bias. For clarity, USGBC should use the accepted FAO definition. All certification
systems allow conversions to occur. This needs to be recognized in this benchmark. GMOs: A more
objcetive benchmark would address obth imiproved planting stock and biotechnology using sound
scientific methods and following applicable laws and international protocols. The current language
does not adequately define GMOs. Chemical Use: An improved benchmark would include support
for integrated pest managment, use of least toxic chemicals necessary to achieve managment
objectives, and use of registered pesticides in accordance with label requirements. Aboriginal land
and tenure rights: In the US and Canada, the legal reights of indigenous peoples have been defined
by treaties, laws, and ongoing judicial review.

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
Yes, but many would have problems with substantial portions of the language as proposed. See
comments above.
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
No, changes are necessary to establish realistic standards that encourage and support long-term
forest management. Plantations: This benchmark is too closely aligned with the FSC program and
should be modified to avoid system bias. USGBC should recognize that the term "plantation" simply
means that trees are planted. Why is tree planting bad? US Forest Service Forest Inventory and
Analysis data show that over time, many planted acres become mixed pine-hardwood stands, very
similar to "natural forest" conditions. On many forest acres, planting is necessary to reforest lands
following harvest and essential to maintaining economically sustainable forests. All certification
systems allow conversions to occur - this needs to be recognized by USGBC. For example, FSC
Principle 6.10 states, "Forest conversion to plantations or non-forest land uses shall not occur,
except in circumstances where conversion: Entails a limited portion of the forest management
unit Does not occur on high conservation value forest areas; Will enable, clear, substantial,
additional, secure, long-term conservation benefits across the forest management unit." Without
reasonable standards pertaining to "plantations," forest landowners will continue to avoid
certification programs since the perception is that such systems prevent economically viable forest
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Plantations: All certification systems allow conversions to occur - this needs to be recognized by
USGBC. Genetically modified organisms (GMOs): USGBC should be neutral in their position in their
criteria. USGBC should not prohibit an entire technology in the LEED Green Building Rating System
as such action completely negates the principles of sound science in the development of
technologies that may improve the environmental impact of buildings and construction. Chemical
Use: An improved benchmark would include; ? Support for integrated pest management ? Use of
least toxic chemicals necessary to achieve management objectives. ? Use of registered pesticides in
accordance with label requirements. ? Compliance with applicable state and federal regulations.
Aboriginal land and tenure rights: This is an unnecessary reach. In the US, Canada, and other
countries the legal rights of indigenous peoples have been defined by treaties, laws and ongoing
judicial review. Special aboriginal sites: This is an unnecessary reach.In the US, Canada, and other
countries the legal rights of indigenous peoples have been defined by treaties, laws and ongoing
judicial review. Compensation: The judicial systems provide significant mechanisms for anyone to
address a grievance and seek compensation. Continual Improvement: Continual improvement
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Comments Regarding "Plantations:" As pointed out in the prior section, VFPA feels this benchmark is
too closely aligned with the FSC program and should be modified to avoid system bias. For clarity
and consistency, USGBC should use the accepted FAO definition. VFPA would like to point out that
all certification systems allow conversions to occur - this needs to be recognized by USGBC. For
example, FSC Principle 6.10 states, "Forest conversion to plantations or non-forest land uses shall
not occur, except in circumstances where conversion: entails a limited portion of the forest
management unit; does not occur on high conservation value forest areas; and will enable, clear,
substantial, additional, secure, long-term conservation benefits across the forest management unit"
Furthermore, five percent conversion is acceptable for FSC certification under these exception
clauses, which is significantly higher than the one-tenth of one percent US national average for
forest land conversion. It is also noted that FSC auditors allow varying amounts of converted land
into FSC-certified forests. Comments regarding "Genetically Modified Organisms: At this point in
time VFPA feels there is evidence to encourage the pursuit of biotechnology to enhance the quality,
productivity and value of purpose grown trees. We recommend that USGBC consider a neutral

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
VFPA again has a concern that requiring certification through a separate program puts many family
owned and/or small business as a disadvantage, particularly where constant review of the resource
(by government entities) as well as resource protection laws and regulations support the end goals
of resource sustainability and environmental protection. VFPA furthermore feels that other
materials (such as steel, aluminum, concrete and masonry) should also be required to meet
certifications that their materials have been produced in a manner which insures all of the goals that
are desired with wood-based certification. To have a unique requirement that basically impacts only
one segment of the marketplace is unfair. That being said, many of the proposed benchmarks in this
section are very good, objective criteria, consistent with internationally recognized assessments for
determining the quality of certification systems. The existing certification systems (FSC, PEFC, SFI,
Tree Farm, CSA) should be able to meet the majority of the benchmarks as currently drafted. USGBC
needs to define how points will be awarded and whether or not partial crediting will be
incorporated into the assessments. There are two notable omissions that should be included in the
final set of benchmarks: procurement and continuous improvement: Under procurement, the way
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
FSC "certifies" forests in areas where accredited standards do not exist. Many times, these are just
checklists created by a certification body and have not completed full public consultation, nor has it
had input from a broad range of stakeholders.
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.

No. FSC should be the only wood certification standard allowed in LEED. If other certification
standards can equal or exceed FSC in every aspect, then they could be allowed for consideration in
LEED. However, this is clearly not the case, as evidence with the matrix provided by USGBC.

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
Yes. FSC should be the benchmark for any requirements in LEED.

If yes, please explain indicate which systems comply and how they are compliant.
FSC, period. FSC represents best practices in forestry internationally. Any standard lower than FSC is
and will be seen as a watered-down standard.

If not, please explain how the existing systems are deficient.
The matrix provided by USGBC shows where other certification standards do not meet or exceed
FSC.
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Again it is a bit vague. USGBC should determine what systems are acceptable before making this
change. to make clear and avoid greenwashing. Wood sourced from recycled/salvaged srouces
should also be part of the 50% total certified wood used as not to penalize projects uing these
recycled/salvaged kinds of wood
If yes, please explain indicate which systems comply and how they are compliant.
The Forest Stewardship Council is a member organization.

If not, please explain how the existing systems are deficient.
The SFI BOD is elected by the existing board in a closed process. Thus the social and environmental
decision-makers are hand-selected by the existing board members.

Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.


No. Perkins + Will feels that the USGBC should maintain a strong performance standard for Wood
Certification in the LEED rating system. As a reflection of the USGBC's core values, the standard
should require continuous improvement through market transformation and must retain rigorous
social and environmental requirements founded on the best available objective science. A strong
Certified Wood Credit is important because the health of our forest eco-systems and their
inhabitants is vital to the health of our planet and our civilization. Forests cover 30% of the world's
land area and store over 50% of the world's carbon. The Certified Wood credit is the only LEED
credit that explicitly establishes criteria for all three core elements of Sustainability and the Triple
Bottom Line: Environment, Economics and Social Equity. While the intent of moving to a
performance based criteria for the credit language is acceptable, the verification process for
certification is critical for the Benchmark to be successful. It must be objective and transparent. In
addition, the membership should be presented with the process before voting on the final revisions.

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
Yes
If not, please explain how the existing systems are deficient.

2) Furthermore, each of these recognized certification systems must be open and accessible to all
organizations, individuals and landowners and not exclude eligible third party certification systems.

Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
I would like to express my support for opening LEED recognition to all credible forest certification
systems including FSC, SFI and American Tree Farm where the land has undergone an independent
third party certification process
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
No, these proposed changes completely undermines the core value of high performance buildings.
The proposed yes/no vote on an undefined system and process is an insufficient opportunity to
comment upon a complex issue. We are being asked to vote on a benchmark standard that has not
been defined in detail and appears to be lacking critical information. We support the idea of
benchmark criteria if it includes fully developed and consistent criteria that is not in any way "less
than" the current FSC requirement. It appears as though the proposed criteria are inconsistent, not
in accordance with the USGBC's Guiding Principles, and also not consistent with the
recommendations of the Yale report. This blantant disregard will undermine the credibility of USGBC
and will appear that the USGBC lessoned the standards to allow large production forestry
companies to undermine the standards of high-performance buildings. We urge the tag committee,
USGBC board, stakeholders, members, etc to visit the following site for more information:
www.dontbuysfi.com. Why are we proposing to weaken the most riquorous forestry scheme with
one that is diluted and does not appear to offer transperency, openess, disverse govering
stakeholder group.

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
YES

If yes, please explain indicate which systems comply and how they are compliant.
FSC
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
The benchmark is too closely aligned with the FSC program and should be modified to avoid system
bias. For clarity, USGBC should use the accepted FAO definition.

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?


All certification systems allow conversions to occur - this needs to be recognized by USGBC. For
example, FSC Principle 6.10 states, "Forest conversion to plantations or non-forest land uses shall
not occur, except in circumstances where conversion: Entails a limited portion of the forest
management unit Does not occur on high conservation value forest areas; Will enable, clear,
substantial, additional, secure, long-term conservation benefits across the forest management unit"
Five percent conversion is acceptable for FSC certification under these exception clauses, which is
significantly higher than the one-tenth of one percent US national average for forest land
conversion. FSC auditors allow varying amounts of converted land into FSC-certified forests.

If not, please explain how the existing systems are deficient.
There should be a benchmark for continuous improvement. Continuous improvement drives
positive change and should be recognized as a specific benchmark. Continuous improvement is a
core element of ISO quality management and environmental management standards. Continuous
improvement is supported by the over-riding philosophy and objectives of USGBC to drive change in
the building industry. There should be a benchmark for procurement. The way certification systems
handle the non-certified component of the supply chain should be recognized as a specific
benchmark. In the U.S. context, where the bulk of the fiber supply originates from non-industrial
forest landowners and where less then 10% of the commercial forest land is certified, procurement
elements with standards are critical to ensure core tenants of sustainable forestry are being met
throughout the supply chain.
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
We believe that the benchmark assessment should focus on the objective of practicing sustainable
forestry. As such, it needs to assess the baseline legal requirements and benchmarks within the
various certification standards. Examples where this needs to occur include benchmarks for wages,
rights to organize, soil productivity, riparian protection, soil protection, residual tree protection,
species at risk, GMO's and chemical use (this list is not exhaustive). A number of the benchmarks are
prescriptive as currently written and we recommend the use of goal/objective focused language.
When language is too prescriptive, the ability to demonstrate best practices is limited. We believe
that goal or objective oriented language will allow certification programs to demonstrate how the
meet and exceed the benchmarks in new and unique ways and helps to promote continuous
improvement of all standards. There is clear evidence that in response to competition, all
certification standards have improved over the past several years. USGBC should consider a
graduated assessment approach to their benchmark with an expectation of continuous
improvement. Within each general category (governance; standards substance; certifiers,
accreditation and auditing; and chain of custody and labelling) a threshold measure of achievement

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?

Yes. The four standards used in British Columbia and Canada - the Canadian Standards Association's
Sustainable Forest Management Standard (CSA), the Forest Stewardship Council (FSC), the
Programme for the Endorsement of Forest Certification schemes (PEFC), and the Sustainable
Forestry Initiative (SFI) - all comply with the Technical/Standards Substance requirements,
particularly if the USBGC moves from a prescriptive to a goal/objective approach and assesses both
the requirements of the certification as well as all applicable legislation.

If yes, please explain indicate which systems comply and how they are compliant.
The four standards used in British Columbia and Canada - CSA, FSC, PEFC, and SFI - all depend on
independent, third-party audits where auditors measure the planning, procedures, systems and
performance of on-the-ground forest operations against the predetermined standard. A forest
operation that is found to be in conformance with the standard is issued a certificate. The four
programs all provide for the basics by ensuring that harvested areas are reforested, that laws are
obeyed and that there is no unauthorized or illegal logging. They all go beyond this by ensuring the
conservation of biological diversity, the maintenance of wildlife habitat, soils and water resources,
and the sustainability of timber harvesting, all of which promote sustainable forest management. All
require annual surveillance audits and public disclosure of findings through audit reports. They all
require engagement with affected aboriginal people to ensure traditional forest knowledge and
values and rights are respected. Of particular note, Canada's constitution protects the rights of
Aboriginal peoples, and there is a strong framework in place for resolving disputes about rights and
settling land claims. Overall it must be recognized that in British Columbia and Canada, Aboriginal

If not, please explain how the existing systems are deficient.
Not applicable.
If yes, please explain indicate which systems comply and how they are compliant.
The Forest Stewardship Council is a member organization.

If not, please explain how the existing systems are deficient.
The SFI BOD is elected by the existing board in a closed process. Thus the social and environmental
decision-makers are hand-selected by the existing board members.

Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.


No. Perkins + Will feels that the USGBC should maintain a strong performance standard for Wood
Certification in the LEED rating system. As a reflection of the USGBC's core values, the standard
should require continuous improvement through market transformation and must retain rigorous
social and environmental requirements founded on the best available objective science. A strong
Certified Wood Credit is important because the health of our forest eco-systems and their
inhabitants is vital to the health of our planet and our civilization. Forests cover 30% of the world's
land area and store over 50% of the world's carbon. The Certified Wood credit is the only LEED
credit that explicitly establishes criteria for all three core elements of Sustainability and the Triple
Bottom Line: Environment, Economics and Social Equity. While the intent of moving to a
performance based criteria for the credit language is acceptable, the verification process for
certification is critical for the Benchmark to be successful. It must be objective and transparent. In
addition, the membership should be presented with the process before voting on the final revisions.

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
Yes
Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
The FSC standard complies with the USGBC requirements and should be the only certification body.

Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.

No. It has been clearly shown that the FSC is the only independent certification body that is capable
of ensuring responsible forest practices. Opening the door to multiple certification programs will not
only make the certified wood credit far more confusing, it will clearly open the door to constant
'cheating' on this credit, as contractors will only seek out the cheapest wood possible.
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Forest extent This is one of the most critical issues for "sustainable forest management," and a
strong benchmark needs to be included. The conversion of forest to non-forest land uses and
conditions is one of the most unsustainable things that can happen to forest resources. This is an
issue that can be addressed by certification systems, as evidenced by the existing requirements of
leading systems. This is also a crucial benchmark and should be mandatory. Biodiversity; landscape;
forests of special conservation value This benchmark is too vague to be meaningful. Moreover, the
benchmark also does not actually include any language pertaining to biodiversity and ecological
values, but instead focuses solely on geological, historical, and cultural sites, which are an entirely
different issue. The benchmark needs to be rewritten to require protection for all forest areas that
serve as biodiversity refugia, that have particularly high biodiversity values, that are habitats for
threatened or endangered species, that contain rare or threatened ecosystem types (whether
naturally rare or rare as a result of human activity), that comprise larger intact wilderness (or "intact
forest") areas, and/or that have other priority or outstanding conservation values. This is a crucial

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
Decline Comment until Benchmark and Process are Defined

If not, please explain how the existing systems are deficient.
Decline Comment until Benchmark and Process are Defined

If yes, please explain indicate which systems comply and how they are compliant.
Decline Comment until Benchmark and Process are Defined
If yes, please explain indicate which systems comply and how they are compliant.
Decline comment until benchmarks and process are better defined.

If not, please explain how the existing systems are deficient.
Decline comment until benchmarks and process are better defined.

Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
General Comments: There are key issues addressed in this section that are strong and provide a
foundation to distinguish exemplary forest management practices. We are concerned, however,
that some of the benchmarks in this section are overly ambiguous and that others have wrongly
dismissed a crucial issue as something forest certification cannot address. Additionally, we feel that
some central and longstanding issues of forest management have been understated in the
benchmarks and have been incorrectly referenced to other sections in the benchmarks. Comments
on specific benchmarks: Forest Extent - Forest extent: No specific benchmark - Not considered an
issue that certification can effectively address. The statement that this is not an issue that
certification can address, we believe to be patently incorrect. A standard can and should include
requirements that certificate holders prohibit or strictly limit conversion of natural forest lands to
non-forest or plantations. Further a certification scheme can and should exclude wood from
conversion sources both as an acceptable non-certified component of a mixed-source label.
Landscape - Forests of special conservation value: Manage lands that are geologically, historically, or
culturally important to protect special qualities. Include regionally and locally significant attributes,

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
Decline comment until benchmarks and process are better defined.
If yes, please explain indicate which systems comply and how they are compliant.
SFI probably. If you follow the letter of your wording, though, even FSC doesn't comply.

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
I think so.

Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
I like this stuff. How do you define "Forests of Exceptional Conservation Value"? This is so
ambiguous you could drive a Mack truck through it. Also, are you certain it is fair to require groups
to make their plans public? For instance, another association we are a part of, the Scientific
Equipment & Furniture Association, has several performance standards to which members test their
products. HOW they meet the tests is not made public, but IF they meet the tests is on file at the
association office for verification by anyone who has a question. As I often say, "I don't care if
someone uses plywood made from paper mache! If they can meet the performance test, good for
them!" It's all about encouraging companies to be creative in finding better solutions. If their
proprietary solutions are going to be made public then either they won't be creative OR they won't
go through certification. Either way the public loses. Gotta rethink this. Come on. What is wrong
with plantations if they are following sustainable guidelines? This can help create good jobs, for
instance for indigenous peoples. Gee whiz. You're going a little overboard here. You know, if it
wasn't for GMO's a lot more people around the world would be starving. Nobel prizes have been
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
No, the proposed requirements are too colsely aligned with the FSC system.
If yes, please explain indicate which systems comply and how they are compliant.
The Forest Stewardship Council is a member organization."
If not, please explain how the existing systems are deficient.
The SFI BOD is elected by the existing board in a closed process. Thus the social and environmental
decision-makers are hand-selected by the existing board members

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
yes

Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
No. The Criteria for Governance - Openness - Organizational type: "Membership organizations (i.e.
organizations governed by members) are open to all major interest groups, organizations and
individuals." should be changed. Proposed Revision: Membership organizations (i.e. organizations
governed by members) open to all major interest groups, organizations and individuals USGBC
should maintain a strong performance standard for Wood Certification in the LEED rating system. As
a reflection of the USGBC's core values, the standard should require continuous improvement
through market transformation and must retain rigorous social and environmental requirements
founded on the best available objective science. A strong Certified Wood Credit is important
because the health of our forest eco-systems and their inhabitants is vital to the health of our planet
and our civilization. Forests cover 30% of the world's land area and store over 50% of the world's
carbon. The Certified Wood credit is the only LEED credit that explicitly establishes criteria for all
three core elements of Sustainability and the Triple Bottom Line: Environment, Economics and
Social Equity. While the intent of moving to a performance based criteria for the credit language is
acceptable, the verification process for certification is critical for the Benchmark to be successful. It
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
We believe that additional modifications to the credit would increase the use of environmentally
preferable wood sources. The benchmark criteria essentially mirror the criteria set forth in the FSC
standard. We agree that achieving FSC certification is a worthy endeavor, but there are many
reasons that achieving FSC certification on a meaningful number of products is nearly impossible for
a flooring company the size of Armstrong. These standards are currently very difficult to implement
in many areas around the world. The difficulty in implementation is not always due to poor forest
management or illegal logging conditions. Often times there are already good forest management
practices in place or even certification systems in place that are providing sustainable forest
management but will not meet all of the conditions required in the FSC standards and the USGBC
benchmark standards. Many of the standards that are required deal with social issues, labor issues,
training issues, land ownership issues and others that create requirements outside of what is
needed to ensure sustainable forestry management. Many of these conditions are barriers to a
certification process due to added cost, market consideration or are simply not relevant in some
countries where the issues the standards are trying to eliminate do not exist. The USGBC standards

If not, please explain how the existing systems are deficient.
One possible approach may include a multi-tiered credit. Many organizations, including the World
Wildlife Fund's Global Forest and Trade Network, embrace a stepwise approach to FSC certification -
understanding that the process to become fully certified may take several years, depending on
supply chain complexities. We would like to recommend that the Certified Wood credit become a
tiered credit where a point is given for achieving a certain more basic set of criteria; the second
point would be awarded when the product used was certified by FSC or an equivalent standard as
defined by the "Benchmark Criteria". This approach would help to mobilize a critical mass within the
hardwood flooring market to achieve, at a minimum, a certain level of performance. This would also
help to incent people towards better practices and hopefully would result in a higher percentage of
products eventually achieving the highest level of performance, as defined in the Benchmark
Criteria.
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
NO SFI - Only FSC should be considered!
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
I believe they do establish appropriate program requirements. One area of clarification is listed
below. (#4)

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
Besides FSC, SFI may also comply with the Technical standards and reference.

If yes, please explain indicate which systems comply and how they are compliant.
Please see above.

If not, please explain how the existing systems are deficient.

Regarding the USGBC Benchmark document, on p. 10 it lists "Restrictions on non-certified material"
and the Benchmark's second criteria is " 2) compliance with CITES". Please elaborate as to which
Appendices (I, II, III) the 'compliance' refers to. Secondly, will other organizations such as IUCN be
referenced in the benchmark? IUCN is another authoritative body in terms of threatened species.
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
No. The forest management standards are so vague that they will actually cause more harm than
good. It would have been better to eliminate wood sourcing from the list of LEED credits. Protection
of old growth forests and limiting or eliminating clear-cutting are two critical forest management
issues. The proposed benchmark does not address either of these issues. Instead, the authors of the
benchmark state that both old growth and clear-cutting are addressed by "other benchmarks
contained in the ecosystem-based criteria." However, the definition of ecosystem-based criteria is
vague and does not mention old growth or clear-cutting at all. Neither does the benchmark
reference a publication to detail what is meant by 'ecosystem-based criteria'. This means that a
clear-cutting operation could be deemed 'sustainable' under the USGBC benchmark. Lumber
obtained from clear-cutting -whether for harvest or land conversion - should be disallowed. The
State of Maine could serve as a good model. Small and large woodlot owners thrive under the
state's strong anti-clearcutting laws. Long-term protection of the timber resource is the goal. There
are other important benchmarks that have also been left undefined. For example, reforestation
shall take place "in a timely manner". Does that mean weeks, months, years? This is hopelessly
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Many of the benchmarks establish appropriate requirements. The following benchmarks are
progressive, and we are pleased to see the USGBC use them and support their continued inclusion in
the benchmark: Proposed Benchmark - Training: This is core not only to the success of the forest
operations, but also to include in a forest certification program. In order to ensure properly safety of
forest workers, and also proper implementation of management plans, training of workers is
paramount, and we support the inclusion of this benchmark. Proposed Benchmark - Research: SFM
certification programs should be based on the best available science. Technology is constantly
changing, and it is necessary for certified companies to engage in research activities to ensure they
are employing the most scientifically sound management decisions. However, some benchmarks
need modification in order to provide added benefit to the LEED Standard. These are: Proposed
Benchmark - Forests of special conservation value: Manage lands that are geologically, historically,
or culturally important to protect special qualities. Include regionally and locally significant
attributes, socio-economic attributes, in definition of forests of special conservation value. Provide
public summary of the management program for forests of special conservation value. The USGBC

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
All credible certification programs in North America with fully endorsed standards, such as ATFS,
CSA, FSC, PEFC, and SFI meet the intent of the requirements, in that they seek to protect forest
resources, wildlife, endangered species, water quality, and other important components of the
forest system, while providing the forest products the market demands. Making the changes
outlined above would provide added clarity as to whether specific certification programs could
participate in the LEED standard.

If yes, please explain indicate which systems comply and how they are compliant.
As these are the official comments of the Sustainable Forestry Initiative, we will speak only to SFI's
compliance to the USGBC's proposed benchmarks relating to forest certification system Standards
Substance. However, it is SFI's opinion that the fully endorsed standards of the other certification
programs - such as ATFS, CSA, FSC, and PEFC - will also demonstrate compliance. SFI has analyzed
the proposed policy criteria, and where a benchmark was provided, we have taken text from the SFI
Standard (comprised of 13 objectives, 34 performance measures, and 102 indicators) to
demonstrate how SFI meets the USGBC's benchmarks for Standard Substance. Proposed Benchmark
- Forests of special conservation value: Manage lands that are geologically, historically, or culturally
important to protect special qualities. Include regionally and locally significant attributes, socio-
economic attributes, in definition of forests of special conservation value. Provide public summary
of the management program for forests of special conservation value. Performance Measure 4.1:
Program Participants shall have programs to promote biological diversity at stand and landscape
levels. Indicators: 1. Program to promote the conservation of native biological diversity, including
species, wildlife habitats, and ecological or natural community types, at stand and landscape levels.

If not, please explain how the existing systems are deficient.
No certification program will conform to these benchmarks 100%, which means that some
benchmarks will need to be modified, and the threshold level for compliance needs to be defined in
order to know if a specific Standard will conform to the benchmark for Standards Substance. A
specific explanation follows. Benchmark - Aboriginal Rights and Compensation For example, while
many FSC Standards require compensation to aboriginal communities, a brief review of some of the
largest FSC certified companies in Canada do not show that compensation has ever been given to
aboriginal peoples by the companies. In one case it was listed as a corrective action. Further, "free
and informed consent" can be interpreted in different way as well. The intent box under Section 3.1
in the FSC Boreal standard states: The applicant is expected to make best efforts to obtain a positive
acceptance of the management plan. Thus, harvesting can take place even if consent is not given.
Therefore, as these benchmarks are not practically applied or implemented, they should be
modified as described in Question 1. Benchmark - Plantations The FSC standard allows for
conversion to plantations under Principle 6.10 - Forest conversion to plantations or non-forest land
shall not occur, except in circumstances where conversion: a) entails a very limited portion of the
If not, please explain how the existing systems are deficient.
""Old growth" and "Clearcutting".other benchmarks contained in the ecosystem-based criteria
address this issue - no specific benchmark has been established." Please clarify - where are these
key issues addressed?
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
No. Some of the so called benchmarks are extremely vague. For example, under the Standards
Substance section, Productive Functions, Reforestation the benchmark is "Reforest in a timely
manner." What is a timely manner? One month, one year, two years? There are several similar
examples throughout the Benchmarks submitted for public comment. Also, there is seemingly no
benchmark for Chain-of-Custody certifications related to businesses (lumber yards, retail outlets,
furniture makers, paper producers etc.) that are not directly involved in forest manufacturing
activites. Chain-of-Custody is a critical piece of the puzzle in terms of distinguishing among certified
and non-certified forest products in the marketplace. If engineers/architects/contractors can't
distinguish among certified and non-certified products, how could they ever meet the LEED Certified
Wood credit in the first place? This would obviously be impossible.

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?

This question is not even answerable. The reason is because it is wholly undefined as to the exact
assessment process by which the benchmarks will be applied to judge the various existing systems.
Who will conduct the assessment? Are all benchmarks obligatory or is there a scoring scheme in
place (similar to LEED itself). Not to mention the above concern about the vagueness of many of the
benchmarks and lack of assessment for Chain-of-Custody certifictaion. Until these fundamental
questions are answered, it is impossible to judge whether current systems meet the benchmarks or
not.
If not, please explain how the existing systems are deficient.
No certification program will conform to these benchmarks 100%, which means that some
benchmarks will need to be modified, and the threshold level for compliance needs to be defined in
order to know if a specific Standard will conform to the benchmark for Standards Substance. For
example, while many FSC Standards require compensation to aboriginal communities, a brief review
of some of the largest FSC certified companies in Canada do not show that compensation has ever
been given to aboriginal peoples by the companies. In one case it was listed as a corrective action.
Further, "free and informed consent" can be interpreted in different way as well. The in tent box
under Section 3.1 in the FSC Boreal standard states: The applicant is expected to make best efforts
to obtain a positive acceptance of the management plan. Thus, harvesting can take place even if
consent is not given. Therefore, as these benchmarks are not practically applied or implemented,
they should be modified as described above. The FSC standard has the exceptions listed under
Principle 6.10, which allows for conversion under certain circumstances: Forest conversion to
plantations or non-forest land shall not occur, except in circumstances where conversion: a) entails
a very limited portion of the Forest Management Unit; and b) does not occur on High Conservation

If yes, please explain indicate which systems comply and how they are compliant.
The SFI Program has requirements that cover all of the benchmarks in Standards Substance: Forests
of special conservation value: Manage lands that are geologically, historically, or culturally
important to protect special qualities. Include regionally and locally sigificant attributes, socio-
economic attributes, in definition of forests of special conservation value. Provide public summary
of the management program for forests of special conservation value. See SFI Standard
Performance Measure 4.1, Objective 6, and Performance Measure 8.5. Ecosystem structure,
function and forest successional stages: Maintain natural ecosystem structure and function. See SFI
Objective 2 and Objective 4 Tree/snag/woody debris retention: Retention of stand-level wildlife
habitat elements (e.g. snags, nest trees, etc.) See SFI Performance Measure 4.1. and associated
Indicators. Plantations: No certification of plantations converted after 2007 unless change in
ownership or program to convert back to natural forest beginning in advance of the next harvest
cycle. For this purpose, the definition of plantations is consistent with the FAO definition. See SFI
Indicator 2.1.5 . Species diversity: Promote habitat biodiversity. See SFI Objective 4. Species at risk:

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?

All credible certification programs meet the intent of the requirements, in that they seek to protect
forest resources, wildlife, endangered species, water quality, and other important components of
the forest system, while providing the forest products the market demands. However, all programs
may need to make some modifications to comply fully with the benchmarks as they are currently
written. Making the changes outlined above would provide added clarity as to whether specific
certification programs could participate in the LEED standard.

Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Many of the benchmarks establish appropriate requirements. The following benchmarks are
progressive, and we are pleased to see the USGBC use them and support their continued inclusion in
the benchmark: Training: This is core not only to the success of the forest operations, but also to
include in a forest certification program. In order to ensure properly safety of forest workers, and
also proper implementation of management plans, training of workers is paramount, and we
support the inclusion of this benchmark. Research: SFM certification programs should be based on
the best available science. Technology is constantly changing, and it is necessary for certified
companies to engage in research activities to ensure they are employing the most scientifically
sound management decisions. However, some benchmarks need modification in order to provide
added benefit to the LEED Standard. These are: Forests of Exceptional Conservation Value:
Manage lands that are geologically, historically, or culturally important to protect special qualities.
Include regionally and locally sigificant attributes, socio-economic attributes, in definition of forests
of special conservation value. Provide public summary of the management program for forests of
special conservation value. The USGBC should not require that management plans be made public,
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Dear USGBC/LEED/MRTAG/other: We are writing to express our support of the idea to develop and
use benchmark criteria to recognize leadership in the selection of environmentally preferred and
sustainably produced wood products in the awarding of LEED points. We are however unable to
support the proposal as presented based upon those issues detailed below. The USGBC's efforts to-
date are laudable because they relied on deep research and analysis of the topic to direct the course
of action in a transparent way. To this end, we would like to express our interest that all USGBC
members not only comment on the shift from third-party label recognition to benchmark criteria for
the Certified Wood credit(s), but also on the specific criteria that will comprise the new set of
benchmarks and measurement protocol. Based on our reading of the provided information, it
appears that the membership will only be given the opportunity to provide comments and a yes/no
vote on the decision to make this change, rather than be engaged in a review and approval of
specific criteria. If this is in-fact true, we can not in good faith support this direction as we believe
that a majority of the referenced benchmarks reside in one of these three categories: A. Those
without a specific benchmark (whether because the topic is allegedly covered in another section,
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
I concur with the comments by the FSC-US. Comments on specific benchmarks: Forest Extent. It is
critical that certification address this issue prohibiting or strictly limiting the conversion of diverse,
multi-aged forests plantation or to non-forests. Landscape. Another "Key Issue" that needs to be
addressed is the need for Landscape planning/management to happen at the landscape level, across
multi-ownerships in order to protect connectivity for wildlife and other forestry management issues
which can only be clearly seen and addressed at a landscape level. Re: "Ecosystem structure,
function and forest successionaly stages: Maintain natural ecosystem structure and function." I fully
support this benchmark, however, as stated, it is vague and needs to be defined in greater detail
with explicit references to water, soil, vegetation and fauna at both the ste and landscape levels. It
also needs to require restoration of degraded systems, including intensively managed even-aged
plantations. Re: "Old growth." Given the critical importance of remnant old-growth trees in our
forests, it is critical that a benchmark address the need to protect old-growth by prohibiting the
logging of old-growth--which needs to be further defined--except for the restoration and
maintainance of old-growth, indigenous ownerships with cultural components, and other special

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
Decline comment until benchmarks and process are better defined.

If not, please explain how the existing systems are deficient.
Decline comment until benchmarks and process are better defined.

If yes, please explain indicate which systems comply and how they are compliant.
Decline comment until benchmarks and process are better defined.
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
The Sustainable Forest Initiative is flawed in that it attempts to address societal issues beyond that
of the environment. This occurs in the area of labor and organizing of labor. This issue has little or
no affect on the sustainablity issues being addressed by LEED.
Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?

This standard has the effect of restraining trade. Domestic producers are being excluded for
Canadian producers. The effect is higher pricing due to an artificial monopoly. As a publicly funded
owner, we have an obligation to taxpayers to spend their monies wisely. We are encountering
premiums or 30% for LEED certified lumber of questionable environmental gains.

If yes, please explain indicate which systems comply and how they are compliant.
This is complicated by the fact that domestic producers have legitimate positions which preclude
their inclusion under the existing definitions used. Compliance with what is being perceived as an
"arbitrary set of guidelines" makes this a moot point.

If not, please explain how the existing systems are deficient.

In Ohio we are governed by the Ohio Revised Code which mandates the use of Domestic Steel in all
state-funded projects. LEED forestry initiatives as presently configured mandate foreign materials.
As Owners begin to see and understand the true costs to build LEED certified buildings and
sensitivity to domestic vs. foreign purchasing movement grows, we will probably see some
competing system to LEED which is also friendly to society in a holistic view.
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
There are several problems with some of the proposed benchmarks. On is the idea of avoiding wood
from lands being converted to plantations. This may or not be problematic, depending on how
plantations are defined. This is an issue in tropical forests, where the goal is to site new plantations
on agricultural land or degraded forest, and to avoid converting native tropical forests. The
definitions are clear because the plantations are nearly always exotic species. The U.N. Food and
Agriculture Organization's (FAO) definitions try to make this distinction. With a clear distinction,
conversion should be virtually non-existent in the U.S. If, however, the definition of plantations
includes semi-natural forests, then in some regions in the U.S. a substantial part of current timber
supplies could be interpreted as coming from "conversion" because the harvest is of native species,
followed by tree planting of a subset of those species. This would put the USGBC in the non-
scientific position of opposing tree planting, which is necessary for successful regeneration of many
species, especially those most important for building materials. The other issue is that most forests
in the US are privately owned, most by small landowners, and it is not desirable or realistic to expect
to dictate future land use to them. This issues requires different approaches for different regions, eg

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?

None of the standards can substantiate a claim that products do not include wood from plantations
converted from natural forests. All allow the use of converted wood. Similarly, none can
substantiate the claims implied by the benchmarks on indigenous peoples rights.
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
1.Continual improvement drives positive change and ensures that the program itself is sustainable;
thus, it should be recognized as a specific benchmark. We support further education and outreach
on re-forestation and promoting well-managed forest on all lands, not just those that are certified.
In addition, the handling of un-certified sources in the supply chain should be recognized as a
specific benchmark.

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
2. No comment

If not, please explain how the existing systems are deficient.
4. In general, we feel that this benchmark is too closely aligned with the FSC program and should be
modified to avoid system bias.

If yes, please explain indicate which systems comply and how they are compliant.
3. No comment
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.


No. Perkins + Will feels that the USGBC should maintain a strong performance standard for Wood
Certification in the LEED rating system. As a reflection of the USGBC's core values, the standard
should require continuous improvement through market transformation and must retain rigorous
social and environmental requirements founded on the best available objective science. A strong
Certified Wood Credit is important because the health of our forest eco-systems and their
inhabitants is vital to the health of our planet and our civilization. Forests cover 30% of the world's
land area and store over 50% of the world's carbon. The Certified Wood credit is the only LEED
credit that explicitly establishes criteria for all three core elements of Sustainability and the Triple
Bottom Line: Environment, Economics and Social Equity. While the intent of moving to a
performance based criteria for the credit language is acceptable, the verification process for
certification is critical for the Benchmark to be successful. It must be objective and transparent. In
addition, the membership should be presented with the process before voting on the final revisions.

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?

No. The Criteria for Governance - Openness - Organizational type: "Membership organizations (i.e.
organizations governed by members) are open to all major interest groups, organizations and
individuals." should be changed. Proposed Revision: Membership organizations (i.e. organizations
governed by members) open to all major interest groups, organizations and individuals

If yes, please explain indicate which systems comply and how they are compliant.
Yes. "The Forest Stewardship Council is a member organization."
If not, please explain how the existing systems are deficient.
The SFI BOD is elected by the existing board in a closed process. Thus the social and environmental
decision-makers are hand-selected by the existing board members.
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
In this area of concern, the proposed benchmarks suggest a lowering of standards across the board.
Strong language aside, this is certainly not the direction to go. The USGBC has in its history been the
stubborn enabler urging industry towards more exceptable levels of social and environmental
accountability and responsibility. If the USGBC goes soft and bends to industry, it loses its credibility
and gives up its ability to transform. Disappointements outlined below: Landscape -Forests of
special conservation value Manage lands that are geologically, historically, or culturally important to
protect special qualities. Include regionally and locally significant attributes, socio-economic
attributes, in definition of forests of special conservation value. Provide public summary of the
management program for forests of special conservation value. **PROPOSED use FSC criteria
Landscape -Protected areas (non-special value forests) forests) Other benchmarks contained in the
ecosystem-based criteria address this issue - no specific benchmark has been established.
**PROPOSED Proposed Revision: (Use FSC-US Criteria) Ecosystem Diversity: Ecosystem structure,
function and forest successional stages Maintain natural ecosystem structure and function.
**PROPOSED Proposed Revision: (Use FSC-US Criteria: Consider landscape, species' requirments,

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
No.

If not, please explain how the existing systems are deficient.


The soil productivity benchmark is the only benchmark that FSC does not comply with. FSC-US
complies with all proposed revisions listed in comment 1 with exception to: a) environmental
services where FSC-Canada was suggested, b) residual tree protection where PEFC standards were
suggested, and c) tradition knowledge where FSC-International was suggested. ATFS does not
comply with many of the proposed benchmarks and complies with none of the suggestions made in
comment 1. CSA does not comply with many of the proposed benchmarks and complies with none
of the suggestions made in comment 1. SFI does not comply with many of the proposed benchmarks
and complies with only 'species diversity' and 'timber production' of the suggestions made in
comment 1. PEFC complies with more of the proposed benchmarks by comparrison to SFI, CSA, and
ATFS and complies with all but a few of the proposed revisions outlined in comment 1.
If yes, please explain indicate which systems comply and how they are compliant.
No comment.

If not, please explain how the existing systems are deficient.
No comment.
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Much of the language in this section heavily reflects the FSC certification system. In order to truly
consider other forest certification systems the USGBC should invite input from other systems to
develop environmentally friendly, socially responsible and economically feasible standards that are
more broadly achievable.

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
Once again credible forest certification systems should meet the majority of the benchmarks set by
LEED 2009.
Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?

All system have some portion but none have all. FSC has two fo the core labor standards, PEFC has
all the core standards but not the ILO convention of IP's COnvention 169. Neither system has chain
of custody. One system has chain of cusotdy for tow ILO conventions, MTCC. Requiring the ILO core
labor standards and requiring CofC will drive these systems to comply and strengthen the human
rights and working health of all forestry and millworkers. These standards could be announce now
and put into effect in a year.

If not, please explain how the existing systems are deficient.
See above

Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.

Instead of relying on international standards established more than 50 years ago, the USGBC
systems appears to be attempting to re invent the wheel. The ILO core labor standards have been
almost universally endorsed for more than 50 years by almost every country in the world. Both of
the largest certification systems codify some portion of these standards. There exists an
international UN agency, the ILO, to evaluate compliance and an international mechansim for
conflict resolution and appeals. The labor standard should codify the full ILO core labor standards
and should do so through the entire chain of custody. Reliance on national law where natioanl law is
inadaquate does not promote the rights of workers. Likwise relying on national standards for OSH
will put wood in buildings that may have come from a sustainable forest but was milled at the most
unsafe mill in the world. Safety standards must be absolute. Most countries have accident reporting
readily available. The certification systems must require that all downstream processers provide
work places free from known hazards and risks. Whether they do or not can be determine by the
number of injuries and the severity fo injuries.
If not, please explain how the existing systems are deficient.
See above

If yes, please explain indicate which systems comply and how they are compliant.
See above
Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
See above

Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.


(Same comment for all four sections of the proposed benchmarks:) If the proposed benchmarks do
not exclude SFI or other PEFC certification systems, then I think the proposal is okay. If they exclude
these systems, LEED is creating another forest certification system on top of those that already
exist, and it seems to be doing so even though benchmarks are nonexistent, or at least uncommon,
elsewhere in the LEED ratings. I don't know the answer to the following, but are there benchmarks
for harvesting of bamboo, or for modes of transport within the 500-mile radius, or for the
manufacture of bike racks, or for recycling of metals? If, politically, benchmarks are the best way to
appease the FSC-only crowd, then I support them. But, sooner or later, the FSC-only folks are going
to have to accept that there are other schemes that generate sustainable wood products. We
should be rewarding the use of forest products, not acting to restrict them.
Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
Don't know.

Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.

No. Like the governance requirements, many of these proposed changes are vague and
unsubstantiated. For example, in "Timber production," "long term harvests are sustainable" may
(and will) be subject to interpretation and debate. Also, developing and implementing a program to
protect endangered species does not guarantee that said program will achieve the ostensibly
intended result. These type of guidelines need much more specific language.
If not, please explain how the existing systems are deficient.
No certification program will conform to these benchmarks 100%. The threshold level for
compliance needs to be defined in order to know if a specific Standard will conform to the
benchmark for Standards Substance.

If yes, please explain indicate which systems comply and how they are compliant.

The SFI Program has requirements that cover all of the benchmarks in Standards Substance to
include ecosystem structure, snag retention, plantations, species diversity, species at risk, exotics,
GMO's, natural disturbance, chemical use, timber production, soil productivity, riparian protection,
soil protection, physical infrastucture, aboriginal lands/sites/rights, community benefit, rights to
organize, wages, compensation, health and safety, public consulation, public lands, forest law, land
tenture, management plans, impact assessment, monitoring, training, and research.
Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?

All credible certification programs meet the intent of the requirements with some modifications.

Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.

I support these progressive benchmarks. Training is key to the success of forest operations and
should be included in any forest certification program. SFM certification programs should be based
on the best available science. The USGBC should not require management plans be made public
(antitrust implications). Plantations can have positive benefits. They take pressure off naturally
managed forests, and provide many desirable qualities including biodiversity, water quality, and
wildlife habitat. Continual improvement is key to any sustainable system. It needs to be addressed.
Procurement needs to be addressed. A substantial amount of product in the supply chain is not and
never will be certified to any program. Responsible sourcing by certified companies should be a
requirement under the LEED program.
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.

No. Some of the benchmarks are obviously biased towards one particular certification system. The
GMO benchmark should be modified to recognize that applications of appropriate biotechnology
methods for forest tree improvement have the potential to enhance the quality, productivity, and
value of plantation forests managed for wood, pulp, and bioenergy; protect tree species from insect
and disease problems; and provide other social, economic and environmental benefits. The
Chemical Use benchmark should be modified to include the use of registered pesticides in
accordance with label requirements and used in compliance with applicable state and federal
regulations.

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
No comment.

If yes, please explain indicate which systems comply and how they are compliant.
No comment.

If not, please explain how the existing systems are deficient.
No comment.
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
The proposed benchmarks have many good features mine are deficient in many other areas. Here
are my comments on some of the benchmarks that I am concerned about. 1-Re: ecosystem
structure the terms used here have different meanings when used by different people or groups.
Therefore it is necessary that these terms we defined precisely. It is really important that the
functions of the ecosystem be clearly defined. 2-clearcutting is a method of making harvest cuts that
should not be discriminated against just because it may not be pleasing to the eye. There is no other
way to manage shade intolerant species such as Douglas-fir here in Western Oregon them to clear-
cut. There are absolutely no examples of successful long-term management of West Coast Douglas-
fir her on an individual preselection basis. It may work with other species and other locations but
not for us. Please don't make blanket applications of standards for the whole country. They will be
unworkable for many. 3-Re: snags etc. most of us small woodland owners retain snags and leave
woody debris on the ground when harvesting our timber. USGBC should refrain from writing tiny
detailed prescriptions in this area because timber types vary greatly across the country and also the
wildlife needs and requirements are different in different parts of the country. Here in Oregon just

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
I believe that the American Tree Farm System meets most of the requirements.

If yes, please explain indicate which systems comply and how they are compliant.

The areas in which the American tree farm system may not comply I have addressed above.

If not, please explain how the existing systems are deficient.
I believe I have and this is in section 1.
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
A number of areas could be improved, including the following: 1) Plantations - the benchmark as
proposed can be improved as follows: RMS feels this benchmark as proposed is too closely aligned
with the FSC program and strongly recommends it be modified to avoid that bias. We support use of
the accepted FAO definition of plantations by the USGBC. RMS does not support language that limits
certification of plantations converted after 2007 (with noted exceptions). Rather, a conversion of a
limited portion of the forest management unit should be allowed - we support 5% as the threshold,
as long as that conversion does not occur on forests with exceptional conservation value. 2)
Genetically modified organisms (GMOs) - RMS feels this benchmark can be improved as follows: In
the near future, scientific breakthroughs in biotechnology methods for forest tree improvement
have the potential to enhance the quality, productivity, and value of plantation forests managed for
wood, pulp, and renewable energy; protect tree species from serious insect and disease problems;
and perhaps even allow a return to forests of the magnificent American chestnut. Given the
potential of GMOs to benefit society and the environment, RMS urges USGBC to remain neutral
with regard to a position on use of genetically modified organisms at this time. 3. Chemicals - RMS

If not, please explain how the existing systems are deficient.
A number of areas could be improved, including the following: 1) Plantations - the benchmark as
proposed can be improved as follows: RMS feels this benchmark as proposed is too closely aligned
with the FSC program and strongly recommends it be modified to avoid that bias. We support use of
the accepted FAO definition of plantations by the USGBC. RMS does not support language that limits
certification of plantations converted after 2007 (with noted exceptions). Rather, a conversion of a
limited portion of the forest management unit should be allowed - we support 5% as the threshold,
as long as that conversion does not occur on forests with exceptional conservation value. 2)
Genetically modified organisms (GMOs) - RMS feels this benchmark can be improved as follows: In
the near future, scientific breakthroughs in biotechnology methods for forest tree improvement
have the potential to enhance the quality, productivity, and value of plantation forests managed for
wood, pulp, and renewable energy; protect tree species from serious insect and disease problems;
and perhaps even allow a return to forests of the magnificent American chestnut. Given the
potential of GMOs to benefit society and the environment, RMS urges USGBC to remain neutral
with regard to a position on use of genetically modified organisms at this time. 3. Chemicals - RMS
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Forests of Exceptional Conservation Value There should not be a requirement to make management
plans public due to potential antitrust implications. Instead, require audit reports be made public
and easily obtainable. The certification public summary audit reports clearly state areas of
conformance and non conformance, which would include any information on the management plan
as needed. If a public summary of the management plan is required, it must not include any
proprietary information on harvesting techniques, rotation lengths, etc. Plantations All certification
programs must deal with plantations, whether established or new. Plantations can have a positive
benefit. Prohibiting conversion is not practical given that all certification programs deal with new
and established plantations alike. This benchmark as written is arbitrary and not science based.
Instead, support the certification programs that limit the use of exotics in plantations, and that also
ensure the same requirements for natural forest management exists for planted stands as well.
GMO's There are no commercially grown GMO's in North America. However, research is important
to the future of the world's forests. Therefore GMO's should not be banned based on the
requirements of one program because research involving biotechnology has the potential to restore
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
No. As a member of the U.S. hardwood lumber industry for over 30 years, I am glad to take this
opportunity to comment on the USGBC Forest Certification Benchmark. Hardwood products grown
and processed in the United States are inherently green and environmentally friendly. The U.S.
Forest Service Forest Inventory Analysis FIA has proven that hardwoods grown in the U.S. come
from forests that are sustainable and have been sustainable for over 50 years. For example, in 2006
only 55.2% of net hardwood growth was removed. Products from hardwoods are some of the most
environmentally friendly of all products and their use should be encouraged by all true
environmentalists. Green certification processes add much cost to the product and must be passed
on to the consumer or taken from the grower. As costs increase consumers have less incentive to
use hardwoods and growers have less incentive to keep their land in forest cover. If the ultimate
goal of USGBC is to improve the environment, and encourage sustainable use of raw materials for
the present and the future while decreasing dependency on fossil fuels, then using a resource such
as hardwoods should be given every advantage and its use should be encourage in building and
design. I suggest that since hardwoods have been proven sustainable scientifically through U. S.
Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
Yes. NAHB spec is more practical.

If yes, please explain indicate which systems comply and how they are compliant.
As above

Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Monoculture of trees is not able to sustain an adequate amount of construction, due to the
specifications of strength values (fb primarily.)
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Specific concerns are summarized below: 23 of the 85 policy criteria do not have specified
benchmarks. Additionally, others state that the benchmarks are covered by other requirements. The
lack of clarity in these key issues leaves room for potential manipulation by groups grading
certifications against benchmarks. Really, it leaves the entire benchmark system unclear. Need
further explanation on intent of restrictions on non-certified wood (legality & acceptable sources)
that may be used as a screen for all wood used in green building. Need to clarify that the
Controlled Wood risk assessment must be done at the forest level and not the mill or manufacturing
level. Greater clarification of how social requirements will fit the goal of ensuring a forest is
sustainably managed, and appropriate benchmarks. Pesticide language needs some clarification.
The language, "pesticides acutely toxic to terrestrial or aquatic organisms" will potentially prohibit
use of most/all pesticides. The intent of a pesticide is to be toxic to problematic organisms and
therefore control those organisms. The language should specify "non-target" organisms. Finally,
we disagree with the language to ban genetically modified organisms. At a minimum, USGBC needs

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
In addition to our support of the general intent to allow other certified wood programs, Marvin does
feel there is positive change in some revised language: Governance, Chain of Custody, and
Certifier/Auditor requirements all align good Verification of Legal wood being recognized and
applicable to mixed source standard
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.

Under "7 Protective Functions; Soil and Water Resources" should substitute the words "adhere to"
in place of "follow" state-recognized BMPs.... This modified language should appear under both
"riparian protection" and "physical infrastructure." Under "7 Protective Functions; Legal,
institutional, policy frameworks" "Monitoring" section should have language added to ensure BMP
implementation is being monitored and reported.
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
I am writing as the Director of the Northwest Chapter of Rainforest Relief, which has worked on
since 1993 on identifying and stopping the uses of rainforest wood products that have been
harvested in a destructive manner. I have a Master of Science degree in Zoology and have worked as
an environmental scientist since 1984. The proposed USGBC benchmarks relating to forest
certification system Technical/Standards Substance do not establish appropriate program
requirements. We do not support the move by USGBC to open its process to non-FSC certification
protocols at this time, as no other systems provide the needed rigor, transparency and certainty. In
fact, because of the large number of certifications of logging in primary (previously undisturbed)
forests that have been completed or are under consideration around the world, even certification
under FSC no longer provides the needed certainty that ecological functions and indigenous people
are being protected. This is because no one has been able to demonstrate that this kind of logging
(especially considering concomitant effects such as hunting and colonization done on roads built for
logging) can be done without damaging the residual forest, reducing biodiversity, and diminishing
watershed and hydrologic functions. If the goal of the USGBC is to contribute to forest protection -

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
There are no existing certification systems (including FSC) that protect ecosystem diversity and
forests of special conservation value (i.e., no system protects previously unlogged forest from the
inevitable damage done by loggin).

If not, please explain how the existing systems are deficient.
Existing systems, including FSC, are deficient in large part because they do not recognize the
importance of previously-unlogged (i.e., primary or old-growth) forests, and do not have criteria to
protect biodiversity, watershed and hydrologic functions, and indigenous people. The world's have
experienced an unprecedented rate of destruction and degradation, most of which has occurred in
the last 200 years. According to the World Resources Institute (WRI), only 20% of Earth's original
forests remain today in areas large enough to maintain their full complement of biological and
habitat diversity and ecological functions. These "frontier" forests are: (1) dominated by native
trees; (2) provide a variety of habitat types; (3) are large enough to support viable populations of
native species and withstand natural disasters; and (4) have been subjected to limited human
disturbance. The remainder of Earth's native forests consist of (1) old growth forests lacking the size
or continuity to maintain all of their ecological functions and biodiversity; (2) fragmented old-growth
forests; (3) and second growth forests that may or may not support full natural biodiversity and
ecological functions. Repeatedly, studies have shown that logging for timber is the main factor
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
General Comments: There are key issues addressed in this section that are strong and provide a
foundation to distinguish exemplary forest management practices. We are concerned, however,
that some of the benchmarks in this section are overly ambiguous and that others have wrongly
dismissed a crucial issue as something forest certification cannot address. Additionally, we feel that
some central and longstanding issues of forest management have been understated in the
benchmarks and have been incorrectly referenced to other sections in the benchmarks. Comments
on specific benchmarks: Forest Extent - Forest extent: No specific benchmark - Not considered an
issue that certification can effectively address. The statement that this is not an issue that
certification can address, we believe to be patently incorrect. A standard can and should include
requirements that certificate holders prohibit or strictly limit conversion of natural forest lands to
non-forest or plantations. Further a certification scheme can and should exclude wood from
conversion sources both as an acceptable non-certified component of a mixed-source label.
Landscape - Forests of special conservation value: Manage lands that are geologically, historically, or
culturally important to protect special qualities. Include regionally and locally significant attributes,
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.

Old growth, clear cutting, and forest restoration each have the same benchmark: other benchmarks
contained in the ecosystem-based criteria address this issue--no specific benchmark has been
established. Because these three issues are so important to sustainable forest management, I would
like to see specfically how they are addressed. It is not clear in the matrix.
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Based on the comments in Credit Language Revision section, we feel it is unnecessary to comment
on specific benchmarks. However, we encourage USGBC to ensure that its final benchmarks are
written to avoid any unfair bias toward one certification system over another. As the different
certification systems are working to address the challenges in certification for the hardwood
community, we urge USGBC to keep the door open for an assessment process that assures a fair and
balanced review of each certification system.
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Many of the benchmarks within the standards substance section appropriately address important
issues such as habitat diversity, timely reforestation, and requirements to follow state best
management practices. We appreciate the opportunity to comment on several benchmarks within
the standards substance section which we feel establish inappropriate program requirements.
Several benchmarks also require further clarification and explanation. Ecosystem structure, function
and forest successional stages: This benchmark requires further clarification. In implementation, the
phrase "natural ecosystem structure and function" has several, competing interpretations. ATFS
recommends that USGBC clearly identify the intent of the benchmark and provide set definitions for
each of the terms. Tree/snag/woody debris retention: We agree with this benchmark's intention
and recognize the importance of ensuring forest certification standards address the issue of wildlife
habitat. ATFS encourages USGBC to look at the overall intent of the forest certification standard
when considering forest management effects on wildlife habitat. We recognize that these elements
are important but feel USGBC should avoid prescriptive benchmarks. Exotics: We are encouraged
that USGBC is considering this important issue. Further clarification is necessary on the body
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
A. The lack of a benchmark or objective for both carbon storage and forest extent should be
corrected. The intent of most forest certification systems is to ensure that the forest is managed in
its entirety. That includes everything organic from the base of the soil to the top of the trees. The
important role of growing forests to store carbon, while providing a host of other benefits (i.e.,
water purity, oxygen production, habitat, soil retention, etc.), should be recognized. Given the
USGBC's interest in reducing harmful emissions that advance climate change, it makes sense to
incorporate this measure into both the source of the material and the material itself. As well, the
issue of forest extent should acknowledge the retention of natural forest types and species, the
expansion of forested lands and efforts to diminish conversion of forest lands to other uses. This
should be clarified when discussing plantation forestry. B. The USGBC should also consider
developing a gradient system for compliance and hence scoring. Every system and every certified
forest operation is going to have some areas where they shine and others where there are
difficulties. A simple yes/no may not be the solution to demonstrate sustainable forest

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
Yes. All four standards used in Canada - the Canadian Standards Association's Sustainable Forest
Management Standard (CSA), the Forest Stewardship Council (FSC), the Programme for the
Endorsement of Forest Certification schemes (PEFC), and the Sustainable Forestry Initiative (SFI) -
comply with the Technical/Standards Substance requirements

If not, please explain how the existing systems are deficient.
n/a

If yes, please explain indicate which systems comply and how they are compliant.
The vast majority of Canadian forests are publicly owned. As a result, each provincial government
sets regulations governing their respective forests. The standards set in Canada are among the
toughest in the world and reflect the values underscoring the USGBC's benchmarks. Each of the four
standards used in Canada - CSA, FSC, PEFC, and SFI - must ensure these regulations are followed in
addition to the benchmarks set by the standard. For the most part, the regulations all depend on
independent, third-party audits where auditors measure the planning, procedures, systems and
performance of on-the-ground forest operations against the predetermined standard. A forest
operation that is found to be in conformance with the standard is issued a certificate. The four
programs all provide for the basics by ensuring that harvested areas are reforested, that laws are
obeyed and that there is no unauthorized or illegal logging. Each of the standards incorporates
benchmarks for all of the values desired by USGBC. In fact, many of the standards surpass the
expectations of the government and USGBC in many areas, particularly in Canada, where the public
involvement procedures required by governments, the owners of the land base, are second to none.
All of the systems ensure conservation of biological diversity, of wildlife habitat, soils and water
If yes, please explain indicate which systems comply and how they are compliant.
CSA, FSC, SFI and PEFC, applied in conjunction with regulatory systems in Canada, all comply with
the objectives reflected in the benchmarks. They all help meet the overall goal of promoting good
forest management through principles, criteria and objectives that are viewed by international
governments as the basis of sustainable forest management around the world. They ensure laws are
obeyed, harvested areas are reforested, there is no illegal logging, biological diversity is conserved;
habitat, soils and water resources are protected, and harvesting is sustainable. On the
social/economic side, they all address health and safety issues, indigenous rights, and public input.
Their programs include third party independent audits and chain of custody certification. The
standards have evolved over time, just as the definition of sustainable forest management itself has.
They remain current and relevant through standard reviews and on many fronts there has been
convergence over time. For example, FSC standards have become more responsive to economic
concerns, CSA has become more responsive to social concerns, and SFI is now governed fully
independently from industry. A robust independent assessment carried out by the British
Government's Central Point of Expertise on Timber (CPET) found that CSA, FSC, SFI and PEFC

If not, please explain how the existing systems are deficient.
Not applicable

Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
The benchmarks and the assessment process need to be fair, balanced, and transparent in order to
be successful. - The benchmarks should be worded in a non-prescriptive manner and focused on
intent (results). It is important to avoid looking for specific wording that may be in one standard but
will likely not be in others, when indeed they are both addressing the same objective. - The
regulatory and social framework for which standards were developed must be considered as part of
the assessment. Canada has some of the toughest forestry laws in the world, so some benchmarks
(e.g. chemical use and GMOs) are not repeated in the certification programs developed for use in
this country. - A threshold level of benchmarks that must be met in order to receive a "passing
grade" should be set. This would recognize that sustainable forest management itself is a continuum
(it is not an 'all or none' situation), that standards are diverse for a number of good reasons, and
that they are all continually evolving. A few notes on specific benchmarks follow: Tree/snag/woody
debris retention. Retention of stand-level wildlife habitat elements (e.g. snags, nest trees etc). We
suggest adding "Where ecologically appropriate" Riparian Protection. If the focus is on North
American standards, this benchmark should read, "Follow state-recognized or provincial Best

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
Yes. The major credible and recognized systems used in Canada (CSA, FSC, PEFC and SFI) all comply
with the proposed technical/substance requirements.
If yes, please explain indicate which systems comply and how they are compliant.
NA

If not, please explain how the existing systems are deficient.

Urban forests are currently certified by the National Arbor Day Foundation. The most common and
recognizable program, Tree City USA, awards annual certificates to municipalities for sound
community tree management. The Growth Award, provides Tree City USA communities an
opportunity to be recognized for continual improvements in community forest management
including wood reclamation. There are complementary programs for campuses, utility rights-of-way
and military lands. However, the Tree City USA program currently does not address urban timber
harvesting in a significant way and therefore would not meet the Forest Certification System
Benchmark for LEED Certified Wood.

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
No urban forest management system could qualify.

Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
The Illinois Emerald Ash Borer Wood Utilization Committee welcomes the U.S. Green Building
Council's move toward a Forest Certification System Benchmark, but we want to make sure that the
new benchmarking system allows urban forests to be certified so that urban and community trees
can receive wood material credits in LEED buildings. As currently written, only forests managed for
their commodity crop value will qualify. This is not acceptable. LEED certification is supposed to
demonstrate that a building is, among other things, "environmentally responsible." When certifying
wood used in buildings, which is more environmentally responsible: using wood from trees grown to
be harvested as a crop (typically) hundreds of miles away from the site or using wood (typically)
from nearby trees grown for their aesthetic benefits and felled due to insect infestation, disease,
age specific decline, safety issues, or to make way for the very project seeking certification?
Commodity forests are managed for the trees' value when dead. Urban forests are managed for the
trees' value while living: improving the quality of life and saving energy costs (as reflected in
increased property values). Because urban and community trees are not grown for their timber
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Forests of Exceptional Conservation Value: It should be recognize that: - forest management
standard are publicly available, - certification bodies procedures are publicly available, - certification
results (including summary of certification reports) are publicly available, - most of the forest is open
to public access. These documents therefore provide excellent information to the public, and it is
not clear in how far public summaries (whichever form they may take) add value to the already
available information. (see also comment on "Public consultation). Conversions: Conversion of
forest is a result of political processes in individual countries and should be based on land use
planning and land allocation. Forest plantation can have a positive impact on economic and social
development of developing countries as well as they can contribute to minimize pressure on natural
and the most valuable forests. The criteria relating to plantations or natural forest conversion
should therefore be focused on conditions under which the plantations can be established rather
than prohibit the plantations access to certified status and their product to some markets. In
addition, Agenda 21 as agreed within UN Conference on Environment specified that the land use
planning and land allocation is a sovereign authority and responsibility of national governments.
If not, please explain how the existing systems are deficient.

If numerous and varied ways. Overall the goal should raise the bar for forest certification from
where it is now with the prescriptive standard of FSC by creating a standard that embodies the
Precautionary Principle, while requiring continuous improvement and rigorous requirements
founded on the best available objective science. In addition, the Yale Forestry Report recommended
a pre-requisite that all wood in LEED projects come from certified sources. This would be a welcome
addition and give room for all programs.

Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
No. - -Forest extent*** -No specific benchmark - Not considered an issue that certification can
effectively address. Proposed Revision: Forest conversion to plantations or non-forest shall not
occur except: limited areas, not High Conservation Value Forest and leads to long-term conservation
benefits. Consider conversion of abandoned agriculture and treeless lands into forest with proven
long term conservation benefits only - -Carbon storage*** -No specific benchmark - No measurable
requirements found in existing schemes. Proposed Revision: Maintain and appropriately enhance
forest resources and their contribution to global carbon cycles according to the best available
science and emerging research. (ie. Intergovernmental Panel on Climate Change and the Pew Center
on Global Climate Change.) Landscape - - - - -Forests of special conservation value : Proposed
Revision: Change to Forests of High Conservation Value-Manage lands that are geologically,
historically, or culturally important to protect special qualities. Include regionally and locally
significant attributes, socio-economic attributes, in definition of forests of special conservation
value. Provide public summary of the management program for forests of special conservation
value. Proposed Revision: (Use FSC criteria.) - -Protected areas (non-special value forests) forests) -

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
No
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Plantations: The LEED position on plantations looks somewhat extreme and might go beyond even
the FSC standard. The full picture would require a look at the FAO definition of "plantation", the
emphasis being on natural forest conversion rather than plantations established on former
agricultural lands. It would be helpful to have the FAO definition included in the LEED table and for
LEED to clarify that tree planting for natural forest cover types is acceptable. Even allowance of
some FAO type plantations should be accepted if they take pressure off of natural forests.
Genetically Modified Organisms (GMOs): LEED should not include a blanket rejection of GMOs. In
the US, GMO permitting is controlled by the USDA through APHIS permitting. Currently, no GMO
forest plants have been registered by USDA, but it seems false to reject GMOs if careful USDA
review were to establish an acceptable product in the United States. FSC certainly has this
requirement covered, but an allowance for GMO forest plants should be made (as in SFI) if such a
plant were approved by a rigorous, scientific governmental review. A blanket rejection of GMOs is
based on emotion, not science or logic. Including it in LEED shows a bias in favor of FSC. Chemical
Use: The LEED standard on pesticides is written so that only FSC will qualify. Since LEED is a US

If not, please explain how the existing systems are deficient.

American Tree Farm System operates exclusively on private, non-industrial forestland in the United
States. In the US, the legal rights of indigenous peoples have been defined by treaties, laws, and on-
going judicial review. The aboriginal land and tenure rights requirement should not be extended to
lands beyond those under the direct control of a given group of indigenous peoples.
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
MNDNR supports establishing specific, meaningful, measurable requirements for those key issues
listed under biodiversity in the "Biodiviersity in Forest Certification Benchmark Draft.

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
Yes

If yes, please explain indicate which systems comply and how they are compliant.

After a brief review of the Technical/Standards Substance requirements as established in the USGBC
benchmarks, it appears that both FSC and SFI certification systems are compliant. There are most
likely other systems, including PEFC that may comply as well... though Minnesota Department of
Natural Resources (MNDNR) is not as familiar with systems beyond SFI and FSC. Without dublicating
or contradicting other systems already in existance, MNDNR supports establishing specific,
meaningful, measurable requirements for those key issues listed under biodiversity in the
"Biodiversity in the Forest Certification Benchmark Draft."

If not, please explain how the existing systems are deficient.
NA
If yes, please explain indicate which systems comply and how they are compliant.

The CSA Z809 standard, considered within the regulatory framework in which it is applied, meets
the spirit and intent of these requirements. It also has many other strengths that go beyond the
requirements For example, performance goals are achieved and then continuously improved upon
through a system of planning, implementing, checking, corrective actions and management reviews.
Then the cycle begins again. The quality and validity of indicators of sustainable forest management
(such as clean water), and the targets established for each of them, are regularly assessed using this
system. The information is then used to modify forecasts, activities and plans. In this way new
knowledge and changing environmental, social and economic values are incorporated into forest
management.

If not, please explain how the existing systems are deficient.
Not Applicable

Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Carbon Storage - Because of the importance of the climate change issue, a separate and specific
benchmark would be appropriate here. We suggest adding a benchmark for understanding the net
carbon uptake in a forest area. Forest managers can then consider that information when
developing forest management strategies. Plantations -As it currently reads this benchmark is
detailed to the point of being unclear and confusing. We suggest it be reconsidered, simplified, and
stated in the form of an Objective around the maintenance of ecosystem diversity. Species at Risk -
We suggest getting away from the prescriptiveness of "Develop and implement a program." and
focus instead on the objective. In this case the benchmark stated in the form of an Objective would
read "Protect threatened and endangered species and their habitats". This allows for "species at
risk" protection in a variety of circumstances including those in public versus private lands, and
within different domestic jurisdictional situations. For example, in Canada on public lands forest
managers ensure the existence of habitat and help prevent a species from becoming more at risk by
implementing programs to protect the populations. However, those programs are developed by
governments which are responsible for involving all stakeholders / players across a landscape. At the

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
yes
Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
Not sure about the meaning of this question.

Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.

Somewhat. Requirements should support scientific based forest management practices. Also, the
statement under 'forest health', natural disturbance, chemical use, "Prefer natural methods, such as
integrated pest management, to control plant and animal pests and diseases." The integrated pest
management is not synomymous with 'natural methods' as the statement implies. The statement
should read something like "Integrated pest management must be followed to control plant and
animal pests and diseases."
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
No. They establish FSC requirements. One could argue that they have been created to exclude all
other certification systems. In the process, they cut out of LEED the vast majority of certified
sustainable forest products, as well as almost the entire hardwood resource, which has been
sustainably managed for many generations.

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
Yes. FSC.

If yes, please explain indicate which systems comply and how they are compliant.

Yale built these benchmarks around the FSC standards, so naturally FSC fits the benchmarks.
If not, please explain how the existing systems are deficient.
The existing systems are not deficient, the benchmark is deficient!!! For one reason or another, SFI,
ATFS, PEFC and CSA are all excluded from meeting the benchmark, and in ways that will not easily
be overcome, nor should they be. SFI: One LEED benchmarks says a certification system acceptable
to LEED must prohibit the use of genetically modified organisms. That single clause shuts out SFI,
which is currently the most viable certification alternative to FSC for softwood lumber and product
producers. ATFS: LEED's proposed changes would require annual audits. The American Tree Farm
System (ATFS), the most likely current avenue for expanded hardwood certification, only
administers 5-year audits. ATFS also does not specifically restrict usage of any chemicals or
genetically modified trees. CSA: It's hard to tell whether CSA would meet the revised LEED standard
for certified wood. My guess is "no," simply because CSA does not lay out hard and fast forest
management guidelines, but rather leaves that up to specialists within each defined forest area
(DFA). PEFC: On-site inspections of forest certifications are only mandatory every 5 years under
PEFC.
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.

The inclusion of all recognized forest certification systems (including the SFI and CSA Standards) is
beneficial to the encouragement of exemplary environmentally and socially responsible forest
management. West Fraser Mills Ltd strongly supports the inclusion of the SFI and CSA certification
systems, as the company's forest management is certified primarily to the SFI standard.
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
LEED Certified Wood, Forest Certification System Benchmark The following comments represent the
position of the State of Oregon by and through the Oregon Department of Forestry, Oregon Forest
Resources Institute, and the Oregon Department of Energy. More information relevant to these
comments is available upon request. The State of Oregon does not support elements of the
proposed forest certification system benchmark that essentially restate Forest Stewardship Council
standards. The USGBC is encouraged to coordinate with the international Programme for the
Endorsement of Forest Certification (PEFC). PEFC already has a mature system for evaluating forest
certification systems in place and has established itself as the dominant global organization for this
purpose. Rather than developing a redundant new system for evaluating certification systems,
USGBC should consider developing an alliance with PEFC. The Oregon Board of Forestry has also
developed draft Oregon principles and recommended elements for the evaluation of voluntary,
market-based, forest management certification systems. The USGBC is encouraged to consult these
principles and elements and incorporate them where applicable into the proposed Benchmarks.
Important Oregon principles applicable to Technical/Standards Substance are described below:
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
I could not find where the program requirements addressed the use of reclaimed wood in a product.
Reclaimed wood, both post and pre-consumer, is used in many applications. Besides producing a
green product, it also reduces how much of the waste is burned and/or landfilled. Unfortunately,
many of the certifiers being discussed do not include a certification for products produced from
100% post-consumer waste. The only certification currently available is from the SmartWood under
their Rediscovered Wood Program.
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
I believe that all American grown wood should be included in and approved for LEED use. Studies
and reports, year after year, show that America is growing more wood than is being harvested. We
also know that the sound forestry practices that occur in the US allow for healthy forests that
remove carbon from the air. When a tree is healthy and growing carbon is taken from the air and
replaced with oxygen. When a tree stops growing and eventually starts to decay, this processed is
reversed, which is just one reason to keep the forests healthy by tree removal. Not to mention that
wood itself is recyclable, re-usable and biodegradable. I think it is unfair to say only those that PAY
the FSC the big bucks to have their forests or wood certified are worthy of having thier wood used in
LEED building projects. What if the closest FSC certified wood for a particular projcet is 500 miles
away, but a sawmill 5 miles down the road has the exact same wood, cut from a forest in which Best
Management Practices were used, but does not have specific certification from the Forest
Stewardship Council. How can one agree that it is a better decision to waste the fuel it takes to drive
500+ miles to get the FSC certified wood, than to use the wood available, close by, that is just as
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.

Under "Sustainable Forest Management Themes," the use of "Genetically Modified Organisms
(GMO's)is prohibited. Technically, this would prohibit the use of most of the Southern Yellow Pine
wood grown in the USA because for decades it has been genetically modified by cross-breeding. I
don't think this is the intgent of this requirement. Perhaps the prohibition should be limited to
"Organisms genetically modified by gene manipulation techniques" or some similar wording.
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
On the surface, the various SFM Themes, Criteria and Key Issues listed appear to incorporate the
major elements universally recognized as needed for generic Sustainable Forest Management
(SFM). However, it remains that many of the Key Issues and related benchmarks also originate from
a specific certification scheme. For reason of transparency, the USGBC should endeavour to adhere
to elements identified in scientific definitions emanating from independent and recognized
processes such as the "Montreal process" and the "Helsinki process". These impartial processes
have help to define in generic terms those elements of SFM, without bias. While, in this regard,
there exists variations amongst all existing certification systems, the assessment process aught to
evaluate general alignment or compliance with the basic elements of SFM. In addition, a number of
the benchmarks are quite specific and prescriptive in nature. It is thus suggested that the
benchmarks should be written in a way that describes the desired outcome or result rather than a
specific means to address the General Concept identified. Finally, it is noted that the process by
which the evaluation of forest certification systems will occur is yet to be defined. It is thus unclear
how a "pass/fail" grade will be determined. In this aspect, it is strongly recommended that the

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?

Yes. It is believed that the four standards we are familiar with in British Columbia (Canadian
Standards Association - CSA, Forest Stewardship Council - FSC, Sustainable Forestry Initiative - SFI,
Programme for the Endorsement of Forest Certification schemes - PEFC) all substantially comply
with the Technical/Standards Substance requirements listed.

If yes, please explain indicate which systems comply and how they are compliant.

The four standards in use in British Columbia (Canadian Standards Association - CSA, Forest
Stewardship Council - FSC, Sustainable Forestry Initiative - SFI, Programme for the Endorsement of
Forest Certification schemes - PEFC) all substantially comply with the requirements listed. These
four standards contain requirements against all seven "SFM Themes" identified in the USGBC
benchmarks. They all include elements for the conservation of biological diversity and maintenance
of ecosystem functions such as wildlife habitat, soil and water quality. All systems require
engagement with aboriginal people potentially affected by forest management and recognize and
respects their indigenous rights. Associated concepts are particularly well developed in Canada and
British Columbia through established framework for consultation and dispute resolution processes.
Public participation is also included in all these systems and is particularly prominent in the CSA
standard. Finally, all incorporate a process for continual improvement involving elements of
monitoring and adaptive management.

If not, please explain how the existing systems are deficient.
N/A
If yes, please explain indicate which systems comply and how they are compliant.
WTCA - Representing the Structural Building Components Industry has no comment.

If not, please explain how the existing systems are deficient.
WTCA - Representing the Structural Building Components Industry has no comment.
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.


WTCA - Representing the Structural Building Components Industry comment: With respect to the
entire Standards Substance section, if there are items that do not have a specific standardized
benchmark that can be measured or quantified in a specific manner, WTCA believes they should be
removed. Additionally, items that do not relate specifically to the forest certification process should
be removed. For instance, if items are not considered "core issues," why are they included? We
believe that they should not be. Finally, all benchmarks should be fully defined and standardized
using a consensus standard development procedure (e.g. ANSI, ASTM, etc.). With respect to the
entire Standards Substance section, it is clear that the benchmarks presented are largely based on
FSC certification criteria, which WTCA believes is inappropriate. If the process of evaluating forest
certification programs is to be done in an unbiased manner, the criteria or benchmarks cannot be
based on or driven by FSC and should be based on a standard that is developed under a consensus
standard development procedure (e.g. ANSI, ASTM, etc.).

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
WTCA - Representing the Structural Building Components Industry has no comment.
Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
-

Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
There appears to be a great deal of alignment with the FSC program which should be removed to
avoid system bias.

If yes, please explain indicate which systems comply and how they are compliant.
-

If not, please explain how the existing systems are deficient.
-
If yes, please explain indicate which systems comply and how they are compliant.
The four standards in use in Canada (CSA, SFI, PEFC and FSC) all depend on independent , 3rd party
audits where auditors measure the planning, procedures, systems and performance of on-the-
ground forest operations against the predetermined standard. All standards remain current and
relevant through regular standard review cycle (approximately every 5 years). For plantations
suggest using FAO definition. Should provide a defintion of "genetically modifed organism" and have
objective address both improved planting stock and biotechnology using sound scientific methods
and following applicable laws and international protocols. On chemical use the benchmark is too
closely aligned with the FSC program and should be modifed to avoid system bias. Stress IPM
approach and use of registered pesticides in accordance with label and applicable
legislation/regulations. On Aboriginal land and tenure rights USGBC should consider the
interpretation by FSC Canada of Indicator 3.1.2 of the National Boreal Standard which states that
"the intent of the standard clearly allows for certification to take place even in a situation where
there is not agreement with an affected Indigenous Community. In such circumstances the applicant
needs to be able to demonstrate that is has made "best efforts" to reach agreement, and is making

Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.

We believe that the benchmark assessment should focus on the objective of practising sustainable
forestry. A number of the benchmarks are prescriptive as currently written and should be modifed
to use goal/objecive focused language that can allow best practises to be demonstrated. The USGBC
should consider a graduated assessment approach to their benchmark with an expectation of
continuous improvement. Within each general category a threshold measure of acheievement (ie
70%) should be assigned. Where performance within categories or subcategories meets the
threshold but is less than 100%, an expectation of continual improvement to their achievement
must be domonstrated within the duration of the certification standard.

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?

Yes. The four standards in use in Canada (CSA, SFI, PEFC and FSC) all comply with the
Technical/Standards requirements if the USGBC moves from a prescriptive to a goal/objective
approach and assesses both the requirements of the certification as well as all applicable legislation.
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Benchmark for Forest Extent- Should require conversion to plantation or non-forest use is
prohibited and minimized (e.g. FSC 6.10, 10.9). Biodiversity/Landscaope/Forests of special
conservation value benchmark - The definition of "forests of special conservation value" is too
vague; definition does not speak to biodiversity or ecological values. The benchmark does not
consider issue of scale, as uniqueness can be global, regional, subregional and/or local. Identification
of these areas should be subject to consultation with specialists in the area concerned, indigenous
peoples, and stakeholders. Continuous monitoring of management regime should also be required
to ensure the values are being maintained. Benchmark for protected areas - we disagree that the
other benchmarks address this issue. The criteria proposed are too general and do not speak to
reserving representative samples of ecosystems or habitat. Benchmark for ecosystem
structure/function and successional stages: As currently worded, the benchmark is too vague to
allow for meaningful evaluation of whether the key issue is being addressed. Should require
maintenance of distributions of wildlife habitat, plant communities, forest age, structure and
composition, representative of the range of natural variation. Moreover, simply comparing the

If yes, please explain indicate which systems comply and how they are compliant.
This should be determined through an independent evaluation, conducted by experts familiar with
all certification systems

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
This should be determined through an independent evaluation, conducted by experts familiar with
all certification systems

If not, please explain how the existing systems are deficient.
This should be determined through an independent evaluation, conducted by experts familiar with
all certification systems
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
No! American hardwoods should recieve credits for sustainability of the forests and proven legality
of harvests, without 3rd party certification!
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
No, the current proposed technical standards fail to recognize intensive forest management as a
long term objective. Plantation forestry should be encouraged on high site currently non-productive
forest land. for example after catastraphic wildfire, society should be encouraging quick salvage of
destroyed commercially viable products and prompt reforestation of native commercial species
through intensive forest management practices.Plantations. No certifications of plantations
converted after 2007 unless change in ownership or program to convert back to natural forest
beginning in advance of the next harvest cycle. For this purpose, the definition of plantations is
consistent with the FAO definition. Points for USGBC consideration include: Ø This benchmark is
too closely aligned with the FSC program and should be modified to avoid system bias. Ø For
clarity, USGBC should use the accepted FAO definition. Ø All certification systems allow conversions
to occur - this needs to be recognized by USGBC. For example, FSC Principle 6.10 states, "Forest
conversion to plantations or non-forest land uses shall not occur, except in circumstances where
conversion: · Entails a limited portion of the forest management unit · Does not occur on high
conservation value forest areas; · Will enable, clear, substantial, additional, secure, long-term

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
Chemical Use. Prefer natural methods, such as integrated pest management, to control plant and
animal pests and diseases. The following chemicals are prohibited: chlorinated hydrocarbon
pesticides, pesticides banned by international agreement. Also prohibited, chemicals deemed to be
acutely toxic to terrestrial or aquatic organisms or highly persistent (including dioxins) according to
WHO, the US EPA or the Stockholm Convention on Persistent Organic Pesticides (POP). If temporary
exemptions are allowed, there is a formal transparent process for obtaining them. Points for USGBC
consideration include: Ø A prescriptive benchmark rather than the current proscriptive approach
would better serve the benchmarking process. An improved benchmark would include; · Support
for integrated pest management · Use of least toxic chemicals necessary to achieve management
objectives. · Use of registered pesticides in accordance with label requirements. · Compliance
with applicable state and federal regulations. Ø A prescriptive benchmark supports the role of
governmental agencies to assess the risks including toxicity and persistence and benefits of
pesticides. Ø This benchmark is too closely aligned with the FSC program and should be modified to
avoid system bias.

If yes, please explain indicate which systems comply and how they are compliant.


Chain of Custody and Labeling Acceptable non-certified sources for percent-based claims. No virgin
or pre-consumer recycled wood from 1) non-certified forests of special social and environmental
conservation value, 2) genetically modified organisms and 3) harvesting that converts natural forest
to plantations/ non-forest. Points for USGBC consideration include: Ø This benchmark is too closely
aligned with the FSC program and should be modified to avoid system bias. Ø Definitions and
interpretation of the benchmark is needed to better understand expectations and intent. Ø Do the
provisions of sections 1), 2) and 3) apply to non-certified sources and thereby excludes sources that
are certified or do they apply to sources from only those certification programs recognized by
USGBC? Ø The term "forests of special social and environmental conservation value" needs to be
defined. Ø See comments above on GMO's and plantations.
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.

Cost needs to be considered in all aspects of certification. Small landowners, hardwood sawmills,
etc. cannot justify the cost and does not bring a premium in the market place. Research needs to be
based on the best available science. Training is an important part of forest management.
Management plans should be not public information. This information needs to be kept
confidential. Publicizing audit reports would be appropriate which show areas of conformance or
non-conformance. Public Consultation: Again, forest management plans should not be public
information. Procurement: The growing problem of sourcing the adequate amount of certified fiber
on private land in the East is a continuing debate. Methods for certifing the fiber from these lands
needs established that is economically feasible and benefits the landowners who may only harvest
their lands once or twice in their lifetime.

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
Yes, if recommended changes are made.

If yes, please explain indicate which systems comply and how they are compliant.
The American Tree Farm System and SFI have all of the benchmarks.
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Plantations: Under the USGBC proposal, no certification is allowed on plantations converted after
2007 unless change of ownership or program to convert back to natural forest beginning in advance
of the next harvest cycle. All certification programs must deal with plantations, whether established
or new. Plantations can have a positive benefit by reducing pressure on naturally managed forests,
while providing fiber for needed building products. Under the SFI standard, all forest management
requirements such as biodiversity, water quality and wildlife habitat are implemented on natural
and planted forests alike. USGBC should support certification programs like SFI that limit the use of
exotics in plantations and natural forests, and also ensure the same requirements for natural forest
management exist for planted stands as well. This language seems to follow closely the language
from the FSC Standard. This benchmark should be modified to avoid bias. GMOs: USGBC proposal
prohibits all use of genetically modified organisms throughout the world. But research is imperative
to the future of all forests, like finding ways to make trees resistant to insects and disease that
regularly destroy immense forestlands. Limited government-approved trials of GMOs in North
America are research-based and do not mean commercial sales because they aren't commercially
If not, please explain how the existing systems are deficient.
They are compliant

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
It appears that SFI and FSC comply with the requirements. That is our experience in DNR, which is
dually certified.
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.

Yes, there are very detailed and cover many of the Standards' principles and criteria and objectives.

If yes, please explain indicate which systems comply and how they are compliant.

They both examine landscapes, visual concerns, protection of environmental ecosystems,
plantations, old growth, chemical use, exotics etc. forest productivity, riparian protections,
aboriginal rights, social considerations and local economic vitality. Training, certification and
transparency and independent audint by third parties are also included and consistent.
Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
Yes

If yes, please explain indicate which systems comply and how they are compliant.

All current systems should be included if a certification system should be required. There have been
numerous studies completed showing the effectiveness of each system. We believe that limiting the
certification bodies can be detrimental to sustainable forestry as a whole.

If not, please explain how the existing systems are deficient.
All current systems should be included

Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.

Fitzpatrick & Weller, Inc. believes that all hardwood sourced from the United States should not be
subject to a certification system because it meets the benchmark requirements.
If yes, please explain indicate which systems comply and how they are compliant.
The Western Red Cedar Lumber Association supports and endorses the comments submitted by
Forestry Innovation Investment on this point: namely that "The four standards used in British
Columbia and Canada - CSA, FSC, PEFC, and SFI - all depend on independent, third-party audits
where auditors measure the planning, procedures, systems and performance of on-the-ground
forest operations against the predetermined standard. A forest operation that is found to be in
conformance with the standard is issued a certificate. The four programs all provide for the basics
by ensuring that harvested areas are reforested, that laws are obeyed and that there is no
unauthorized or illegal logging. They all go beyond this by ensuring the conservation of biological
diversity, the maintenance of wildlife habitat, soils and water resources, and the sustainability of
timber harvesting, all of which promote sustainable forest management. All require annual
surveillance audits and public disclosure of findings through audit reports. They all require
engagement with affected aboriginal people to ensure traditional forest knowledge and values and
rights are respected. Of particular note, Canada's constitution protects the rights of Aboriginal
peoples, and there is a strong framework in place for resolving disputes about rights and settling
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
The Western Red Cedar Lumber Association supports and endorses the comments submitted by
Forestry Innovation Investment on this point: namely that "We believe that the benchmark
assessment should focus on the objective of practicing sustainable forestry. As such, it needs to
assess the baseline legal requirements and benchmarks within the various certification standards.
Examples where this needs to occur include benchmarks for wages, rights to organize, soil
productivity, riparian protection, soil protection, residual tree protection, species at risk, GMO's and
chemical use (this list is not exhaustive). A number of the benchmarks are prescriptive as currently
written and we recommend the use of goal/objective focused language. When language is too
prescriptive, the ability to demonstrate best practices is limited. We believe that goal or objective
oriented language will allow certification programs to demonstrate how the meet and exceed the
benchmarks in new and unique ways and helps to promote continuous improvement of all
standards. There is clear evidence that in response to competition, all certification standards have
improved over the past several years. USGBC should consider a graduated assessment approach to
their benchmark with an expectation of continuous improvement. Within each general category

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?

The Western Red Cedar Lumber Association supports and endorses the comments submitted by
Forestry Innovation Investment on this point: namely that "The four standards used in British
Columbia and Canada - the Canadian Standards Association's Sustainable Forest Management
Standard (CSA), the Forest Stewardship Council (FSC), the Programme for the Endorsement of Forest
Certification schemes (PEFC), and the Sustainable Forestry Initiative (SFI) - all comply with the
Technical/Standards Substance requirements, particularly if the USBGC moves from a prescriptive to
a goal/objective approach and assesses both the requirements of the certification as well as all
applicable legislation."
If not, please explain how the existing systems are deficient.
Hardwood sourced from the United States should not be subject to a certification system because it
meets the benchmark requirements. If a certification system is required, all current systems should
be included.
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
According to the PEFC Council, the USGBC should recognize that: - forest management standard are
publicly available, - certification bodies procedures are publicly available, - certification results
(including summary of certification reports) are publicly available, - most of the forest is open to
public access. Therefore the public has been provided with sufficient opportunity to learn about the
applied forest management practices as well as influence the certification process. · Plantations:
No certification of plantations converted after 2007 unless change in ownership or program to
convert back to natural forest beginning in advance of the next harvest cycle. For this purpose, the
definition of plantations is consistent with the FAO definition. PEFC Council: Conversion of forest is a
result of political processes in individual countries and should be based on land use planning and
land allocation. Forest plantation can have a positive impact on economic and social development of
developing countries as well as they can contribute to minimize pressure on natural and the most
valuable forests. The criteria relating to plantations or natural forest conversion should therefore be
focused on conditions under which the plantations can be established rather than prohibit the
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Standards Substance 1: Do the proposed USGBC benchmarks relating to forest certification system
Standards Substance establish appropriate program requirements? Please explain and/or suggest
how the requirements might be improved. Many of the benchmarks establish appropriate
requirements. The following benchmarks are progressive, and we are pleased to see the USGBC use
them and support their continued inclusion in the benchmark: Training: This is core not only to the
success of the forest operations, but also to include in a forest certification program. In order to
ensure properly safety of forest workers, and also proper implementation of management plans,
training of workers is paramount, and we support the inclusion of this benchmark. Research: SFM
certification programs should be based on the best available science. Technology is constantly
changing, and it is necessary for certified companies to engage in research activities to ensure they
are employing the most scientifically sound management decisions. However, some benchmarks
need modification in order to provide added benefit to the LEED Standard. These are: Forests of
Exceptional Conservation Value: Manage lands that are geologically, historically, or culturally
important to protect special qualities. Include regionally and locally sigificant attributes, socio-
Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?

Many of the benchmarks establish appropriate requirements. The following benchmarks are
progressive, and we are pleased to see the USGBC use them and support their continued inclusion in
the benchmark: Training: This is core not only to the success of the forest operations, but also to
include in a forest certification program. In order to ensure properly safety of forest workers, and
also proper implementation of management plans, training of workers is paramount, and we
support the inclusion of this benchmark. Research: SFM certification programs should be based on
the best available science. Technology is constantly changing, and it is necessary for certified
companies to engage in research activities to ensure they are employing the most scientifically
sound management decisions.

Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
, some benchmarks need modification in order to provide added benefit to the LEED Standard.
These are: Forests of Exceptional Conservation Value: Manage lands that are geologically,
historically, or culturally important to protect special qualities. Include regionally and locally
sigificant attributes, socio-economic attributes, in definition of forests of special conservation value.
Provide public summary of the management program for forests of special conservation value. The
USGBC should not require that management plans be made public, because if they contain
proprietary information, this could have antitrust implications. Instead, the USGBC should require
that the audit reports are made public and easily obtainable. The certification public summary audit
reports clearly state areas of conformance and non conformance, which would include any
information on the management plan as needed. It should be the responsibility of the certification
program's governing body to ensure that all audit reports are housed in one place, so that the public
can easily access them, as they are on the SFI website. If the USGBC requires a public summary of
the management plan, it must not include any proprietary information on harvesting techniques,
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Many of the benchmarks establish appropriate requirements. The following benchmarks are
progressive, and we are pleased to see the USGBC use them and support their continued inclusion in
the benchmark: Training: This is core not only to the success of the forest operations, but also to
include in a forest certification program. In order to ensure properly safety of forest workers, and
also proper implementation of management plans, training of workers is paramount, and we
support the inclusion of this benchmark. Research: SFM certification programs should be based on
the best available science. Technology is constantly changing, and it is necessary for certified
companies to engage in research activities to ensure they are employing the most scientifically
sound management decisions. However, some benchmarks need modification in order to provide
added benefit to the LEED Standard. These are: Forests of Exceptional Conservation Value:
Manage lands that are geologically, historically, or culturally important to protect special qualities.
Include regionally and locally sigificant attributes, socio-economic attributes, in definition of forests
of special conservation value. Provide public summary of the management program for forests of
special conservation value. The USGBC should not require that management plans be made public,

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?

All credible certification programs meet the intent of the requirements, in that they seek to protect
forest resources, wildlife, endangered species, water quality, and other important components of
the forest system, while providing the forest products the market demands. However, all programs
may need to make some modifications to comply fully with the benchmarks as they are currently
written. Making the changes outlined above would provide added clarity as to whether specific
certification programs could participate in the LEED standard.

If yes, please explain indicate which systems comply and how they are compliant.
The SFI Program has requirements that cover all of the benchmarks in Standards Substance: Forests
of special conservation value: Manage lands that are geologically, historically, or culturally
important to protect special qualities. Include regionally and locally sigificant attributes, socio-
economic attributes, in definition of forests of special conservation value. Provide public summary
of the management program for forests of special conservation value. See SFI Standard
Performance Measure 4.1, Objective 6, and Performance Measure 8.5. Ecosystem structure,
function and forest successional stages: Maintain natural ecosystem structure and function. See SFI
Objective 2 and Objective 4 Tree/snag/woody debris retention: Retention of stand-level wildlife
habitat elements (e.g. snags, nest trees, etc.) See SFI Performance Measure 4.1. and associated
Indicators. Plantations: No certification of plantations converted after 2007 unless change in
ownership or program to convert back to natural forest beginning in advance of the next harvest
cycle. For this purpose, the definition of plantations is consistent with the FAO definition. See SFI
Indicator 2.1.5 . Species diversity: Promote habitat biodiversity. See SFI Objective 4. Species at risk:

If not, please explain how the existing systems are deficient.
No certification program will conform to these benchmarks 100%, which means that some
benchmarks will need to be modified, and the threshold level for compliance needs to be defined in
order to know if a specific Standard will conform to the benchmark for Standards Substance. For
example, while many FSC Standards require compensation to aboriginal communities, a brief review
of some of the largest FSC certified companies in Canada do not show that compensation has ever
been given to aboriginal peoples by the companies. In one case it was listed as a corrective action.
Further, "free and informed consent" can be interpreted in different way as well. The in tent box
under Section 3.1 in the FSC Boreal standard states: The applicant is expected to make best efforts
to obtain a positive acceptance of the management plan. Thus, harvesting can take place even if
consent is not given. Therefore, as these benchmarks are not practically applied or implemented,
they should be modified as described above. The FSC standard has the exceptions listed under
Principle 6.10, which allows for conversion under certain circumstances: Forest conversion to
plantations or non-forest land shall not occur, except in circumstances where conversion: a) entails
a very limited portion of the Forest Management Unit; and b) does not occur on High Conservation
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Wisconsin Division of Forestry submits the following for consideration: Plantations: The LEED
position on plantations looks somewhat extreme and might go beyond even the FSC standard. The
full picture would require a look at the FAO definition of "plantation", the emphasis being on natural
forest conversion rather than plantations established on former agricultural lands. It would be
helpful to have the FAO definition included in the LEED table and for LEED to clarify that tree
planting for natural forest cover types is acceptable. Even allowance of some FAO type plantations
should be accepted if they take pressure off of natural forests. Genetically Modified Organisms
(GMOs): LEED should not include a blanket rejection of GMOs. In the US, GMO permitting is
controlled by the USDA through APHIS permitting. Currently, no GMO forest plants have been
registered by USDA, but it seems false to reject GMOs if careful USDA review were to establish an
acceptable product in the United States. FSC certainly has this requirement covered, but an
allowance for GMO forest plants should be made (as in SFI) if such a plant were approved by a
rigorous, scientific governmental review. A blanket rejection of GMOs is based on emotion, not
science or logic. Including it in LEED shows a bias in favor of FSC. Chemical Use: The LEED standard
If not, please explain how the existing systems are deficient.

American Tree Farm System operates exclusively on private, non-industrial forestland in the United
States. In the US, the legal rights of indigenous peoples have been defined by treaties, laws, and on-
going judicial review. The aboriginal land and tenure rights requirement should not be extended to
lands beyond those under the direct control of a given group of indigenous peoples.
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.


THe benchmark on plantations is too narrow. There should be provision for allowing conversion
from one forest type to another, including plantation management. To limit this is not in the best
interest of sustainable forestry as it may create disincentives for maintaining forest land in general.
There should be allowance for conversion of forest land up to a certain threshold, such as 5%-10%.
Genetically modifed organisms (GMO) should be allowed, and USGBC should not seek to limit use of
appropriately managed GMO in forest production. USGBC should use a benchmark that promotes
accepted scientific methods and following applicable laws. Building construction constantly is
upgrading to new materials, technologies, and methods. To deny the same in careful scientific
technologies seems counterproductive, counter-intuitive, political and hypocritical. Concerning
chemical use, benchmarks should promote integrated pest management approaches with allowance
for the use of registered pesticides in accordance with label requirements. Suggest that the
benchmarks should limit chemical use to the minimum necessary.
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Many of the benchmarks establish appropriate requirements. The following benchmarks are
progressive, and we are pleased to see the USGBC use them and support their continued inclusion in
the benchmark: Training: This is core not only to the success of the forest operations, but also to
include in a forest certification program. In order to ensure properly safety of forest workers, and
also proper implementation of management plans, training of workers is paramount, and we
support the inclusion of this benchmark. Research: SFM certification programs should be based on
the best available science. Technology is constantly changing, and it is necessary for certified
companies to engage in research activities to ensure they are employing the most scientifically
sound management decisions. However, some benchmarks need modification in order to provide
added benefit to the LEED Standard. These are: Forests of Exceptional Conservation Value:
Manage lands that are geologically, historically, or culturally important to protect special qualities.
Include regionally and locally sigificant attributes, socio-economic attributes, in definition of forests
of special conservation value. Provide public summary of the management program for forests of
special conservation value. The USGBC should not require that management plans be made public,
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Many of the benchmarks establish appropriate requirements. The following benchmarks are
progressive, and we are pleased to see the USGBC use them and support their continued inclusion in
the benchmark: · Training: This is core not only to the success of the forest operations, but also to
include in a forest certification program. In order to ensure properly safety of forest workers, and
also proper implementation of management plans, training of workers is paramount, and we
support the inclusion of this benchmark. · Research: SFM certification programs should be based
on the best available science. Technology is constantly changing, and it is necessary for certified
companies to engage in research activities to ensure they are employing the most scientifically
sound management decisions. However, some benchmarks need modification in order to provide
added benefit to the LEED Standard. These are: · Forests of Exceptional Conservation Value:
Manage lands that are geologically, historically, or culturally important to protect special qualities.
Include regionally and locally sigificant attributes, socio-economic attributes, in definition of forests
of special conservation value. Provide public summary of the management program for forests of
special conservation value. The USGBC should not require that management plans be made public,

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?

All credible certification programs meet the intent of the requirements, in that they seek to protect
forest resources, wildlife, endangered species, water quality, and other important components of
the forest system, while providing the forest products the market demands. However, all programs
may need to make some modifications to comply fully with the benchmarks as they are currently
written. Making the changes outlined above would provide added clarity as to whether specific
certification programs could participate in the LEED standard.

If yes, please explain indicate which systems comply and how they are compliant.
The SFI Program has requirements that cover all of the benchmarks in Standards Substance: Forests
of special conservation value: Manage lands that are geologically, historically, or culturally
important to protect special qualities. Include regionally and locally sigificant attributes, socio-
economic attributes, in definition of forests of special conservation value. Provide public summary
of the management program for forests of special conservation value. See SFI Standard
Performance Measure 4.1, Objective 6, and Performance Measure 8.5. Ecosystem structure,
function and forest successional stages: Maintain natural ecosystem structure and function. See SFI
Objective 2 and Objective 4 Tree/snag/woody debris retention: Retention of stand-level wildlife
habitat elements (e.g. snags, nest trees, etc.) See SFI Performance Measure 4.1. and associated
Indicators. Plantations: No certification of plantations converted after 2007 unless change in
ownership or program to convert back to natural forest beginning in advance of the next harvest
cycle. For this purpose, the definition of plantations is consistent with the FAO definition. See SFI
Indicator 2.1.5 . Species diversity: Promote habitat biodiversity. See SFI Objective 4. Species at risk:

If not, please explain how the existing systems are deficient.
No certification program will conform to these benchmarks 100%, which means that some
benchmarks will need to be modified, and the threshold level for compliance needs to be defined in
order to know if a specific Standard will conform to the benchmark for Standards Substance. For
example, while many FSC Standards require compensation to aboriginal communities, a brief review
of some of the largest FSC certified companies in Canada do not show that compensation has ever
been given to aboriginal peoples by the companies. In one case it was listed as a corrective action.
Further, "free and informed consent" can be interpreted in different way as well. The in tent box
under Section 3.1 in the FSC Boreal standard states: The applicant is expected to make best efforts
to obtain a positive acceptance of the management plan. Thus, harvesting can take place even if
consent is not given. Therefore, as these benchmarks are not practically applied or implemented,
they should be modified as described above. The FSC standard has the exceptions listed under
Principle 6.10, which allows for conversion under certain circumstances: Forest conversion to
plantations or non-forest land shall not occur, except in circumstances where conversion: a) entails
a very limited portion of the Forest Management Unit; and b) does not occur on High Conservation
Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
Yes, the CSA User Group members believe that CSA SFM Standard complies with the benchmarks' 7
themes of sustainable forest management

If yes, please explain indicate which systems comply and how they are compliant.
The CSA SFM standard meets the spirit and intent of the 7 themes of sustainable forest
management as detailed by the benchmarks. In order to become certified under the CSA standard
the forest manager must develop a sustainable forest management plan that identifies indictors,
objectives and targets which cover all of the benchmarks' 7 themes of sustainable forest
management. Forest management under the standard is carried out under the principles of adaptive
management and continual improvement. Each indictor is monitored and assessed over time, and
corrective actions to management practices and plans are taken as necessary. The CSA standard
requires that, in developing the forest management plan, the forest manager engage in an intensive
and balanced public participation process. Public participation is an essential part of sustainable
forest management in Canada because the public owns 95% of Canada's forests. All interested
parties are invited to provide input that will be used to develop locally adapted forest-specific
performance indicators for each of the national criteria. The CSA standard recognizes the unique
significance that Canadian forests have for Aboriginal peoples. It requires that particular efforts be
made to provide opportunities for incorporating their special knowledge into the planning process.

If not, please explain how the existing systems are deficient.
The CSA User Group believes that the CSA SFM standard is not deficient.

Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
This is an excessively detailed and prescriptive list of benchmarks and, rather than focussing on the
higher level objectives of practicing sustainable forest management, has included benchmark
elements that are at the level of indicators. Indicators are best dealt with at a regional or forest
management unit level. If USGBC intends to use these benchmarks to assess forest certification
systems that are national or international in scope then this level of detail will make the job very
difficult. Schemes should be assessed for their overall adherence to sustainable forest management
principles and for their contribution to the adaptive management and continual improvement of
forestry. Assessment at the level envisioned by some of these benchmarks would require it be done
at the forest management unit rather than the certification scheme level. Our specific comments
follow. Carbon storage: With the important role that forests play in carbon storage and climate
change, we suggest adding a benchmark that recognizes the need for understanding the net carbon
uptake in a forest area. Tree/snag/woody debris retention: This benchmark details items that are
part of ecosystem structure, which is already covered. It reads like an indicator and should be
removed. Plantations: This benchmark is unclear and confusing. We suggest it be simplified as an
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.

Improvements have been made in the USGBC's benchmarks by including elements related to
training and research. However, other areas still need some modification including: 1) Plantations -
Plantations often have a positive benefit, relieving pressure on naturally managed forests and
providing biodiversity, water quality, and wildlife benefits. Prohibiting conversion outright is
arbitrary and not a science-based conclusion. 2) Chemical Use - Chemicals are an important tool to
use in appropriate situations in forest management. USGBC's benchmark in this area is also arbitrary
and not science-based. Other areas that should be added as standards requirements include
"continued improvement" and "procurement." The SFI Program has requirements in its various
objectives, performance measures, and indicators which cover all the benchmarks included in
Standards Substance.
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
First, I would like to thank you for the opportunity to comment on the U.S. Green Building Council's
Forest Certification System Benchmark. I applaud your decision to create a rigorous standard to
which any forest management system may apply to be considered for obtaining materials credits in
the LEED program. This benchmark, while clearly the product of a great deal of research and careful
thought, does leave out one important factor: that many sustainable wood products are being
created nationwide from trees that do not come from traditional, managed, forest ecosystems.
Urban wood utilization, whereby logs from dead community trees are recovered and put to use as
lumber and other high value products, is becoming more prevalent throughout the U.S. While many
of the efforts are currently on a smaller scale, the potential resource base is enormous. The USDA
Forest Service estimates that if usable logs removed from urban areas were recovered, instead of
chipped as mulch or burned, they could supply over 25% of the nation's hardwood lumber needs
each year. Clearly, this is an effort that we should support if we are looking to improve sustainability
within our communities. While urban wood users have pursued LEED credits in recycled materials or
local products in the past, many builders and architects have overlooked this material, wanting only
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Briefly: Exotics. This is a very importnant issue. Exotics certainly need to be effectively controlled if
not eliminated entirely as appropropriate. however, many exotics pose no ecological threat, or, are
essentially benign to ecosystem health. In some cases, an exotic species may provide societal or
economic benefits that clearly outweigh any potential environmental threat. Bottomline, the
decision to identify threat level of exotics and according response should be best addressed at local
level (e.g, State or Province) in consultation with relevant resource experts and authorites. GMOs:
this language may be overly broad and capture the seedlings we have carefully improved through
multiple generations of selective breeding for traits that are deemed socially and economically
beneficial yet do not diminish the (or alter) the long-term health or regnerative capacity of the
species. Clarification is needed such that improvements to physical traits are not arbritrarily parsed.
Plantations are not necessarily out of place within natural systems. There are in fact varying degrees
of stocking manipulation and it is our firm belief that the plantations common to our area are in no
way harmful to natural forest systems. Therefore, we would like to see the proscriptive language

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
n/a

If yes, please explain indicate which systems comply and how they are compliant.
n/a

If not, please explain how the existing systems are deficient.
n/a
Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?

The NRLA is encouraged by the proposed benchmarks and believes they are a sign of movement in a
positive direction. With minor amendments to the proposed benchmarks, several additional existing
internationally recognized certification systems should meet the requirements. The NRLA would
emphasize that should these existing certification systems meet the newly created benchmarks they
should be eligible and awarded equal credit under MR 7 as FSC. The NRLA encourages the USGBC to
maintain an open dialogue with the forest products industry and work collaboritaviely to maximize
the sustainable managment of the world's forests.

If yes, please explain indicate which systems comply and how they are compliant.
No comment.

If not, please explain how the existing systems are deficient.
No comment.

Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Some benchmarks under Technical/Standards and Substance duplicate US law governing
compensation and labor. Where the existing certification systems operate within the confines of US
law, this benchmark should not be required. The NRLA would emphasize there is a lack of
consistency of the requirements of the forest products industry compared to other building
materials. Wood is held to an inequitable standard compared to products such as steel.
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
No. There are key issues addressed in this section that are strong and provide a foundation to
distinguish exemplary forest management practices. We are concerned, however, that some of the
benchmarks in this section are overly ambiguous and that others have wrongly dismissed a crucial
issue as something forest certification cannot address. Additionally, we feel that some central and
longstanding issues of forest management have been understated in the benchmarks and have been
incorrectly referenced to other sections in the benchmarks. - Certification should place limits on
conversion and maintaining "forest extent." This has been omitted from the benchmarks. -
Managing for "forests of special conservation value" is a critically important landscape concept, but
the benchmark does not specify the classification on a landscape scale. The benchmark must require
public and external expert consultation to address what may be a conflict of interest in identifying
these forests. - We do not agree that the key issue of "protected areas" is clearly addressed in other
benchmarks, as stated in the benchmark. This is founded on our understanding of the goals of
protected areas as reference areas for scientific values, reference controls for management decision-
making, or establishing safeguards for impacts of extractive forest management. - The key issues of

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
Yes. The Forest Stewardship Council (FSC).

If yes, please explain indicate which systems comply and how they are compliant.
FSC's Principles and Criteria meet requirements outlined in the benchmarks, and many more. These
are available at: http://www.fscus.org/images/documents/FSC_Principles_Criteria.pdf FSC's 10
Principles and 56 Criteria provide the international baseline of requirements that all FSC-certified
forests worldwide must meet. These Principles and Criteria may then be further elaborated at a
regional level to reflect the local ecology and social circumstances of that region. This is one of the
strengths of the FSC system, as it allows regional standards to address issues of concern to
stakeholders in specific regions. If you create one generic standard to cover different forest regions,
the requirements must be so general as to limit their ability to truly ensure forests are being
managed responsibly. For example, a forest in northern Canada and one in Southern U.S. are
completely different ecosystems and must therefore be managed differently. The following was
written in response to claims from certain quarters that FSC Canada's Boreal standard is deficient
when compared with other certification system standards. In particular, it has been pointed out by
some proponents of the SFI system that the SFI standard states that the average size of clear-cut
harvest areas should not exceed 120 acres, except to respond to forest health emergencies or other
If yes, please explain indicate which systems comply and how they are compliant.
The exisiting SFI Standard meets most/all of the proposed technical requirements (see SFI, Inc
website for a copy of the exisiting standard, pilot projects, continual imporvement and the 2010 -
2014 standard review process.
If not, please explain how the existing systems are deficient.
See above

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?

Most of the exisiting certification programs can meet all or part of the intent of the USGBC technical
requirements. However - a side by side comparison of the exisiting programs should still be made so
an "apples to apples" examination is considered for the final LEED standard.

Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.

The following benchmarks need modification to provide maximum benefit to the LEED Standard: 1)
Plantations - support certification programs that do not limit the use of commercially planted
species 2) Continual Improvement - require continual improvement, innovation and an external
audit process 3) Procurement - require the use of BMP's, trained loggers, education and outreach,
endangered species considerations & reforestation on non-certified lands
Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
NA

Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
I think that LEED should open recognition to all credible forest certification systems including FSC,
American Tree Farm, and SFI, provided that the lands have been approved by an independent third
party certification process. I also think that each of these recognized certification systems should be
open and accessible to all organizations, individuals, and landowners (both large and small
landowners).
If yes, please explain indicate which systems comply and how they are compliant.
We offer the following points for USGBC to consider: ? Many of the proposed benchmarks are very
good, objective criteria, consistent with internationally recognized assessments for determining the
quality of certification systems. ? The existing certification systems (FSC, PEFC, SFI, Tree Farm, CSA)
should be able to meet the majority of the benchmarks as currently drafted. ? USGBC needs to
define how points will be awarded and whether or not partial crediting will be incorporated into the
assessments. ? There are two notable omissions that should be included in the final set of
benchmarks: procurement and continuous improvement: ? Procurement o The way certification
systems handle the non-certified component of the supply chain should be recognized as a specific
benchmark. o In the U.S. context, where the bulk of the fiber supply originates from non-industrial
forest landowners and where less than 10% of the commercial forest land is certified, procurement
elements with standards are critical to ensure core tenants of sustainable forestry are being met
throughout the supply chain ?Continual improvement o Continual improvement drives positive
change and should be recognized as a specific benchmark. o Continual improvement is a core
element of ISO quality management and environmental management standards. o Continual
If not, please explain how the existing systems are deficient.
No comment

Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Many of the benchmarks establish appropriate requirements. However, important benchmarks such
as continual improvement and, most importantly, credit for a third party certified procurement
system standard should be added. The USGBC needs to recognize the substantial amount of product
in the supply chain that is from family forest landowners and is not expected to be certified to any
program. Responsible sourcing by certified companies should be a requirement under the LEED
program, as only 10% of the world's forests are certified to any system. The USGBC should include a
benchmark mimics the SFI Procurement Standard. This ensures program participants take measures
to ensure the fiber was harvested legally, meet state, provincial and federal laws regarding
threatened and endangered species, encourage landowners to incorporate actions that identify and
protect or create habitat for wildlife, encourage landowners to reforest harvested lands, both
naturally and through replanting, encourage landowners to protect riparian zones and water quality,
implement a verifiable monitoring system to continually improve the effectiveness of encouraging
landowners to reforest harvested areas and apply best management practices to protect water
quality, encourage landowners to use loggers and resource professionals trained in sustainable

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?

There are many different forest certification systems around the world, each with a slightly different
focus. Each system has unique strengths due the range of national land ownership patterns and
governmental structures. Georgia-Pacific acknowledges all of the recognized forest certification
organizations including systems which recognize and certify procurement practices. We view
competition among these organizations as vital to continually improving the practice of sustainable
forestry on all lands, but not all programs are applicable or relevant for all landowners and every
region of the world.
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Plantations: Missouri Forest Products Association feels this benchmark is too closely aligned with
the FSC program and should be modified to avoid system bias. All certification systems allow
conversions to occur-this needs to be recognized by USGBC For clarity, USGBC should use the
accepted FAO definition. Genetically-modified organisms (GMOs): Missouri Forest Products
Association recommends that USGBC consider a neutral position in their criteria. Well-studied
applications of appropriate biotechnology methods for forest tree improvement have the potential
to enhance the quality, productivity, and value of plantation forests for managed wood, pulp,
bioenergy; protect tree species from serious insect and disease problems; and provide other social,
economic and environmental benefits. Chemical Use: This benchmark is too closely aligned with the
FSC program and should be modified to avoid system bias. A prescriptive benchmark rather than the
current proscriptive approach would be better. The benchmark would include support for integrated
pest management, use of least toxic chemicals necessary to achieve management objectives, use of
registered pesticides in accordance with label requirements, and compliance with applicable state
and federal regulations. Aboriginal land and tenure rights: This benchmark is not applicable to all

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
The existing certification systems (FSC, PEFC, SFI, Tree Farm, CSA) should be able to meet the
majority of the benchmarks as drafted.
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Mr. Rick Fedrizzi, President & CEO U.S. Green Building Council 1800 Massachusetts Avenue, NW
Washington, DC 20036 Dear Mr. Fedrizzi: On behalf of ArborGen, LLC, I would like to take this
opportunity to thank you and the Materials and Resources Technical Advisory Group for allowing
public comment on the various LEED rating systems, beginning with the proposed changes put
forward in May on LEED v3 and LEED 2009. We support the use of Life Cycle Analysis and life cycle
credits and believe that incorporating these systems into LEED 2009 is a positive advance in green
building. As one of the principle growers of traditional tree seedstock and tree seedlings in the
world, and the global leader in tree biotechnology, ArborGen supports the proposed credit revision
for certified wood (MR7) and views your consideration as a forward step in gaining global
acceptance within LEED of environmentally friendly and sustainably managed wood products.
Though it is clear that the new benchmark system has made great strides in creating a credit
requirement that uses system-neutral phrasing, it is equally clear that FSC certification standards
have heavily influenced the draft. We respectfully request that you consider the following
comments in support of a fair and informed evaluation of third-party certification systems in North

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
Mr. Rick Fedrizzi, President & CEO U.S. Green Building Council 1800 Massachusetts Avenue, NW
Washington, DC 20036 Dear Mr. Fedrizzi: On behalf of ArborGen, LLC, I would like to take this
opportunity to thank you and the Materials and Resources Technical Advisory Group for allowing
public comment on the various LEED rating systems, beginning with the proposed changes put
forward in May on LEED v3 and LEED 2009. We support the use of Life Cycle Analysis and life cycle
credits and believe that incorporating these systems into LEED 2009 is a positive advance in green
building. As one of the principle growers of traditional tree seedstock and tree seedlings in the
world, and the global leader in tree biotechnology, ArborGen supports the proposed credit revision
for certified wood (MR7) and views your consideration as a forward step in gaining global
acceptance within LEED of environmentally friendly and sustainably managed wood products.
Though it is clear that the new benchmark system has made great strides in creating a credit
requirement that uses system-neutral phrasing, it is equally clear that FSC certification standards
have heavily influenced the draft. We respectfully request that you consider the following
comments in support of a fair and informed evaluation of third-party certification systems in North

If yes, please explain indicate which systems comply and how they are compliant.
Mr. Rick Fedrizzi, President & CEO U.S. Green Building Council 1800 Massachusetts Avenue, NW
Washington, DC 20036 Dear Mr. Fedrizzi: On behalf of ArborGen, LLC, I would like to take this
opportunity to thank you and the Materials and Resources Technical Advisory Group for allowing
public comment on the various LEED rating systems, beginning with the proposed changes put
forward in May on LEED v3 and LEED 2009. We support the use of Life Cycle Analysis and life cycle
credits and believe that incorporating these systems into LEED 2009 is a positive advance in green
building. As one of the principle growers of traditional tree seedstock and tree seedlings in the
world, and the global leader in tree biotechnology, ArborGen supports the proposed credit revision
for certified wood (MR7) and views your consideration as a forward step in gaining global
acceptance within LEED of environmentally friendly and sustainably managed wood products.
Though it is clear that the new benchmark system has made great strides in creating a credit
requirement that uses system-neutral phrasing, it is equally clear that FSC certification standards
have heavily influenced the draft. We respectfully request that you consider the following
comments in support of a fair and informed evaluation of third-party certification systems in North

If not, please explain how the existing systems are deficient.
Mr. Rick Fedrizzi, President & CEO U.S. Green Building Council 1800 Massachusetts Avenue, NW
Washington, DC 20036 Dear Mr. Fedrizzi: On behalf of ArborGen, LLC, I would like to take this
opportunity to thank you and the Materials and Resources Technical Advisory Group for allowing
public comment on the various LEED rating systems, beginning with the proposed changes put
forward in May on LEED v3 and LEED 2009. We support the use of Life Cycle Analysis and life cycle
credits and believe that incorporating these systems into LEED 2009 is a positive advance in green
building. As one of the principle growers of traditional tree seedstock and tree seedlings in the
world, and the global leader in tree biotechnology, ArborGen supports the proposed credit revision
for certified wood (MR7) and views your consideration as a forward step in gaining global
acceptance within LEED of environmentally friendly and sustainably managed wood products.
Though it is clear that the new benchmark system has made great strides in creating a credit
requirement that uses system-neutral phrasing, it is equally clear that FSC certification standards
have heavily influenced the draft. We respectfully request that you consider the following
comments in support of a fair and informed evaluation of third-party certification systems in North
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Standards: Some of the benchmarks are reasonable and useful in assessing certification systems,
but others are so vague that they cannot be used for the purpose of evaluating systems. In addition,
many critical areas are not addressed with specific benchmarks, and the language in the documents
says that "other benchmarks. address this issue", but they do not. This includes such key issues as
Protected areas, Old-growth, Forest restoration, etc. All of these issues should be reconsidered
and specific benchmarks proposed. For Protected areas, standards should require that
representative samples of protected areas within an ownership be protected, particularly for mid-
and large-sized operations. On highly degraded lands, certification systems should require a certain
amount of Forest restoration. Old-growth is sufficiently rare and under-represented in the U.S., and
most experts would agree that specific conservation elements should be included in certification
standards. In addition, some criteria are so vague to be almost meaningless - they are not
benchmarks at all. These include Ecosystem Structure and Function - maintain natural ecosystem
structure and function. How would this be used to assess certification standards? Another
important issue is that landscape scale issues are not addressed adequately. The first is the
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Forests of Exceptional Conservation Value: There should not be a requirement to make
management plans public due to potential antitrust implications. Instead, require audit reports be
made public and easily obtainable. The certification public summary audit reports clearly state areas
of conformance and non conformance, which would include any information on the management
plan as needed. If a public summary of the management plan is required, it must not include any
proprietary information on harvesting techniques, rotation lengths, etc. Plantations: All certification
programs must deal with plantations, whether established or new. Plantations can have a positive
benefit. Prohibiting conversion is not practical given that all certification programs deal with new
and established plantations alike. This benchmark as written is arbitrary and not science based.
Instead, support the certification programs that limit the use of exotics in plantations, and that also
ensure the same requirements for natural forest management exists for planted stands as well.
GMO's: There are no commercially grown GMO's in North America. However, research is important
to the future of the world's forests. Therefore GMO's should not be banned based on the
requirements of one program because research involving biotechnology has the potential to restore
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Forests of Exceptional Conservation Value: There should not be a requirement to make
management plans public due to potential antitrust implications. Instead, require audit reports be
made public and easily obtainable. The certification public summary audit reports clearly state areas
of conformance and non conformance, which would include any information on the management
plan as needed. If a public summary of the management plan is required, it must not include any
proprietary information on harvesting techniques, rotation lengths, etc. Plantations: All certification
programs must deal with plantations, whether established or new. Plantations can have a positive
benefit. Prohibiting conversion is not practical given that all certification programs deal with new
and established plantations alike. This benchmark as written is arbitrary and not science based.
Instead, support the certification programs that limit the use of exotics in plantations, and that also
ensure the same requirements for natural forest management exists for planted stands as well.
GMO's: There are no commercially grown GMO's in North America. However, research is important
to the future of the world's forests. Therefore GMO's should not be banned based on the
requirements of one program because research involving biotechnology has the potential to restore

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
The SFI Program complies with the benchmarks.

If yes, please explain indicate which systems comply and how they are compliant.

The SFI Program has a fully independent certification body accreditation program. Accreditation
programs are overseen by IAF members. Further, there are specific accreditation programs for the
2005-2009 SFI Standard and for the SFI chain-of-custody and labeling standard, which comply with
their respective ISO guides. Accredited certification bodies are witnessed annually by the
accreditation body. The SFI certification process can only be completed by an accredited
certification body, which is an independent third party. The certification process requires field and
desk audits, consultation with stakeholders, and a public summary report is available on the SFI
website. Certification must be maintained with annual surveillance audits and re-certification every
5 years. The SFI Program has an open and transparent dispute resolution process that is overseen by
the accreditation bodies.

If not, please explain how the existing systems are deficient.

The FSC program is deficient in the following areas: Certification Body Accreditation: According to
an ITTO report from October 2007: FSC was not fully compying with the ISO 17011 as the same
organization had responsibility for the setting of standards and the accreditation of certification
bodies. The problem was partially addressed through the separation of the standard and
accreditation service functions by creation of a new subsidiary company, ASI-Accreditation Services
International GmbH. Accreditation decisions are still made by the FSC Board of Directors upon the
recommendation of ASI which has carried out the evaluation on applicant certification bodies.
Dispute Resolution Process: The FSC program does not maintain an open and transparent dispute
resolution process. Only FSC members can file a dispute, and they must pay for it themselves. FSC
does not have an established process for handling disputes, only a interim document, dated April
1998.
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
LEED should recognize all credible forest certification systems (i.e. FSC, SFI, Tree Farm, etc) where
land has been subject to an independent third party certification

If not, please explain how the existing systems are deficient.
All organizations, landowners, and landowner groups should have access to all recognized
certification systems.
If not, please explain how the existing systems are deficient.
All PEFC

If yes, please explain indicate which systems comply and how they are compliant.
FSC

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
Only FSC

Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.

Decline to answer in depth until benchmarks and clear process for their use are defined. Please look
at comments provided under #1 in governance, which are all inclusive.
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Forests of Exceptional Conservation Value: There should not be a requirement to make
management plans public due to potential antitrust implications. Instead, require audit reports be
made public and easily obtainable. The certification public summary audit reports clearly state areas
of conformance and non conformance, which would include any information on the management
plan as needed. If a public summary of the management plan is required, it must not include any
proprietary information on harvesting techniques, rotation lengths, etc. Plantations: All certification
programs must deal with plantations, whether established or new. Plantations can have a positive
benefit. Prohibiting conversion is not practical given that all certification programs deal with new
and established plantations alike. This benchmark as written is arbitrary and not science based.
Instead, support the certification programs that limit the use of exotics in plantations, and that also
ensure the same requirements for natural forest management exists for planted stands as well.
GMO's: There are no commercially grown GMO's in North America. However, research is important
to the future of the world's forests. Therefore GMO's should not be banned based on the
requirements of one program because research involving biotechnology has the potential to restore
Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
Again, Oregon SIC only has expertise with the SFI standard. SFI meets the intent of the
requirements, in that they seek to protect forest resources, wildlife, endangered species, water
quality, and other important components of the forest system, while providing the forest products
the market demands. However, it is not clear if SFI would have to make some modifications to
comply fully with the benchmarks as they are currently written. Incorporating the suggestions above
and those made by SFI Inc. should provide added clarity as to whether SFI ( and other certification
programs) could participate in the LEED standard. Oregon SIC suggests that USGBC study the
requirements of the SFI standard and familiarize themselves with the implementation of SFI across
North America. Many of the pieces of SFI specifically address the issues inherent in the proposed
USGBC benchmarks, including protection of habitats, riparian protection, ecosystem function, etc.

If yes, please explain indicate which systems comply and how they are compliant.


Again, Oregon SIC only has expertise with the SFI standard. SFI meets the intent of the
requirements, in that they seek to protect forest resources, wildlife, endangered species, water
quality, and other important components of the forest system, while providing the forest products
the market demands. However, it is not clear if SFI would have to make some modifications to
comply fully with the benchmarks as they are currently written. Incorporating the suggestions above
and those made by SFI Inc. should provide added clarity as to whether SFI ( and other certification
programs) could participate in the LEED standard. Oregon SIC suggests that USGBC study the
requirements of the SFI standard and familiarize themselves with the implementation of SFI across
North America. Many of the pieces of SFI specifically address the issues inherent in the proposed
USGBC benchmarks, including protection of habitats, riparian protection, ecosystem function, etc.

If not, please explain how the existing systems are deficient.
It is not clear if a standard would have to pass with a score of 100%. If not, are some benchmarks
"must pass" while others are not? If that is true, how many of them can a standard miss? Who
decides that ratio? This needs to be made clear.

Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Many of the benchmarks establish appropriate requirements and appear to be very consistent with
the details found within the SFI standard. However, some benchmarks need modification in order to
provide added benefit to the LEED Standard. These are: Plantations: No certification of plantations
converted after 2007 unless change in ownership or program to convert back to natural forest
beginning in advance of the next harvest cycle. For this purpose, the definition of plantations is
consistent with the FAO definition. The intent of this benchmark is unclear. Vast acreages of planted
stands exist in Oregon, reforested as required by law with appropriate species. Are these stands
plantations or natural forests? The word conversion is confusing as well. Conversion in the Oregon
context means a change of land use, usually to development. Certification would not be an issue in
this context. GMO's: Prohibit the use of genetically modified organisms. It seems shortsighted to
ban the use of GMO's. Oregon SIC supports strong, thorough research on any new application of
technology, but sees diseases such as Sudden Oak Death as capable of eliminating entire forest
ecosystems. If a solution exists to fight the spread of that disease, Oregon SIC believes it should be
fully researched. Chemical Use: Prefer natural methods, such as integrated pest management, to
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
In my opinion as a consulting forester who manages both small and large ownerships, I think there
should be LEED recognition for established, credible certification systems, such as the Sustainable
Forest Initiative (SFI) and the American Tree Farm System.
Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
Yes.

Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Specific benchmarks related to genetically modified organisms (GMOs), plantations, chemical use,
forests of special conservation value, aboriginal land and tenure rights, and special aboriginal sites
should be determined by multi-stakeholder experts associated with each certification system. We
concur with the Management Plan Benchmark, but suggest public summaries of these plans should
not be required. Publicly posting summaries raises serious concerns related to private information
and will subject USGBC to legal risk. Federal and state land management agencies are currently
subject to a number of environmental laws and regulations which require extensive public
consultation beyond that required by private forest landowners. Additional requirements beyond
what is currently required are not necessary. The USGBC should recognize continual improvement
as an important aspect of updating the LEED standard and promoting "adaptive forest
management" based on past experiences, new knowledge or the latest research. With
approximately 10% of the world's forests certified to any certification system, the USGBC will need
to include benchmarks promoting management for sustainable forests on those ownerships
currently not certified. These benchmarks should address the use of trained loggers, best

If not, please explain how the existing systems are deficient.
N/A

If yes, please explain indicate which systems comply and how they are compliant.
Credible programs such as SFI, FSC and ATFS. Although in different manners, each addresses most of
the benchmarks outlined in the Standards Substance.
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.

I support open LEED recognition to all credible forest certification systems (SFI, American Tree Farm,
FSC). Provided there has been an independent third party certification process

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
No comment

If yes, please explain indicate which systems comply and how they are compliant.
No comment

If not, please explain how the existing systems are deficient.

Each recognized certification system should be open to all landowners (organization or individual).
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
No. The benchmarks are written exclusively for commodity forests and ignore the significant
potential benefits of harvesting timber from urban and community forests. The Morton Arboretum
is leading efforts in northeastern Illinois to develop markets and networks necessary to reclaim
potentially valuable wood products from community landscape trees as they are removed in the
course of good urban forest management. The impending crisis that will result from the emerald ash
borer, predicted to kill 20% of the urban forest, necessitates aggressive and creative action. As a
member of the Illinois Governor's Emerald Ash Borer Science & Management Advisory Panel, and
Wood Utilization Team, I hope for inclusion of urban wood in benchmarks developed by USGBC. I
am pleased with the effort undertaken by USGBC to evaluate the important wood component of
LEED certification, but I am requesting revisions to include the unique objectives and potential of
the urban forest. The US Forest Service has estimated that more than 25% of the nation's annual
hardwood needs could be met if all the trees normally removed from the urban forest and currently
treated as waste, were reclaimed. These trees, over the course of decades, give continual
environmental, health, aesthetic, and energy conservation benefits. The US Forest Service also

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
Urban forests are currently certified by the National Arbor Day Foundation. The most common and
recognizable program, Tree City USA, awards annual certificates to municipalities for sound
community tree management. The Growth Award, provides Tree City USA communities an
opportunity to be recognized for continual improvements in community forest management
including wood reclamation. There are complementary programs for campuses, utility rights-of-way
and military lands. However, the Tree City USA program currently does not address urban timber
harvesting in a significant way and therefore would not meet the benchmarks for USGBC
benchmarks.

If yes, please explain indicate which systems comply and how they are compliant.
.

If not, please explain how the existing systems are deficient.

Tree City USA could become the certifier of urban forests inclusive of urban timber harvesting.
However, proposed benchmarks of 'Landscape, Ecosystem Diversity, Natural Disturbance,
Indigenous Rights, Forest Operation, do not translate to an urban forest that is managed for
maximum benefits to community residents. This is due to the primary nature of the land use and
forest management objective. Plantations, skid roads, and indigenous ownership for example, do
not exist in the urban forest. In other areas, such as Forest Restoration, Environmental Services,
Public Consultation, Community Benefit, and Exotics, urban forest goals, management, and
mensuration exceed those typical of traditional forestry. Specifically, for example, many
communities have local ordinances requiring replacement planting of any tree removed, often at
rates as high as three trees planted for every one removed. Community involvement may be as high
as a statutory citizen tree board or commission setting urban forest management policy.
Benchmarking in the Standard Substance section must be flexible enough to accommodate the
urban forest resource.
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.

As I read the requirements they seem ambiguous and less than clear. My impression is that the new
language will tend to allow less stringent certification systems (like SFI) to be given the same
recognition as more stringent systems (like FSC). If this happens I believe it will lower the standard
for LEED certification and cheapen the achievement of that standard. Is the goal to make it easier to
attain LEED certification or improve the integrity and cache' associated with it?

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
Due to the ambiguity of the proposed standard I believe users could construe most certification
systems to qualify.

If yes, please explain indicate which systems comply and how they are compliant.
FSC, SFI, ASWA, etc. The standards as proposed do not eliminate any of the certification systems as I
know them. In some cases the system has significant ambiguity as part of its' standards. Couple that
with the ambiguity of the propose USGBC standard and you have a recipe for misuse of the
certification.
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
We believe the standards should allow for the use of wood from urban trees.

If not, please explain how the existing systems are deficient.
Allowing for the use of wood from urban trees.
If not, please explain how the existing systems are deficient.
Not applicable.

If yes, please explain indicate which systems comply and how they are compliant.
ATFS, FSC, and SFI all comply with the reasonable benchmarks.

Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
By and large, yes. However, as a forester who works with private landonwers in the southeastern
US, I believe there is a significant problem with the "Plantation" key issue. Part of this problem is the
FAO definition of a plantation. FAO considers a forest plantation either 1) planted with introduced
species, or 2) planted with indigenous species of 1 or 2 species, even aged, and regularly spaced.
Most southeastern plantations fall into the latter category. Many upland coastal plain forests
present when Europeans first arrived in the southeastern US would have been considered
plantations under this definition as they had a) few species, b) were even aged, and c) were
regularly spaced. Just read "Travels of William Bartram," as Bartram traveled extensively across the
southeastrn US in the late 1700's and documented much of what he saw. The problem is not
plantations, but how they are managed. From my experience, I know that plantations can be
productive forests for forest products, wildlife, biodiversity, and other benefits we derive from
forestland. The exclusionary language that is proposed results in a profound inequity for many
private forest landowners, most of whom have small tracts but a very strong land ethic; they have
managed their forests sustainably for decades and are now excluded from benefiting from their

Do any of the existing systems comply with the Technical/Standards Substance requirements as
established in the USGBC benchmarks?
Yes, except for the significant problem noted above.
Do the proposed USGBC benchmarks relating to forest certification system Technical/Standards
Substance establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
I believe it is very important that LEED open recognition to all credible, scientifically valid forest
certification systems. This would include FSC, SFI, and American Tree Farm System, and others,
where the property and its management has undergone an independent third party certification
process. In addition, each of the certification systems recognized by LEED must be open and
accessible to all organizations, individuals, and landowners in order to encompass the broadest
possible base.
If not, please explain how the existing systems are deficient.

As I understand the current system, only a single forest certification system (FSC) is recognized.
While FSC has led the way in public understanding of the need for forest certification, it is only one
of several certification systems which effectively ensure sound, responsible forest management. I
believe it is very important that LEED open recognition to all credible, scientifically valid forest
certification systems. This would include FSC, SFI, and American Tree Farm System, and others,
where the property and its management has undergone an independent third party certification
process. In addition, each of the certification systems recognized by LEED must be open and
accessible to all organizations, individuals, and landowners in order to encompass the broadest
possible base.
USGBC Responses
Thank you for your comments. The responses to your main points are as follows:
1. Regarding the GMO benchmark, it is not Required but – if achieved – allows for a certification
scheme to exemplify itself from others.
2. Regarding the Chemical use benchmark, USGBC is confident in its prescriptiveness and believes it
sets a rigorous standard.
3. The Labor benchmarks are now Required benchmarks, stipulating that a scheme require
compliance with local labor laws.




Thank you for your comments. To clarify, the USGBC benchmarks are not setting standards for the
certification of particular forest types. Instead, they set standards for the certification schemes
themselves in order for one or more schemes to be recognized in the LEED rating systems. The
Governance section includes a Distinguishing benchmark "Accessibility to diverse ownership types,"
in which its "standards and procedures allow small-scale and/or low intensity operators equitable
access to markets for certified forest products, and/or schemes have developed policies or other
measures to improve small producer market access."

Additionally, wood from urban sources is eligible for a credit under the Regional Materials credit,
and project teams are who use wood sourced from the project site are encouraged to apply for an
Innovation in Design credit.
Thank you for your comments. The responses to your main points are as follows:
1. The revised Plantations benchmark now includes certain exceptions.
2. USGBC is currently determining its larger stance on the use of GMOs. Until finalized, this will be a
Distinguishing benchmark through which a certification scheme can exemplify itself from other.
3. USGBC agrees with the need for continuous improvement but believes that the content of the
Management Plan and Monitoring Required benchmarks ensures this quality is found in any LEED-
recognized certification scheme.




Thank you for your comments and support of the draft benchmarks.




Thank you for your comments. The responses to your main points are as follows:
1. Some of the previously absent benchmarks now include requirements, while others that continue
to lack benchmarks have remained with the knowledge that their topics are covered by the
requirements in other benchmarks.
2. Each of the vague benchmarks you mention have been elaborated upon to varying extent.
Nonetheless, while USGBC strongly desires for the Forest Certification Scheme Benchmarks to
establish clear, understandable requirements, it also understands that the contextual nature of
forestry requires some interpretation of the requirements against a scheme’s actual standards. As
such, USGBC strongly believes that the Forest Certification Benchmarks are not comparable to LEED
credits. Metric-setting for buildings cannot occur to the same extent as in forestry. Please see the
Thank you for your comments. The responses to your main points are as follows:
1. Some of the previously absent benchmarks now include requirements, while others that continue
to lack benchmarks have remained with the knowledge that their topics are covered by the
requirements in other benchmarks.
2. Each of the vague benchmarks you mention have been elaborated upon to varying extent.
Nonetheless, while USGBC strongly desires for the Forest Certification Scheme Benchmarks to
establish clear, understandable requirements, it also understands that the contextual nature of
forestry requires some interpretation of the requirements against a scheme’s actual standards. As
such, USGBC strongly believes that the Forest Certification Benchmarks are not comparable to LEED
credits. Metric-setting for buildings cannot occur to the same extent as in forestry. Please see the
accompany Conformance Assessment Process document to learn how a third-party evaluation will
determine compliant schemes in a transparent and unbiased manner.
3. USGBC has respectfully elected to maintain the requirements of the Funding and Verification of
Acceptable Sources benchmarks.




Thank you for your comments. The responses to your main points are as follows:
1. USGBC strongly desires for the Forest Certification Scheme Benchmarks to establish clear,
understandable requirements, it also understands that the contextual nature of forestry requires
some interpretation of the requirements against a scheme’s actual standards.
2. The Required benchmarks in the revised document have higher weight than the Distinguishing
benchmarks. All of the revised benchmarks are of equal weight within the Required and
Distinguishing categories.
3. Please see the accompanying draft Conformance Assessment to learn how USGBC intends to
evaluate the forest certification schemes against the finalized benchmarks.
4. The Plantations benchmark prohibits “the certification of plantations that were converted from
natural forest after 2009 unless the current owner is not responsible for their conversion.” This
stringency is coupled with a collection of exceptions.
5. USGBC strongly believes that the Forest Certification Benchmarks cannot contain specific metrics
to same extent as LEED. USGBC understands that forestry is very contextual and allows the
proposed Conformance Assessment Team to determine a scheme’s compliance with a benchmark
given its context.




Thank you for your comments. USGBC hopes that the clarified and elaborated benchmarks address
all of your concerns about benchmark vagueness and inadequacy.
Thank you for your comments. USGBC hopes that the clarified and elaborated benchmarks address
all of your concerns about benchmark vagueness and inadequacy.




Thank you for your comments. The responses to your main points are as follows:
1. The revised Plantations benchmark now defines plantations according to FAO’s 2005 definition.
And, USGBC does not intend for any benchmark to be biased towards a particular forest certification
scheme. Instead, USGBC intends for the benchmarks collectively present the organization's
definition of exemplary forest certification in all aspects of a certification scheme, independent of
any one scheme's previously established guidelines.
2. In this collection of revisions, the GMO benchmark is not required, but is instead a Distinguishing
benchmark for which a certification scheme can distinguish itself from other schemes.
3. The revised Chemical Use benchmark largely conforms with your suggested revisions.
4. The Labor benchmarks are now Required benchmarks, stipulating that a scheme require
compliance with local labor laws. Some other Social benchmarks, however, are Distinguishing,
because USGBC recognizes that the requirements of those benchmarks surpass some North
American laws. As such, a scheme can earn one to exemplify itself from the others.
5. USGBC agrees with the need for continuous improvement but believes that the content of the
Management Plan and Monitoring Required benchmarks ensures this quality is found in any LEED-
recognized certification scheme.
6. The revised Plantations benchmark now includes certain exceptions.
recognized certification scheme.
6. The revised Plantations benchmark now includes certain exceptions.




Thank you for your comments and your extensive recommendations. USGBC hopes that the
revisions address some of your concerns about inconsistency, vagueness, and/or lack of rigor. The
revisions are intended to clarify and elaborate on the benchmarks, all the while finding a balance
between the valid concerns of the expert commenters and the central values and objectives of
USGBC.




Thank you for your comments. To clarify, the USGBC benchmarks are not setting standards for the
certification of particular forest types. Instead, they set standards for the certification schemes
themselves in order for one or more schemes to be recognized. When establishing required and
preferred criteria, USGBC must include the elements already found in forest certification schemes.
Social and labor issues are addressed by all to varying degrees.




Thank you for your comments. USGBC has read and carefully considered the comments submitted
by the Cascadia Region Green Building Council.


Thank you for your comments. USGBC hopes that the clarified and elaborated benchmarks address
all of your concerns about benchmark vagueness and inadequacy.
Thank you for your comments. USGBC hopes that the clarified and elaborated benchmarks address
all of your concerns about benchmark vagueness and inadequacy.




Thank you for your comments. USGBC has read and carefully considered the comments submitted
by the organizations you mention. And, to clarify, USGBC has not yet determined whether
additional certification schemes will be recognized in LEED. The proposed Forest Certification
Scheme Benchmarks are meant to transparently indicate what USGBC expects from exemplary
certification schemes if they are to be recognized in LEED. You're invited to review the
accompanying Conformance Assessment Process to learn how USGBC will evaluate the schemes
against the finalized benchmarks.




Thank you for your comments and your extensive recommendations. USGBC hopes that the
revisions address some of your concerns about inconsistency, vagueness, and/or lack of rigor. The
revisions are intended to 1) clarify and elaborate on the benchmarks and 2) find a balance between
the valid concerns of the expert commenters and the central values and objectives of USGBC.
Thank you for your comments and your extensive recommendations. USGBC hopes that the
revisions address some of your concerns about inconsistency, vagueness, and/or lack of rigor. The
revisions are intended to 1) clarify and elaborate on the benchmarks and 2) find a balance between
the valid concerns of the expert commenters and the central values and objectives of USGBC.




Thank you for your comments. The responses to your main points are as follows:
1. The revised Plantations benchmark provides for some exceptions and references a 2005 FAO
definition of plantations.
2. Regarding the GMO benchmark, it is not Required but – if achieved – allows for a certification
scheme to exemplify itself from others.
3. Regarding the Chemical use benchmark, USGBC is confident in its prescriptiveness and believes it
sets a rigorous standard.
4. The Labor benchmarks are now Required benchmarks, stipulating that a scheme require
compliance with local labor laws.
Thank you for your comments. The responses to your main points are as follows:
1. The revised Plantations benchmark provides for some exceptions and references a 2005 FAO
definition of plantations.
2. Regarding the GMO benchmark, it is not Required but – if achieved – allows for a certification
scheme to exemplify itself from others.
3. Regarding the Chemical use benchmark, USGBC is confident in its prescriptiveness and believes it
sets a rigorous standard.
4. The Labor benchmarks are now Required benchmarks, stipulating that a scheme require
compliance with local labor laws.




Thank you for your comments and your extensive recommendations. USGBC hopes that the
revisions address some of your concerns about inconsistency, vagueness, and/or lack of rigor. The
revisions are intended to 1) clarify and elaborate on the benchmarks and 2) find a balance between
the valid concerns of the expert commenters and the central values and objectives of USGBC.




Thank you for your comments. The responses to your main points are as follows:
1. The revised Plantations benchmark provides for some exceptions and references a 2005 FAO
definition of plantations.
2. Regarding the GMO benchmark, it is not Required but – if achieved – allows for a certification
scheme to exemplify itself from others.
3. Regarding the Chemical use benchmark, USGBC is confident in its prescriptiveness and believes it
sets a rigorous standard.
4. The Labor benchmarks are now Required benchmarks, stipulating that a scheme require
compliance with local labor laws.
Thank you for your comments. The responses to your main points are as follows:
1. The revised Plantations benchmark provides for some exceptions and references a 2005 FAO
definition of plantations.
2. Regarding the GMO benchmark, it is not Required but – if achieved – allows for a certification
scheme to exemplify itself from others.
3. Regarding the Chemical use benchmark, USGBC is confident in its prescriptiveness and believes it
sets a rigorous standard.
4. The Labor benchmarks are now Required benchmarks, stipulating that a scheme require
compliance with local labor laws.




Thank you for your comments.
1. USGBC hopes that the revisions address some of your concerns about inconsistency, vagueness,
and/or lack of rigor. The revisions are intended to 1) clarify and elaborate on the benchmarks and 2)
find a balance between the valid concerns of the expert commenters and the central values and
objectives of USGBC. The revised benchmarks, whether Required or Distinguishing, collectively
present USGBC's definition of exemplary forest certification and its high standards to earn
recognition in LEED.
2. USGBC recognizes that there is not an explicit path for project teams to earn credit for sourcing
their materials from small-scale producers or farmers. As such, it is recommended that project
teams seek a point in the Innovation and Design credit category, explicitly noting how the strategy is
comprehensive, quantifiable, and applicable to other projects. The Governance section of the
benchmarks includes a Distinguishing benchmark "Accessibility to diverse ownership types," in
which its "standards and procedures allow small-scale and/or low intensity operators equitable
access to markets for certified forest products, and/or schemes have developed policies or other
measures to improve small producer market access."
Thank you for your comments. USGBC believes that the finalized Forest Certification System
Benchmarks, in combination with a third-party evaluation, will ensure that the described scenario
will be identified.




Thank you for your comments. Rest assured that USGBC does not intend to decrease the rigor of
the Certified Wood credits. The proposed changes and accompanying Forest Certification Scheme
Benchmarks are meant to increase the transparency by which USGBC chooses one or more scheme
for recognition in those credits. The stringency of the benchmarks ensures that wood used to earn a
point in the credit will continue to come from exemplary forest management practices.




Thank you for your comments. To clarify, the benchmarks on which you commented will be used to
determine which scheme or schemes gain recognition in LEED. This evaluation will then be
incorporated into the proposed changes to the Certified Wood credits. And recycled/salvaged
sources may only count towards achievement of the following credits in the building design and
construction rating systems: MRc3: Materials Reuse and MRc4: Recycled Content.


Thank you for your comments. USGBC agrees that any revision to LEED credits should motivate
market transformation and should advance more sustainable practices. As such, the proposed
changes to the Certified Wood credits are intended to motivate change, in this instance the forest
certification market. The USGBC benchmarks are intended to be an objective and transparent
collection of standards against which forest certification schemes will be evaluated to determine
Thank you for your comments. USGBC agrees that any revision to LEED credits should motivate
market transformation and should advance more sustainable practices. As such, the proposed
changes to the Certified Wood credits are intended to motivate change, in this instance the forest
certification market. The USGBC benchmarks are intended to be an objective and transparent
collection of standards against which forest certification schemes will be evaluated to determine
which meet USGBC's level of rigor and then gain recognition in LEED.

Regarding the verification process, please see the accompanying draft Conformance Assessment to
learn how USGBC intends to evaluate the forest certification schemes against the finalized
benchmarks.




Thank you for your comments. To clarify, USGBC has not yet determined whether additional
certification schemes will be recognized in LEED. The proposed Forest Certification Scheme
Benchmarks are meant to transparently indicate what USGBC expects from exemplary certification
schemes if they are to be recognized in LEED. You're invited to review the accompanying
Conformance Assessment Process to learn how USGBC will evaluate the schemes against the
finalized benchmarks.




Thank you for your comments. The Forest Certification Scheme Benchmarks posted for this 2nd
Public Comment Period are revised to be clearer, better aligned with USGBC's Guiding Principles,
and more consistently present stringent requirements. Additionally, the benchmarks are meant to
increase the transparency by which USGBC chooses one or more scheme for recognition in those
credits. The rigor of the benchmarks ensures that wood used to earn a point in the credit will
continue to come from exemplary forest management practices.
Thank you for your comments. The Forest Certification Scheme Benchmarks posted for this 2nd
Public Comment Period are revised to be clearer, better aligned with USGBC's Guiding Principles,
and more consistently present stringent requirements. Additionally, the benchmarks are meant to
increase the transparency by which USGBC chooses one or more scheme for recognition in those
credits. The rigor of the benchmarks ensures that wood used to earn a point in the credit will
continue to come from exemplary forest management practices.




Thank you for your comments. The responses to your main points are as follows:
1. USGBC does not intend for any benchmark to be biased towards a particular forest certification
scheme. Instead, USGBC intends for the benchmarks collectively present the organization's
definition of exemplary forest certification in all aspects of a certification scheme, independent of
any one scheme's previously established guidelines.
2. The revised Plantations benchmark now includes certain exceptions.
3. USGBC agrees with the need for continuous improvement but believes that the content of the
Management Plan and Monitoring Required benchmarks ensures this quality is found in any LEED-
recognized certification scheme.
Thank you for your comments. The responses to your main points are as follows:
1. The benchmarks are prescriptive to articulate USGBC’s precise expectations for a particular issue.
The conformance assessment process, however, will consider how each certification scheme meets
the benchmarks’ requirements, recognizing and appreciating that schemes can meet requirements
in new and unique ways.
2. The revised benchmarks include an overall new structure: Required and Distinguishing
benchmarks. To gain recognition in LEED, a scheme must achieve all Required benchmarks and the
same number of Distinguishing benchmarks as the currently referenced scheme, FSC.
3. Your specific commentary on these certification schemes is helpful. In the end, a forest
certification scheme will be deemed compliant by an independent, third-party evaluation of its
criteria against the Forest Certification Schemes Benchmarks requirements.
Thank you for your comments. USGBC agrees that any revision to LEED credits should motivate
market transformation and should advance more sustainable practices. As such, the proposed
changes to the Certified Wood credits are intended to motivate change, in this instance the forest
certification market. The USGBC benchmarks are intended to be an objective and transparent
collection of standards against which forest certification schemes will be evaluated to determine
which meet USGBC's level of rigor and then gain recognition in LEED.

Regarding the verification process, please see the accompanying draft Conformance Assessment to
learn how USGBC intends to evaluate the forest certification schemes against the finalized
benchmarks.




Thank you for your comments. First, rest assured that USGBC does not intend to decrease the rigor
of the Certified Wood credits. The proposed changes and accompanying Forest Certification
Scheme Benchmarks are meant to increase the transparency by which USGBC chooses one or more
scheme for recognition in those credits. The stringency of the benchmarks ensures that wood used
to earn a point in the credit will continue to come from exemplary forest management practices.

Second, USGBC has not yet determined whether additional certification schemes will be recognized
Thank you for your comments. First, rest assured that USGBC does not intend to decrease the rigor
of the Certified Wood credits. The proposed changes and accompanying Forest Certification
Scheme Benchmarks are meant to increase the transparency by which USGBC chooses one or more
scheme for recognition in those credits. The stringency of the benchmarks ensures that wood used
to earn a point in the credit will continue to come from exemplary forest management practices.

Second, USGBC has not yet determined whether additional certification schemes will be recognized
in LEED. The proposed Forest Certification Scheme Benchmarks are meant to transparently indicate
what USGBC expects from exemplary certification schemes if they are to be recognized in LEED.
You're invited to review the accompanying Conformance Assessment Process to learn how USGBC
will evaluate the schemes against the finalized benchmarks.


Thank you for your comments and your extensive recommendations. USGBC hopes that the
revisions address some of your concerns about inconsistency, vagueness, and/or lack of rigor. The
revisions are intended to 1) clarify and elaborate on the benchmarks and 2) find a balance between
the valid concerns of the expert commenters and the central values and objectives of USGBC. The
revised benchmarks, whether Required or Distinguishing, collectively present USGBC's definition of
exemplary forest certification and its high standards to earn recognition in LEED.




Thank you for your comments and your extensive recommendations. USGBC hopes that the
revisions address some of your concerns about inconsistency, vagueness, and/or lack of rigor. The
revisions are intended to 1) clarify and elaborate on the benchmarks and 2) find a balance between
the valid concerns of the expert commenters and the central values and objectives of USGBC. The
revised benchmarks, whether Required or Distinguishing, collectively present USGBC's definition of
exemplary forest certification and its high standards to earn recognition in LEED.
exemplary forest certification and its high standards to earn recognition in LEED.




Thank you for your comments. The responses to your main points are as follows:
1. USGBC believes that the virtue or value of the output does not justify the how it was achieved.
Processes to achieve an outcome or output too often have their own negative side effects. It’s
these negative side effects that USGBC wishes to minimize by requiring public plans.
2. The Plantations benchmark has been revised to allow for certain exceptions for converting lands
into plantations. These include 1) conversion occurs on a very limited portion of the forest
management unit; 2) conversion does not occur in forests of special conservation value; 3)
conversion enables clear long-term conservation benefits; and/or 4) there are demonstrated efforts,
guided by long-term planning, to restore the plantation area to natural forest conditions.
3. USGBC strongly supports sound research that addresses serious social, scientific, and economic
problems. However, USGBC does not support the use of certain practices when their effectiveness
has not been definitively proven, specifically in the organization’s definition of exemplary forest
management.
4. The Labor benchmarks are now Required benchmarks, stipulating that a scheme require
compliance with local labor laws. Some other Social benchmarks, however, are Distinguishing,
because USGBC recognizes that the requirements of those benchmarks surpass some North
American laws. As such, a scheme can earn one to exemplify itself from the others.




Thank you for your comments. USGBC does not intend for any benchmark to be biased towards a
particular forest certification scheme. Instead, USGBC intends for the benchmarks collectively
present the organization's definition of exemplary forest certification in all aspects of a certification
scheme, independent of any one scheme's previously established guidelines.
Thank you for your comments. First, please review the benchmark revisions, comments and
responses in the Governance section regarding the Organization Type benchmark you reference.

Second, USGBC agrees that any revision to LEED credits should motivate market transformation and
should advance more sustainable practices. As such, the proposed changes to the Certified Wood
credits are intended to motivate change, in this instance the forest certification market. The USGBC
Thank you for your comments. First, please review the benchmark revisions, comments and
responses in the Governance section regarding the Organization Type benchmark you reference.

Second, USGBC agrees that any revision to LEED credits should motivate market transformation and
should advance more sustainable practices. As such, the proposed changes to the Certified Wood
credits are intended to motivate change, in this instance the forest certification market. The USGBC
benchmarks are intended to be an objective and transparent collection of standards against which
forest certification schemes will be evaluated to determine which meet USGBC's level of rigor and
then gain recognition in LEED.

Regarding the verification process, please see the accompanying draft Conformance Assessment to
learn how USGBC intends to evaluate the forest certification schemes against the finalized
benchmarks.




Thank you for your comments and your extensive recommendations. USGBC hopes that the
revisions address some of your concerns about inconsistency, vagueness, and/or lack of rigor. The
revisions are intended to 1) clarify and elaborate on the benchmarks and 2) find a balance between
the valid concerns of the expert commenters and the central values and objectives of USGBC. The
revised benchmarks, whether Required or Distinguishing, collectively present USGBC's definition of
exemplary forest certification and its high standards to earn recognition in LEED.

USGBC will consider your suggestion to create a multi-tier Certified Wood credit. This credit
revision, however, requires an overall reconsideration of point distribution in LEED, something that
cannot occur until the next version of LEED.. The current revisions propose an alternative
compliance in lieu of a larger point redistribution.
Thank you for your comments. USGBC will evaluate all forest certification schemes against the
finalized benchmarks. Whatever scheme or schemes earn recognition in LEED will maintain the
expectation of exemplary forest certification.

Thank you for your comments. USGBC has not yet determined which of the CITES Appendices it will
adhere to for this benchmark requirement. Knowing that this decision affects the stringency of the
benchmark, the determination will be widely communicated when it is reached.




Thank you for your comments. Rest assured that USGBC does not intend to decrease the rigor of
the Certified Wood credits. The proposed changes and accompanying Forest Certification Scheme
Benchmarks are meant to increase the transparency by which USGBC chooses one or more scheme
for recognition in those credits. The stringency of the benchmarks ensures that wood used to earn a
point in the credit will continue to come from exemplary forest management practices.

USGBC appreciates your extensive recommendations. USGBC hopes that the revisions address
some of your concerns about inconsistency, vagueness, and/or lack of rigor. The revisions are
intended to 1) clarify and elaborate on the benchmarks and 2) find a balance between the valid
concerns of the expert commenters and the central values and objectives of USGBC. The revised
benchmarks, whether Required or Distinguishing, collectively present USGBC's definition of
exemplary forest certification and its high standards to earn recognition in LEED.
Thank you for your comments. Rest assured that USGBC does not intend to decrease the rigor of
the Certified Wood credits. The proposed changes and accompanying Forest Certification Scheme
Benchmarks are meant to increase the transparency by which USGBC chooses one or more scheme
for recognition in those credits. The stringency of the benchmarks ensures that wood used to earn a
point in the credit will continue to come from exemplary forest management practices.

USGBC appreciates your extensive recommendations. USGBC hopes that the revisions address
some of your concerns about inconsistency, vagueness, and/or lack of rigor. The revisions are
intended to 1) clarify and elaborate on the benchmarks and 2) find a balance between the valid
concerns of the expert commenters and the central values and objectives of USGBC. The revised
benchmarks, whether Required or Distinguishing, collectively present USGBC's definition of
exemplary forest certification and its high standards to earn recognition in LEED.




Thank you for your comments and your extensive recommendations. USGBC hopes that the
revisions address some of your concerns about inconsistency, vagueness, and/or lack of rigor. The
revisions are intended to 1) clarify and elaborate on the benchmarks and 2) find a balance between
the valid concerns of the expert commenters and the central values and objectives of USGBC. The
revised benchmarks, whether Required or Distinguishing, collectively present USGBC's definition of
exemplary forest certification and its high standards to earn recognition in LEED.

And, to clarify, USGBC has not yet determined whether additional certification schemes will be
recognized in LEED. The proposed Forest Certification Scheme Benchmarks are meant to
transparently indicate what USGBC expects from exemplary certification schemes if they are to be
recognized in LEED. You're invited to review the accompanying Conformance Assessment Process
to learn how USGBC will evaluate the schemes against the finalized benchmarks.
The revised benchmarks now include specific requirements for the Required Old Growth benchmark
while also directing the reader to Benchmark S3: Forests of special conservation value and
Benchmark S5: Ecosystem structure and function. The Clearcutting benchmark will not be included
in the final collection of benchmarks; the revisions direct the reader to Benchmarks S5: Ecosystem
Thank you for your comments and your extensive recommendations. USGBC hopes that the
revisions address some of your concerns about inconsistency, vagueness, and/or lack of rigor. The
revisions are intended to 1) clarify and elaborate on the benchmarks and 2) find a balance between
the valid concerns of the expert commenters and the central values and objectives of USGBC. The
revised benchmarks, whether Required or Distinguishing, collectively present USGBC's definition of
exemplary forest certification and its high standards to earn recognition in LEED.

And you're invited to see the accompanying draft Conformance Assessment to learn how USGBC
intends to evaluate the forest certification schemes against the finalized benchmarks.
Thank you for your comments and your extensive recommendations. USGBC hopes that the
revisions address some of your concerns about inconsistency, vagueness, and/or lack of rigor. The
revisions are intended to 1) clarify and elaborate on the benchmarks and 2) find a balance between
the valid concerns of the expert commenters and the central values and objectives of USGBC. The
revised benchmarks, whether Required or Distinguishing, collectively present USGBC's definition of
exemplary forest certification and its high standards to earn recognition in LEED.

And you're invited to see the accompanying draft Conformance Assessment to learn how USGBC
intends to evaluate the forest certification schemes against the finalized benchmarks.




Thank you for your comments and your extensive recommendations. USGBC hopes that the
revisions address some of your concerns about inconsistency, vagueness, and/or lack of rigor. The
revisions are intended to 1) clarify and elaborate on the benchmarks and 2) find a balance between
the valid concerns of the expert commenters and the central values and objectives of USGBC. The
revised benchmarks, whether Required or Distinguishing, collectively present USGBC's definition of
exemplary forest certification and its high standards to earn recognition in LEED.

And, to clarify, USGBC has not yet determined whether additional certification schemes will be
recognized in LEED. The proposed Forest Certification Scheme Benchmarks are meant to
transparently indicate what USGBC expects from exemplary certification schemes if they are to be
recognized in LEED. You're invited to review the accompanying Conformance Assessment Process
to learn how USGBC will evaluate the schemes against the finalized benchmarks.
Thank you for your comments and your extensive recommendations. USGBC hopes that the
revisions address some of your concerns about inconsistency, vagueness, and/or lack of rigor. The
revisions are intended to 1) clarify and elaborate on the benchmarks and 2) find a balance between
the valid concerns of the expert commenters and the central values and objectives of USGBC. The
revised benchmarks, whether Required or Distinguishing, collectively present USGBC's definition of
exemplary forest certification and its high standards to earn recognition in LEED. The level of rigor
and performance will not be decreased from its current level.

Additionally, USGBC is committed to using a transparent, third-party evaluation process to
determine which scheme or schemes meet the finalized requirements. USGBC fully values the
Thank you for your comments and your extensive recommendations. USGBC hopes that the
revisions address some of your concerns about inconsistency, vagueness, and/or lack of rigor. The
revisions are intended to 1) clarify and elaborate on the benchmarks and 2) find a balance between
the valid concerns of the expert commenters and the central values and objectives of USGBC. The
revised benchmarks, whether Required or Distinguishing, collectively present USGBC's definition of
exemplary forest certification and its high standards to earn recognition in LEED. The level of rigor
and performance will not be decreased from its current level.

Additionally, USGBC is committed to using a transparent, third-party evaluation process to
determine which scheme or schemes meet the finalized requirements. USGBC fully values the
insight of all stakeholder members and wishes to enlist their insight to the fullest extent possible.




Thank you for your comments and your extensive recommendations. USGBC hopes that the
revisions address some of your concerns about inconsistency, vagueness, and/or lack of rigor. The
revisions are intended to 1) clarify and elaborate on the benchmarks and 2) find a balance between
the valid concerns of the expert commenters and the central values and objectives of USGBC. The
revised benchmarks, whether Required or Distinguishing, collectively present USGBC's definition of
exemplary forest certification and its high standards to earn recognition in LEED.




Thank you for your comments. The responses to each of your main points are as follows
1. One of USGBC's Guiding Principles is "Promote the Triple Bottom Line" (environmental, social,
and economic sustainability). Therefore, the social aspects of a forest certification schemes
resonate with a USGBC principle and therefore will be included in the benchmark requirements.
2. LEED does not mandate the inclusion of foreign products. USGBC understands that, in the
current Certified Wood credit structure, a significant share of FSC-certified wood comes from
foreign sources. Nonetheless, this credit is optional and only worth 1% of the total points in LEED
2009. LEED certification is not contingent on earning this credit.
and economic sustainability). Therefore, the social aspects of a forest certification schemes
resonate with a USGBC principle and therefore will be included in the benchmark requirements.
2. LEED does not mandate the inclusion of foreign products. USGBC understands that, in the
current Certified Wood credit structure, a significant share of FSC-certified wood comes from
foreign sources. Nonetheless, this credit is optional and only worth 1% of the total points in LEED
2009. LEED certification is not contingent on earning this credit.




Thank you for your comments. You're invited to review the revised Plantations benchmark,
whereby certain exceptions have been specified. USGBC intends for this revision to both address
the concerns of you and other commentators as well as adhere to its high expectations.
Thank you for your comments. USGBC agrees with the need for continuous improvement but
believes that the content of the Management Plan and Monitoring Required benchmarks ensures
this quality is found in any LEED-recognized certification scheme. Additionally, USGBC does not
intend for any benchmark to be biased towards a particular forest certification scheme. Instead,
USGBC intends for the benchmarks collectively present the organization's definition of exemplary
forest certification in all aspects of a certification scheme, independent of any one scheme's
previously established guidelines.




Thank you for your comments. USGBC agrees that any revision to LEED credits should motivate
market transformation and should advance more sustainable practices. As such, the proposed
changes to the Certified Wood credits are intended to motivate change, in this instance the forest
certification market. The USGBC benchmarks are intended to be an objective and transparent
collection of standards against which forest certification schemes will be evaluated to determine
which meet USGBC's level of rigor and then gain recognition in LEED.

Regarding the verification process, please see the accompanying draft Conformance Assessment to
learn how USGBC intends to evaluate the forest certification schemes against the finalized
benchmarks.
Thank you for your comments. Rest assured that USGBC does not intend to decrease the rigor of
the Certified Wood credits. The proposed changes and accompanying Forest Certification Scheme
Benchmarks are meant to increase the transparency by which USGBC chooses one or more scheme
for recognition in those credits. The stringency of the benchmarks ensures that wood used to earn a
point in the credit will continue to come from exemplary forest management practices.

Additionally, USGBC hopes that the revisions address some of your concerns about inconsistency,
vagueness, and/or lack of rigor. The revisions are intended to 1) clarify and elaborate on the
benchmarks and 2) find a balance between the valid concerns of the expert commenters and the
central values and objectives of USGBC.




Thank you for your comments. USGBC agrees with the need to consult many forest certification
stakeholders as it finalizes its Forest Certification Scheme Benchmarks. USGBC will also, however,
ardently adhere to its Guiding Principles and its expectation of exemplary forest management when
determining which scheme or schemes gains recognition in LEED.
ardently adhere to its Guiding Principles and its expectation of exemplary forest management when
determining which scheme or schemes gains recognition in LEED.




Thank you for your comments. USGBC greatly appreciates the insight you offer on the labor
benchmark and will consider how to incorporate your suggestions as the benchmarks are finalized.




Thank you for your comments. USGBC has not yet determined whether additional certification
schemes will be recognized in LEED. Instead, the proposed benchmarks are meant to indicate what
USGBC expects from exemplary certification schemes. Additionally, they are meant to maintain the
rigor by which certified wood credits are currently achieved. USGBC agrees that sustainable wood
products and responsible forestry practices should be rewarded and believes that the intent of
these changes embodies those principles. There are not currently benchmarks for the other credits
in question.
schemes will be recognized in LEED. Instead, the proposed benchmarks are meant to indicate what
USGBC expects from exemplary certification schemes. Additionally, they are meant to maintain the
rigor by which certified wood credits are currently achieved. USGBC agrees that sustainable wood
products and responsible forestry practices should be rewarded and believes that the intent of
these changes embodies those principles. There are not currently benchmarks for the other credits
in question.




Thank you for your comments. USGBC hopes that the clarified and elaborated benchmarks address
all of your concerns about benchmark vagueness and inadequacy.




Thank you for your comments and your extensive recommendations. USGBC hopes that the
revisions address some of your concerns about inconsistency, vagueness, and/or lack of rigor. The
revisions are intended to 1) clarify and elaborate on the benchmarks and 2) find a balance between
the valid concerns of the expert commenters and the central values and objectives of USGBC. The
revised benchmarks, whether Required or Distinguishing, collectively present USGBC's definition of
exemplary forest certification and its high standards to earn recognition in LEED.
Thank you for your comments. USGBC appreciates your suggestions on each of the mentioned
issues. In some instances, USGBC has generally followed your suggestion but has elected another
approach for other instances. The revised benchmarks are intended to be less vague, more
detailed, and aligned with USGBC’s Guiding Principles and expectations for exemplary forest
certification.




Thank you for your comments and your extensive recommendations. USGBC hopes that the
revisions address some of your concerns about inconsistency, vagueness, and/or lack of rigor. The
revisions are intended to 1) clarify and elaborate on the benchmarks and 2) find a balance between
the valid concerns of the expert commenters and the central values and objectives of USGBC. The
revised benchmarks, whether Required or Distinguishing, collectively present USGBC's definition of
exemplary forest certification and its high standards to earn recognition in LEED.
Thank you for your comments and your extensive recommendations. USGBC hopes that the
revisions address some of your concerns about inconsistency, vagueness, and/or lack of rigor. The
revisions are intended to 1) clarify and elaborate on the benchmarks and 2) find a balance between
the valid concerns of the expert commenters and the central values and objectives of USGBC. The
revised benchmarks, whether Required or Distinguishing, collectively present USGBC's definition of
exemplary forest certification and its high standards to earn recognition in LEED.




Thank you for your comments and your extensive recommendations. USGBC hopes that the
revisions address some of your concerns about inconsistency, vagueness, and/or lack of rigor. The
revisions are intended to 1) clarify and elaborate on the benchmarks and 2) find a balance between
the valid concerns of the expert commenters and the central values and objectives of USGBC. The
revised benchmarks, whether Required or Distinguishing, collectively present USGBC's definition of
exemplary forest certification and its high standards to earn recognition in LEED.

Additionally, USGBC does not intend for any benchmark to be biased towards a particular forest
certification scheme. Instead, USGBC intends for the benchmarks collectively present the
organization's definition of exemplary forest certification in all aspects of a certification scheme,
independent of any one scheme's previously established guidelines.
Thank you for your comments and your extensive recommendations. USGBC hopes that the
revisions address some of your concerns about inconsistency, vagueness, and/or lack of rigor. The
revisions are intended to 1) clarify and elaborate on the benchmarks and 2) find a balance between
the valid concerns of the expert commenters and the central values and objectives of USGBC. The
revised benchmarks, whether Required or Distinguishing, collectively present USGBC's definition of
exemplary forest certification and its high standards to earn recognition in LEED.




Thank you for your comments. USGBC recognizes the inherently green aspects of all wood types,
including hardwoods. As such, USGBC is embarking on rating system development to determine the
ways in which LEED can recognize the use of wood. If a recognition is ultimately included, it would
not appear until the next version of LEED.
Thank you for your comments. USGBC recognizes the inherently green aspects of all wood types,
including hardwoods. As such, USGBC is embarking on rating system development to determine the
ways in which LEED can recognize the use of wood. If a recognition is ultimately included, it would
not appear until the next version of LEED.




Thank you for your comments.




Thank you for your comments and your extensive recommendations. USGBC hopes that the
revisions address some of your concerns about inconsistency, vagueness, and/or lack of rigor. The
revisions are intended to 1) clarify and elaborate on the benchmarks and 2) find a balance between
the valid concerns of the expert commenters and the central values and objectives of USGBC. The
revised benchmarks, whether Required or Distinguishing, collectively present USGBC's definition of
exemplary forest certification and its high standards to earn recognition in LEED.
Thank you for your comments. USGBC hopes that, while the revisions may not include your
suggestions verbatim, the revisions do address the intent of your concerns.




Thank you for your comments. Your insight is valuable to USGBC as it finalizes the Forest
Certification Scheme Benchmarks. To be sure, it is not yet determine whether schemes besides FSC
will gain recognition in LEED after evaluation against the benchmarks. Above all, USGBC will
maintain its expectations for exemplary forest certification, especially in light of your claims.
Thank you for your comments and your extensive recommendations. USGBC hopes that the
revisions address some of your concerns about inconsistency, vagueness, and/or lack of rigor. The
revisions are intended to 1) clarify and elaborate on the benchmarks and 2) find a balance between
the valid concerns of the expert commenters and the central values and objectives of USGBC. The
revised benchmarks, whether Required or Distinguishing, collectively present USGBC's definition of
exemplary forest certification and its high standards to earn recognition in LEED.




Thank you for your comments. USGBC has created specific requirements for the Old Growth
benchmark but has allowed associated benchmarks to account for the issues in the Clearcutting and
Forest Restoration benchmarks. The associated benchmarks are clearly identified in the revisions.




Thank you for your comments. USGBC does not intend for any benchmark to be biased towards a
particular forest certification scheme. Instead, USGBC intends for the benchmarks collectively
present the organization's definition of exemplary forest certification in all aspects of a certification
scheme, independent of any one scheme's previously established guidelines.
Thank you for your comments. USGBC does not intend for any benchmark to be biased towards a
particular forest certification scheme. Instead, USGBC intends for the benchmarks collectively
present the organization's definition of exemplary forest certification in all aspects of a certification
scheme, independent of any one scheme's previously established guidelines.




Thank you for your comments and your extensive recommendations. USGBC hopes that the
revisions address some of your concerns about inconsistency, vagueness, and/or lack of rigor. The
revisions are intended to 1) clarify and elaborate on the benchmarks and 2) find a balance between
the valid concerns of the expert commenters and the central values and objectives of USGBC. The
revised benchmarks, whether Required or Distinguishing, collectively present USGBC's definition of
exemplary forest certification and its high standards to earn recognition in LEED.




Thank you for your comments. The responses to your main points are as follows:
1. USGBC agrees with the importance of the issues of Carbon Storage and Forest Extent and have
created a Distinguishing benchmark and a Required benchmark for them, respectively.
2. The proposed Conformance Assessment Process will feature a review panel that will look at the
unique aspects of each forest certification scheme.
3. Your specific commentary on these certification schemes is helpful. In the end, a forest
certification scheme will be deemed compliant by an independent, third-party evaluation of its
criteria against the Forest Certification Schemes Benchmarks requirements.
Thank you for your comments. The responses to some of your main points are as follows:
1. USGBC has very specific views on exemplary forest certification; as such, the benchmarks will –
for the most part – remain prescriptive in nature. The third-party evaluation of the schemes against
the benchmarks will fully consider the unique ways in which each scheme meets or does not meet
the requirements.
2. USGBC will place the threshold at the number of Distinguishing benchmarks its currently
referenced standard, FSC meets.
3. On the whole, USGBC hopes that the revisions address some of your concerns about
inconsistency, vagueness, and/or lack of rigor. The revisions are intended to 1) clarify and elaborate
on the benchmarks and 2) find a balance between the valid concerns of the expert commenters and
the central values and objectives of USGBC. The revised benchmarks, whether Required or
Distinguishing, collectively present USGBC's definition of exemplary forest certification and its high
standards to earn recognition in LEED.
Thank you for your comments. To clarify, the USGBC benchmarks are not setting standards for the
certification of particular forest types nor particular tree environs. Instead, they set standards for
the certification schemes in order for one or more schemes to be recognized in the LEED rating
systems. Potentially a certification body could devise a scheme for urban forests and can be
evaluated under this Forest Certification Scheme Benchmark the same as any other scheme. In the
interim, wood from urban sources is eligible for a credit under the Regional Materials credit.
Another option is for project teams who use wood sourced from the project site is to apply for an
Innovation in Design credit explicitly noting how the strategy is comprehensively and quantifiably
bettering the environment.
Thank you for your comments and your extensive recommendations. USGBC hopes that the
revisions address some of your concerns about inconsistency, vagueness, and/or lack of rigor. The
revisions are intended to 1) clarify and elaborate on the benchmarks and 2) find a balance between
the valid concerns of the expert commenters and the central values and objectives of USGBC. The
revised benchmarks, whether Required or Distinguishing, collectively present USGBC's definition of
exemplary forest certification and its high standards to earn recognition in LEED.




Thank you for your comments and your extensive recommendations. USGBC hopes that the
revisions address some of your concerns about inconsistency, vagueness, and/or lack of rigor. The
revisions are intended to 1) clarify and elaborate on the benchmarks and 2) find a balance between
the valid concerns of the expert commenters and the central values and objectives of USGBC. The
revised benchmarks, whether Required or Distinguishing, collectively present USGBC's definition of
exemplary forest certification and its high standards to earn recognition in LEED.
Thank you for your comments and your extensive recommendations. USGBC hopes that the
revisions address some of your concerns about inconsistency, vagueness, and/or lack of rigor. The
revisions are intended to 1) clarify and elaborate on the benchmarks and 2) find a balance between
the valid concerns of the expert commenters and the central values and objectives of USGBC. The
revised benchmarks, whether Required or Distinguishing, collectively present USGBC's definition of
exemplary forest certification and its high standards to earn recognition in LEED.




Thank you for your comments and support of the benchmarks. Your specific commentary on these
certification schemes is helpful. In the end, a forest certification scheme will be deemed compliant
by an independent, third-party evaluation of its criteria against the Forest Certification Schemes
Benchmarks requirements.
Thank you for your comments and support of the benchmarks. Your specific commentary on these
certification schemes is helpful. In the end, a forest certification scheme will be deemed compliant
by an independent, third-party evaluation of its criteria against the Forest Certification Schemes
Benchmarks requirements.




Thank you for your comments and your extensive recommendations. USGBC hopes that the
revisions address some of your concerns about inconsistency, vagueness, and/or lack of rigor. The
revisions are intended to 1) clarify and elaborate on the benchmarks and 2) find a balance between
the valid concerns of the expert commenters and the central values and objectives of USGBC. The
revised benchmarks, whether Required or Distinguishing, collectively present USGBC's definition of
exemplary forest certification and its high standards to earn recognition in LEED.
Thank you very much for your comments and suggested revision. USGBC has accepted your
suggestion and included that phrasing into the revised Chemical Use benchmark.




Thank you for your comments. To be sure, USGBC does not intend for any benchmark to be biased
towards a particular forest certification scheme. Instead, USGBC intends for the benchmarks
collectively present the organization's definition of exemplary forest certification in all aspects of a
certification scheme, independent of any one scheme's previously established guidelines.
Thank you for your comments. To clarify, USGBC has not yet determined whether additional
certification schemes will be recognized in LEED. The proposed Forest Certification Scheme
Benchmarks are meant to transparently indicate what USGBC expects from exemplary certification
schemes if they are to be recognized in LEED. You're invited to review the accompanying
Conformance Assessment Process to learn how USGBC will evaluate the schemes against the
finalized benchmarks.


Thank you for your comments. USGBC does not intend for any benchmark to be biased towards a
particular forest certification scheme. Instead, USGBC intends for the benchmarks collectively
present the organization's definition of exemplary forest certification in all aspects of a certification
scheme, independent of any one scheme's previously established guidelines. USGBC has not yet
determined whether additional certification schemes will be recognized in LEED. Your specific
commentary on PEFC is helpful. In the end, a forest certification scheme will be deemed compliant
by an independent, third-party evaluation of its criteria against the Forest Certification Schemes
Benchmarks requirements. Additionally, USGBC believes that prescriptive benchmarks are necessary
to ensure compliance with its own definition of exemplary forest certification and is not meant to
penalize areas where sustainable forestry practices are already in place.




Thank you for your comments about the Rediscovered Wood program. In the end, a forest
certification scheme will be deemed compliant by an independent, third-party evaluation of its
criteria against the Forest Certification Schemes Benchmarks requirements.
Thank you for your comments about the Rediscovered Wood program. In the end, a forest
certification scheme will be deemed compliant by an independent, third-party evaluation of its
criteria against the Forest Certification Schemes Benchmarks requirements.




Thank you for your concern. Since LEED establishes the leadership benchmarks for the top-
performing buildings and neighborhoods, USGBC also intends for its Forest Certification Scheme
Benchmarks to recognize exemplary schemes. USGBC believes that the comprehensive
requirements set forth by the benchmarks align closest with its Guiding Principles and implicitly
presents what USGBC defines as sustainable forest management with no recognition to a specific
scheme. You are welcome to reference the Conformance Assessment Process to learn how USGBC
will evaluate the schemes against the finalized benchmarks. Additionally, currently MRc5 in LEED for
New Construction, Schools, and Core and Shell award 1-2 points for the use products that are locally
extracted, harvested, or recovered, as well as manufactured, within 500 miles of the project site. It
is recommended that project teams pursue this credit for recognition of sourcing wood from local
sources. For the purposes of the Certified Wood credits, USGBC will ensure that the wood used to
earn the credit comes from exemplary forest management practices, regardless of the geographic
source.




Thank you for your comments. USGBC is currently determining its larger stance on the use of GMOs.
Until finalized, this will be a Distinguishing benchmark through which a certification scheme can
exemplify itself from other.




Thank you for your comments. You specific concerns are addressed below:
1. USGBC does not intend for any benchmark to be biased towards a particular forest certification
scheme.
2. USGBC believes that prescriptive benchmarks are necessary to ensure compliance with its own
definition of exemplary forest certification. To gain recognition in LEED, a forest certification
scheme does not need to fulfill every benchmark.
3. USGBC hopes that the clarified and elaborated benchmarks address all of your concerns about
benchmark vagueness.
4. Your specific commentary on these certification schemes is helpful. In the end, a forest
certification scheme will be deemed compliant by an independent, third-party evaluation of its
criteria against the Forest Certification Schemes Benchmarks requirements.
Thank you for your comments. You specific concerns are addressed below:
1. USGBC does not intend for any benchmark to be biased towards a particular forest certification
scheme.
2. USGBC believes that prescriptive benchmarks are necessary to ensure compliance with its own
definition of exemplary forest certification. To gain recognition in LEED, a forest certification
scheme does not need to fulfill every benchmark.
3. USGBC hopes that the clarified and elaborated benchmarks address all of your concerns about
benchmark vagueness.
4. Your specific commentary on these certification schemes is helpful. In the end, a forest
certification scheme will be deemed compliant by an independent, third-party evaluation of its
criteria against the Forest Certification Schemes Benchmarks requirements.




Thank you for your comments. USGBC hopes that the clarified and elaborated benchmarks address
all of your concerns about benchmark vagueness and inadequacy. Additionally, USGBC does not
intend for any benchmark to be biased towards a particular forest certification scheme. Instead,
USGBC intends for the benchmarks collectively present the organization's definition of exemplary
forest certification in all aspects of a certification scheme, independent of any one scheme's
previously established guidelines.
intend for any benchmark to be biased towards a particular forest certification scheme. Instead,
USGBC intends for the benchmarks collectively present the organization's definition of exemplary
forest certification in all aspects of a certification scheme, independent of any one scheme's
previously established guidelines.




Thank you for your comments. USGBC does not intend for any benchmark to be biased towards a
particular forest certification scheme. Instead, USGBC intends for the benchmarks collectively
present the organization's definition of exemplary forest certification in all aspects of a certification
scheme, independent of any one scheme's previously established guidelines.




Thank you. USGBC believes that prescriptive benchmarks are necessary to ensure compliance with
its own definition of exemplary forest certification. To gain recognition in LEED, a forest certification
scheme does not need to fulfill every benchmark. Please see the accompanying Conformance
Assessment Process to learn how USGBC intends to evaluate the forest certification schemes against
the finalized benchmarks.

Your specific commentary on these certification schemes is helpful. In the end, a forest certification
scheme will be deemed compliant by an independent, third-party evaluation of its criteria against
the Forest Certification Schemes Benchmarks requirements.
Thank you. USGBC believes that prescriptive benchmarks are necessary to ensure compliance with
its own definition of exemplary forest certification. To gain recognition in LEED, a forest certification
scheme does not need to fulfill every benchmark. Please see the accompanying Conformance
Assessment Process to learn how USGBC intends to evaluate the forest certification schemes against
the finalized benchmarks.

Your specific commentary on these certification schemes is helpful. In the end, a forest certification
scheme will be deemed compliant by an independent, third-party evaluation of its criteria against
the Forest Certification Schemes Benchmarks requirements.




Thank you for your comments and your extensive recommendations. USGBC hopes that the
revisions address some of your concerns about inconsistency, vagueness, and/or lack of rigor. The
revisions are intended to 1) clarify and elaborate on the benchmarks and 2) find a balance between
the valid concerns of the expert commenters and the central values and objectives of USGBC. The
revised benchmarks, whether Required or Distinguishing, collectively present USGBC's definition of
exemplary forest certification and its high standards to earn recognition in LEED.
Thank you for your comments and your extensive recommendations. USGBC hopes that the
revisions address some of your concerns about inconsistency, vagueness, and/or lack of rigor. The
revisions are intended to 1) clarify and elaborate on the benchmarks and 2) find a balance between
the valid concerns of the expert commenters and the central values and objectives of USGBC. The
revised benchmarks, whether Required or Distinguishing, collectively present USGBC's definition of
exemplary forest certification and its high standards to earn recognition in LEED.




Thank you for your comments. USGBC recognizes the inherently green aspects of all wood types,
including hardwoods. As such, USGBC is embarking on rating system development to determine the
ways in which LEED can recognize the use of wood. If a recognition is ultimately included, it would
not appear until the next version of LEED.

Thank you for your comments. The responses to each of your main points are as follows:
1. USGBC does not intend for any benchmark to be biased towards a particular forest certification
scheme. Instead, USGBC intends for the benchmarks collectively present the organization's
definition of exemplary forest certification in all aspects of a certification scheme, independent of
any one scheme's previously established guidelines.
2. You're invited to review the revised Plantations benchmark, whereby certain exceptions have
been specified. USGBC intends for this revision to both address the concerns of you and other
commentators as well as adhere to its high expectations.
3. Regarding GMOs, USGBC is currently determining its larger stance on the use of GMOs. Until
finalized, this will be a Distinguishing benchmark through which a certification scheme can exemplify
itself from other.
4. USGBC believes that prescriptive benchmarks are necessary to ensure compliance with its own
definition of exemplary forest certification. Regarding the Chemical use benchmark, USGBC is
confident in its prescriptiveness and believes it sets a rigorous standard.
3. The provisions of those sections apply to non-certified sources that are included in the wood
product that nonetheless includes certified material.
4. Please note that not all benchmarks are required to gain recognition in LEED. USGBC hopes that
the clarified and elaborated benchmarks address all of your concerns about benchmark vagueness
and inadequacy.
Thank you for your comments. The responses to each of your main points are as follows:
1. USGBC does not intend for any benchmark to be biased towards a particular forest certification
scheme. Instead, USGBC intends for the benchmarks collectively present the organization's
definition of exemplary forest certification in all aspects of a certification scheme, independent of
any one scheme's previously established guidelines.
2. You're invited to review the revised Plantations benchmark, whereby certain exceptions have
been specified. USGBC intends for this revision to both address the concerns of you and other
commentators as well as adhere to its high expectations.
3. Regarding GMOs, USGBC is currently determining its larger stance on the use of GMOs. Until
finalized, this will be a Distinguishing benchmark through which a certification scheme can exemplify
itself from other.
4. USGBC believes that prescriptive benchmarks are necessary to ensure compliance with its own
definition of exemplary forest certification. Regarding the Chemical use benchmark, USGBC is
confident in its prescriptiveness and believes it sets a rigorous standard.
3. The provisions of those sections apply to non-certified sources that are included in the wood
product that nonetheless includes certified material.
4. Please note that not all benchmarks are required to gain recognition in LEED. USGBC hopes that
the clarified and elaborated benchmarks address all of your concerns about benchmark vagueness
and inadequacy.
Thank you for your comments. The responses to some of your main points are as follows:
1. The revised benchmarks now require that compliant schemes strive towards economic viability
for the certified forests. This is a performance-based benchmark that allows schemes to ensure that
in methods that are most applicable to their context.
2. The revised "Management plan" benchmark does not require the information to be publicly
available.




Thank you for your comments and your extensive recommendations. Responses to your specific
points are as follows:
1. USGBC does not intend for any benchmark to be biased towards a particular forest certification
scheme.
2. You're invited to review the revised Plantations benchmark, whereby certain exceptions have
been specified. USGBC intends for this revision to both address the concerns of you and other
commentators as well as adhere to its high expectations.
3. Regarding GMOs, USGBC is currently determining its larger stance on the use of GMOs. Until
finalized, this will be a Distinguishing benchmark through which a certification scheme can exemplify
itself from other.
4.Regarding the Chemical use benchmark, USGBC is confident in its prescriptiveness and believes it
sets a rigorous standard.
5. USGBC respectfully recognizes the work done by the EPA but believes that prescriptive
benchmarks are necessary to ensure compliance with its own definition of exemplary forest
certification and to uphold the rigor and integrity of the certified wood credit.


Thank you for your comments and support of the proposed changes.
Thank you for your comments. USGBC recognizes the inherently green aspects of all wood types,
including hardwoods. As such, USGBC is embarking on rating system development to determine the
ways in which LEED can recognize the use of wood. If a recognition is ultimately included, it would
not appear until the next version of LEED.




Thank you for your comments. USGBC hopes that the clarified and elaborated benchmarks address
all of your concerns about benchmark vagueness and inadequacy.

Additionally, your specific commentary on these certification schemes is helpful. In the end, a forest
certification scheme will be deemed compliant by an independent, third-party evaluation of its
criteria against the Forest Certification Schemes Benchmarks requirements.
Thank you for your comments. USGBC recognizes the inherently green aspects of all wood types,
including hardwoods. As such, USGBC is embarking on rating system development to determine the
ways in which LEED can recognize the use of wood. If a recognition is ultimately included, it would
not appear until the next version of LEED.
Thank you for your comments and your extensive recommendations. USGBC hopes that the
revisions address some of your concerns about inconsistency, vagueness, and/or lack of rigor. The
revisions are intended to clarify and elaborate on the benchmarks, all the while finding a balance
between the valid concerns of the expert commenters and the central values and objectives of
USGBC.
Thank you for your comments and your extensive recommendations. USGBC hopes that the
revisions address some of your concerns about inconsistency, vagueness, and/or lack of rigor. The
revisions are intended to clarify and elaborate on the benchmarks, all the while finding a balance
between the valid concerns of the expert commenters and the central values and objectives of
USGBC.




Thank you for your comments and your extensive recommendations. USGBC hopes that the
revisions address some of your concerns about inconsistency, vagueness, and/or lack of rigor. The
revisions are intended to clarify and elaborate on the benchmarks, all the while finding a balance
between the valid concerns of the expert commenters and the central values and objectives of
USGBC.




Thank you for your comments and your extensive recommendations. USGBC hopes that the
revisions address some of your concerns about inconsistency, vagueness, and/or lack of rigor. The
revisions are intended to clarify and elaborate on the benchmarks, all the while finding a balance
between the valid concerns of the expert commenters and the central values and objectives of
USGBC.
Thank you for your comments and your extensive recommendations. USGBC hopes that the
revisions address some of your concerns about inconsistency, vagueness, and/or lack of rigor. The
revisions are intended to clarify and elaborate on the benchmarks, all the while finding a balance
between the valid concerns of the expert commenters and the central values and objectives of
USGBC. Your specific commentary on the certification schemes you reference is helpful. In the end,
a forest certification scheme will be deemed compliant by an independent, third-party evaluation of
its criteria against the Forest Certification Schemes Benchmarks requirements.
Thank you for your comments. Responses to specific comments are as follows:
1. USGBC does not intend for any benchmark to be biased towards a particular forest certification
scheme. Instead, USGBC intends for the benchmarks collectively present the organization's
definition of exemplary forest certification in all aspects of a certification scheme, independent of
any one scheme's previously established guidelines.
2. You're invited to review the revised Plantations benchmark, whereby certain exceptions have
been specified. USGBC intends for this revision to both address the concerns of you and other
commentators as well as adhere to its high expectations.
3. USGBC is currently determining its larger stance on the use of GMOs. Until finalized, this will be a
Distinguishing benchmark through which a certification scheme can exemplify itself from other.
4. USGBC respectfully recognizes the work done by the EPA but believes that prescriptive
benchmarks are necessary to ensure compliance with its own definition of exemplary forest
certification and to uphold the rigor and integrity of the certified wood credit.
5.Regarding the Chemical use benchmark, USGBC is confident in its prescriptiveness and believes it
sets a rigorous standard.
6. USGBC intends for schemes to demonstrate how the legal requirements of their contexts meet
the requirements of the benchmark, thus ensuring compliance.
sets a rigorous standard.
6. USGBC intends for schemes to demonstrate how the legal requirements of their contexts meet
the requirements of the benchmark, thus ensuring compliance.




Thank you for your comments and concern. You're invited to review the revised Plantations
benchmark, whereby certain exceptions have been specified. USGBC intends for this revision to
both address the concerns of you and other commentators as well as adhere to its high
expectations. And USGBC is currently determining its larger stance on the use of GMOs. Until
finalized, this will be a Distinguishing benchmark through which a certification scheme can exemplify
itself from other. Regarding chemical use benchmark, USGBC is confident in its prescriptiveness and
believes it sets a rigorous standard.




Thank you for your comments and your extensive recommendations. USGBC hopes that the
revisions address some of your concerns about inconsistency, vagueness, and/or lack of rigor. The
revisions are intended to 1) clarify and elaborate on the benchmarks and 2) find a balance between
the valid concerns of the expert commenters and the central values and objectives of USGBC. The
revised benchmarks, whether Required or Distinguishing, collectively present USGBC's definition of
exemplary forest certification and its high standards to earn recognition in LEED.




Thank you for your comments and your extensive recommendations. USGBC hopes that the
revisions address some of your concerns about inconsistency, vagueness, and/or lack of rigor. The
revisions are intended to 1) clarify and elaborate on the benchmarks and 2) find a balance between
the valid concerns of the expert commenters and the central values and objectives of USGBC. The
revised benchmarks, whether Required or Distinguishing, collectively present USGBC's definition of
exemplary forest certification and its high standards to earn recognition in LEED.

And, to clarify, USGBC has not yet determined whether additional certification schemes will be
recognized in LEED. The proposed Forest Certification Scheme Benchmarks are meant to
transparently indicate what USGBC expects from exemplary certification schemes if they are to be
recognized in LEED. You're invited to review the accompanying Conformance Assessment Process
Thank you for your comments and your extensive recommendations. USGBC hopes that the
revisions address some of your concerns about inconsistency, vagueness, and/or lack of rigor. The
revisions are intended to 1) clarify and elaborate on the benchmarks and 2) find a balance between
the valid concerns of the expert commenters and the central values and objectives of USGBC. The
revised benchmarks, whether Required or Distinguishing, collectively present USGBC's definition of
exemplary forest certification and its high standards to earn recognition in LEED.

And, to clarify, USGBC has not yet determined whether additional certification schemes will be
recognized in LEED. The proposed Forest Certification Scheme Benchmarks are meant to
transparently indicate what USGBC expects from exemplary certification schemes if they are to be
recognized in LEED. You're invited to review the accompanying Conformance Assessment Process
to learn how USGBC will evaluate the schemes against the finalized benchmarks.
Thank you for your comments. USGBC respectfully believes that prescriptive benchmarks are
necessary to ensure compliance with its own definition of exemplary forest certification and to
uphold the rigor of the certified wood credit. To gain recognition in LEED, a forest certification
scheme does not need to fulfill every benchmark. Please see the accompanying Conformance
Assessment Process to learn how USGBC intends to evaluate the forest certification schemes against
the finalized benchmarks. Additionally, USGBC does not intend for any of the benchmarks to be
biased toward a particular certification scheme. Your comments regarding specific benchmarks and
certification schemes are very helpful. In the end, a forest certification scheme will be deemed
compliant by an independent, third-party evaluation of its criteria against the Forest Certification
Schemes Benchmarks requirements.
Thank you for your comments and concern. You're invited to review the revised Plantations
benchmark, whereby certain exceptions have been specified. Regarding chemical use benchmark,
with due respect to the scientific community, USGBC is confident in its prescriptiveness and believes
it sets a rigorous standard. USGBC agrees with the need for continuous improvement but believes
that the content of the Management Plan and Monitoring Required benchmarks ensures this quality
is found in any LEED-recognized certification scheme.




Thank you for your comments and support of the proposed changes. Please note that LEED includes
a Materials Reuse credit, whereby points are awarded for the use of salvaged, reused or refurbished
materials. Your example of recovered, dead urban trees would fall into the category of salvaged
material.
Thank you for your comments and suggestions. USGBC believes that prescriptive language is
necessary to ensure compliance with its own definition of sustainable forestry. USGBC hopes that
the clarified and elaborated benchmarks address all of your concerns about benchmark vagueness
and inadequacy.




Thank you for your comments, concern, and support of the proposed changes. Please note that not
all benchmarks are required for a certification scheme to be recognized in LEED. The accompanying
Conformance Assessment Process document explains more. USGBC intends to maintain an open
dialogue with the forest production industry and remain completely transparent as the various
forest certification schemes are evaluated against the finalized benchmarks.
Thank you for your comments and your extensive recommendations. USGBC hopes that the
revisions address some of your concerns about inconsistency, vagueness, and/or lack of rigor. The
revisions are intended to 1) clarify and elaborate on the benchmarks and 2) find a balance between
the valid concerns of the expert commenters and the central values and objectives of USGBC. The
revised benchmarks, whether Required or Distinguishing, collectively present USGBC's definition of
exemplary forest certification and its high standards to earn recognition in LEED.

And your specific commentary on certification schemes is helpful. In the end, a forest certification
scheme will be deemed compliant by an independent, third-party evaluation of its criteria against
the Forest Certification Schemes Benchmarks requirements.




Thank you for your comments and suggestions. Regarding plantations, you’re invited to review the
revised benchmark, whereby certain exceptions have been specified. USGBC agrees with the need
for continuous improvement but believes that the content of the Management Plan and Monitoring
Required benchmarks ensures this quality is found in any LEED-recognized certification scheme.
Your specific commentary on the certification schemes noted is useful.
Thank you for your comments and suggestions. Regarding plantations, you’re invited to review the
revised benchmark, whereby certain exceptions have been specified. USGBC agrees with the need
for continuous improvement but believes that the content of the Management Plan and Monitoring
Required benchmarks ensures this quality is found in any LEED-recognized certification scheme.
Your specific commentary on the certification schemes noted is useful.




Thank you for your comments. USGBC has not yet determined whether additional certification
schemes will be recognized in LEED. The proposed Forest Certification Scheme Benchmarks are
meant to transparently indicate what USGBC expects from exemplary certification schemes if they
are to be recognized in LEED. You're invited to review the accompanying Conformance Assessment
Process to learn how USGBC will evaluate the schemes against the finalized benchmarks.




Thank you for your comments and your extensive recommendations. USGBC hopes that the
revisions address some of your concerns about inconsistency, vagueness, and/or lack of rigor. The
revisions are intended to 1) clarify and elaborate on the benchmarks and 2) find a balance between
the valid concerns of the expert commenters and the central values and objectives of USGBC. The
revised benchmarks, whether Required or Distinguishing, collectively present USGBC's definition of
exemplary forest certification and its high standards to earn recognition in LEED.
Thank you for your comments. Responses to your specific points are as follows:
1. USGBC does not intend for any benchmark to be biased towards a particular forest certification
scheme.
2. USGBC is currently determining its larger stance on the use of GMOs. Until finalized, this will be a
Distinguishing benchmark through which a certification scheme can exemplify itself from other.
3. Regarding the Chemical use benchmark, USGBC is confident in its prescriptiveness and believes it
sets a rigorous standard.
4. USGBC agrees with the need for continuous improvement but believes that the content of the
Management Plan and Monitoring Required benchmarks ensures this quality is found in any LEED-
recognized certification scheme.
5. Thank you for noting specific certification systems that you feel are compliant with the proposed
benchmarks. Your input is useful.
Thank you for your comments. Responses to your specific points are as follows:
1. USGBC does not intend for any benchmark to be biased towards a particular forest certification
scheme.
2. USGBC is currently determining its larger stance on the use of GMOs. Until finalized, this will be a
Distinguishing benchmark through which a certification scheme can exemplify itself from other.
3. Regarding the Chemical use benchmark, USGBC is confident in its prescriptiveness and believes it
sets a rigorous standard.
4. USGBC agrees with the need for continuous improvement but believes that the content of the
Management Plan and Monitoring Required benchmarks ensures this quality is found in any LEED-
recognized certification scheme.
5. Thank you for noting specific certification systems that you feel are compliant with the proposed
benchmarks. Your input is useful.




Thank you for your extensive comments and suggestions. USGBC hopes that the revisions address
some of your concerns about inconsistency, vagueness, and/or lack of rigor. Some responses to your
specific comments are as follows:
1. USGBC does not intend the benchmarks to be biased toward one particular certification scheme.
2. Regarding plantations, you’re invited to review the revised Plantations benchmark, whereby
certain exceptions have been specified.
3. USGBC is currently determining its larger stance on the use of GMOs. Until finalized, this will be a
Distinguishing benchmark through which a certification scheme can exemplify itself from other.
4. Regarding the Chemical use benchmark, USGBC is confident in its prescriptiveness and believes it
sets a rigorous standard.
5. USGBC agrees with the need for continuous improvement but believes that the content of the
Management Plan and Monitoring Required benchmarks ensures this quality is found in any LEED-
recognized certification scheme.
Thank you for your comments. USGBC recognizes that the previous versions of the benchmarks
may have been vague, unclear, and/or insufficient. It is hoped that the subsequent revisions
addressed those issues and present elaborated and consistently rigorous benchmarks. USGBC has
either added requirements to some benchmarks that previously did not have any. For those that
continue to not have requirements, an explanation and/or reference to other benchmarks are
included. The revised benchmarks, whether Required or Distinguishing, collectively present USGBC's
definition of exemplary forest certification and its high standards to earn recognition in LEED.




Thank you for your comments. Responses to specific suggestions are as follows:
1. You're invited to review the revised Plantations benchmark, whereby certain exceptions have
been specified. USGBC intends for this revision to both address the concerns of you and other
commentators as well as adhere to its high expectations.
2. USGBC is currently determining its larger stance on the use of GMOs. Until finalized, this will be a
Distinguishing benchmark through which a certification scheme can exemplify itself from other.
3. Regarding the Chemical use benchmark, with all due respect to the EPA and scientific community,
USGBC is confident in its prescriptiveness and believes it sets a rigorous standard.
4. USGBC intends for schemes to demonstrate how the legal requirements of their contexts meet
the requirements of the benchmark, thus ensuring compliance.




Thank you for your comments. Responses to specific suggestions are as follows:
1. You're invited to review the revised Plantations benchmark, whereby certain exceptions have
been specified. USGBC intends for this revision to both address the concerns of you and other
commentators as well as adhere to its high expectations.
2. USGBC is currently determining its larger stance on the use of GMOs. Until finalized, this will be a
Distinguishing benchmark through which a certification scheme can exemplify itself from other.
3. Regarding the Chemical use benchmark, with all due respect to the EPA and scientific community,
USGBC is confident in its prescriptiveness and believes it sets a rigorous standard.
4. USGBC intends for schemes to demonstrate how the legal requirements of their contexts meet
the requirements of the benchmark, thus ensuring compliance.
5. Your specific commentary on the SFI and FSC is useful. In the end, a forest certification scheme
will be deemed compliant by an independent, third-party evaluation of its criteria against the Forest
Certification Schemes Benchmarks requirements.
Thank you for your comments. Responses to specific suggestions are as follows:
1. You're invited to review the revised Plantations benchmark, whereby certain exceptions have
been specified. USGBC intends for this revision to both address the concerns of you and other
commentators as well as adhere to its high expectations.
2. USGBC is currently determining its larger stance on the use of GMOs. Until finalized, this will be a
Distinguishing benchmark through which a certification scheme can exemplify itself from other.
3. Regarding the Chemical use benchmark, with all due respect to the EPA and scientific community,
USGBC is confident in its prescriptiveness and believes it sets a rigorous standard.
4. USGBC intends for schemes to demonstrate how the legal requirements of their contexts meet
the requirements of the benchmark, thus ensuring compliance.
5. Your specific commentary on the SFI and FSC is useful. In the end, a forest certification scheme
will be deemed compliant by an independent, third-party evaluation of its criteria against the Forest
Certification Schemes Benchmarks requirements.
Thank you for your comments. USGBC has not yet determined whether additional certification
schemes will be recognized in LEED. The proposed Forest Certification Scheme Benchmarks are
meant to transparently indicate what USGBC expects from exemplary certification schemes if they
are to be recognized in LEED. You're invited to review the accompanying Conformance Assessment
Process to learn how USGBC will evaluate the schemes against the finalized benchmarks.




Thank you for your comments.




Thank you for your comments. Responses to specific suggestions are as follows:
1. You're invited to review the revised Plantations benchmark, whereby certain exceptions have
been specified. USGBC intends for this revision to both address the concerns of you and other
commentators as well as adhere to its high expectations.
2. USGBC is currently determining its larger stance on the use of GMOs. Until finalized, this will be a
Distinguishing benchmark through which a certification scheme can exemplify itself from other.
3. Regarding the Chemical use benchmark, with all due respect to the EPA and scientific community,
USGBC is confident in its prescriptiveness and believes it sets a rigorous standard.
4. USGBC intends for schemes to demonstrate how the legal requirements of their contexts meet
the requirements of the benchmark, thus ensuring compliance.




Thank you for your comments. Responses to specific suggestions are as follows:
1. You're invited to review the revised Plantations benchmark, whereby certain exceptions have
been specified. USGBC intends for this revision to both address the concerns of you and other
commentators as well as adhere to its high expectations.
2. USGBC is currently determining its larger stance on the use of GMOs. Until finalized, this will be a
Distinguishing benchmark through which a certification scheme can exemplify itself from other.
3. Regarding the Chemical use benchmark, with all due respect to the EPA and scientific community,
USGBC is confident in its prescriptiveness and believes it sets a rigorous standard.
4. The Land Tenure benchmark has been elaborated to require schemes to themselves require that
Thank you for your comments. Responses to specific suggestions are as follows:
1. You're invited to review the revised Plantations benchmark, whereby certain exceptions have
been specified. USGBC intends for this revision to both address the concerns of you and other
commentators as well as adhere to its high expectations.
2. USGBC is currently determining its larger stance on the use of GMOs. Until finalized, this will be a
Distinguishing benchmark through which a certification scheme can exemplify itself from other.
3. Regarding the Chemical use benchmark, with all due respect to the EPA and scientific community,
USGBC is confident in its prescriptiveness and believes it sets a rigorous standard.
4. The Land Tenure benchmark has been elaborated to require schemes to themselves require that
forest operators comply with all legislation relating to property rights. This adheres to your
suggestion about the sufficiency of complying with state and federal laws.
5. Your specific comments on SFI are helpful.
6. Your questions about percentage of benchmarks to meet for compliance are addressed by the
new specification of Required and Distinguishing benchmarks. A scheme must meet at Required
benchmarks and the same number of Distinguishing benchmarks as LEED's currently referenced
scheme, FSC.
Thank you for your comments. Although USGBC has not yet determined whether additional
certification schemes will be recognized in LEED, USGBC will undertake the task of determining
which forest certification scheme meets the requirements of the benchmarks.




Thank you for your comments. USGBC hopes that the clarified and elaborated benchmarks address
all of your concerns about benchmark vagueness and inadequacy. Your specific commentary on
these certification schemes is useful. In the end, a forest certification scheme will be deemed
compliant by an independent, third-party evaluation of its criteria against the Forest Certification
Schemes Benchmarks requirements.
Thank you for your comments.




Thank you for your comments regarding the use of urban wood and the Tree City USA program. In
the end, a forest certification scheme will be deemed compliant by an independent, third-party
evaluation of its criteria against the Forest Certification Schemes Benchmarks requirements. Should
the use of urban wood not be included, a project team might seek an Innovation and Design point
explicitly noting how the strategy is comprehensive, quantifiable, and applicable to other projects.
Please note that the Materials Reuse credit (MRc3 in LEED for New Construction) already awards
one point for the use of salvaged material, in this instance possibly salvaged, dead urban trees.
Thank you for your comments. The benchmarks posted for this 2nd Public Comment Period are
revised to be clearer, better aligned with USGBC's Guiding Principles, and more consistently present
rigorous requirements. Additionally, the proposed credit changes to the certified wood credits and
the accompanying Forest Certification Scheme Benchmarks are intended to ultimately identify a
scheme whose supply of wood comes from exemplary forest management practices. USGBC
intends to maintain the high standards of the current credits.
Thank you for your comments regarding the use of urban wood. The Forest Certification Scheme
Benchmarks (and, indeed, all of LEED) do not exclude the use of urban trees. Indeed, using nearby
wood sources could either earn MRc3: Materials Reuse or MRc5: Regional Materials for a LEED
project. Additionally, it remains within the scope of the certification schemes themselves to
determine the types of forests they certify.


Thank you for your comments. You're invited to review the revised Plantations benchmark, whereby
certain exceptions have been specified. USGBC intends for this revision to both address the
concerns of you and other commentators as well as adhere to its high expectations. The
Governance section of the benchmarks includes a Distinguishing benchmark "Accessibility to diverse
ownership types," in which its "standards and procedures allow small-scale and/or low intensity
operators equitable access to markets for certified forest products, and/or schemes have developed
policies or other measures to improve small producer market access."




Thank you for your comments. USGBC does not intend for any benchmark to be biased towards a
particular forest certification scheme. Instead, USGBC intends for the benchmarks collectively
present the organization's definition of exemplary forest certification in all aspects of a certification
scheme, independent of any one scheme's previously established guidelines. Also, your comments
regarding the specific certification systems are useful. In the end, a forest certification scheme will
be deemed compliant by an independent, third-party evaluation of its criteria against the Forest
Certification Schemes Benchmarks requirements.
be deemed compliant by an independent, third-party evaluation of its criteria against the Forest
Certification Schemes Benchmarks requirements.
Public Comments
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.

FSC IC maintains that the proposed Chain of Custody and Labeling benchmarks address many of the
concerns surrounding non-certified materials. However, the definition of "legality" is limited and the
opportunity to strengthen the policy criteria exists. It is essential that the definition of "legality" be
broadened to include illegal harvest of timber outside of protected areas and better address the
scope of the problem worldwide.
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.

COC and Labeling - Acceptable non-certified sources for percent-based claims As suggested in the
Technical/Standards Substance comments, we believe that USGBC should take a technical position
on this benchmark around viable business cases over the use of genetically modified organisms.

If not, please explain how the existing systems are deficient.
I don't know.

Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Yes. I wonder if there could be an "easy track" for small local producers to follow to get certification
without having the same exhaustive documentation burden.

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?
Yes I believe that FSC does.

If yes, please explain indicate which systems comply and how they are compliant.
Yes I believe that FSC does.
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
No. Please refer to the comprehensive statement submitted to the "Credit Language Revisions"
comments page by the Cascadia Chapter of the USGBC.
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
No. Chain of Custody: which Third Party claims will be accepted by LEED? And if only Third party
claims are accepted, what is the relevance of the following provision: "If other claims (e.g. 1st, 2nd
party) are allowed, labels are designed to avoid possibility of confusion." Under no circumstances,
should manufacturers or trade associations be allowed to self-certify. This loophole eradicates the
program's credibility and the significance of a certification process. Minimum certified material:
one of the most convoluted aspects of the current MRc7 requirements is methodology for
calculating certified wood contributions from assemblies and/or mixed sources. It is quite common
for wood products installed in LEED certified building to fall into one of these two categories. This
should be considered a core issue - and benchmarks are easily conceivable to track. Acceptable
non-certified sources for percentage-based claims: confusing point to make - the current credit does
not allow for any 'recycled' material to count towards the attainment of MRc7. Will this change? Is
this expanding to apply to MRc4: Recycled Content? What is the relevance of this statement?
Verification of non-certified sources: 2nd party verification is not sufficient to verify that illegal

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?

If anything, these benchmarks open the field to too many insufficiently rigourous standards.

If yes, please explain indicate which systems comply and how they are compliant.

If anything, these benchmarks open the field to too many insufficiently rigourous standards.

If not, please explain how the existing systems are deficient.

If anything, these benchmarks open the field to too many insufficiently rigourous standards.
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.

The program needs to include a chain of custody methodology to prevent the use of controversial
wood in a LEED project.The FSC controversial wood standard or equivalent should be used.
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.

Better definitions and interpretation of this benchmark are needed to understand expectations and
intent.For example, the desciption of "forests of special social and environmental conservation
value," requires a definition that includes how such forests are identified and evaluated.
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
No. They are a step backward from the existing FSC standard.

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?
FSC exceeds it and as a part of LEED since it's inception has helped transform the lumber markets.

If yes, please explain indicate which systems comply and how they are compliant.

FSC has adequate chain of custody requirements. Others are less stringent. Come up with a system
that shows others are as stringent (or have equal value to the FSC methodology).

If not, please explain how the existing systems are deficient.
Other systems have not shown ability to meet FSC's level of custody tracking.
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Acceptable non-certified sources for percent-based claims. "No virgin or pre-consumer recycled
wood from 1) non-certified forests of special social and environmental conservation value, 2)
genetically modified organisms and 3) harvesting that converts natural forest to plantations/ non-
forest." Points for USGBC consideration include: ? This benchmark is too closely aligned with the FSC
program and should be modified to avoid system bias. ? Definitions and interpretation of the
benchmark is needed to better understand expectations and intent. ? Do the provisions of sections
1), 2) and 3) apply to non-certified sources and thereby excludes sources that are certified or do
they apply to sources from only those certification programs recognized by USGBC? ? The term
"forests of special social and environmental conservation value" needs to be defined. ? See
comments above on GMO's and plantations. ? A truly neutral benchmark should focus on how the
certification system generally addresses non-certified fiber. As noted above under procurement, we
recommend that this benchmark be expanded to cover the overall treatment of non-certified fiber
in the procurement process, whether it be part of the standard itself or part of the subsidiary chain
of custody standard. Recommended Benchmark: Indicators address procurement of wood fiber

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?
I am not prepared to comment on any particular forest certification system. It was my impression
from the materials supplied by USGBC that the Council was interested in comments on the
proposed benchmarks. I assumed that once the benchmarks were established, USGBC would use
them to assess individual forest certification systems and make a decision as to whether or not
individual systems qualified for certified wood credits under LEED. It seems out of place to be asked
to comment on which certification systems qualify when USGBC has not yet completed their
benchmarks for judging qualifications. Benchmarks should be established independent and separate
from judging any one certification system. Otherwise the benchmarks are open to bias for or against
one or another forest certification system. I am concerned that many of the benchmarks presented
for review by USGBC appear to be pulled directly from the current status quo wood credit certifier,
Forest Stewardship Council. I refer specifically to the Governing board structure, Plantations,
Chemical use, Aboriginal land and tenure rights and Acceptable non-certified sources for percent-
based claims. This practice, of course, creates an immediate bias in the comment process. USGBC
would be better served by following Yale University's lead in their assessment of current
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
No. There needs to be more clarity in what is expected from the chain of custody benchmarks and
what the intent of each is. Comment becomes complicated since the provision in the earlier section
apply to the definition of certified wood in this section. The response is dependent on how the final
benchmarks come out. I am particularly concerned about prohibitions in the chain of custody
section on "acceptable non-certified sources percent-based claims". Without certification or
intensive purchaser investigation, a manufacturer would not know the details of supply. This is not a
workable benchmark. The benchmark on illegal harvest areas should be met by national laws and
legal compliance programs rather that become the responsibility of individual manufacturers. Again,
individual purchasers should not be required to track non-certified material. The two benchmarks:
"Acceptable non-certified sources" and "Definition of legality" should be changed to: "Support for
effective national programs to identify and protect forests of special social and environmental
conservation value; maintain standards and protocol for genetically modified organisms in forestry;
protect natural forest from conversion to non-native species plantation; and prevention of illegal
harvest from protected areas." Process for these (with the exception of GMOs if forestry) are
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.

No, modifications are required. This benchmark is too closely aligned with the FSC program and
should be modified to avoid system bias. Definitions and interpretation of the benchmark is needed
to better understand expectations and intent. Do the provisions of sections 1), 2) and 3) apply to
non-certified sources and thereby excludes sources that are certified or do they apply to sources
from only those certification programs recognized by USGBC? The term "forests of special social and
environmental conservation value" needs to be defined. See comments above on GMO's and
plantations.

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?
Many of the proposed benchmarks are very good, objective criteria, consistent with internationally
recognized assessments for determining the quality of certification systems. The existing
certification systems (FSC, PEFC, SFI, Tree Farm, CSA) should be able to meet the majority of the
benchmarks as currently drafted. USGBC needs to define how points will be awarded and whether
or not partial crediting will be incorporated into the assessments. There are two notable omissions
that should be included in the final set of benchmarks: procurement and continuous improvement:
Procurement The way certification systems handle the non-certified component of the supply chain
should be recognized as a specific benchmark. In the U.S. context, where the bulk of the fiber supply
originates from non-industrial forest landowners and where less then 10% of the commercial forest
land is certified, procurement elements with standards are critical to ensure core tenants of
sustainable forestry are being met throughout the supply chain Continual improvement Continual
improvement drives positive change and should be recognized as a specific benchmark. Continual
improvement is a core element of ISO quality management and environmental management
standards. Continual improvement is supported by the over-riding philosophy and objectives of
Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?
The existing certification systems (FSC, PEFC, SFI, Tree Farm, CSA) should be able to meet the
majority of the benchmarks as currently drafted.

Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
This benchmark is too closely aligned with the FSC program and should be modified to avoid system
bias.
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
VFPA feels, again, that this benchmark is too closely aligned with the FSC program and should be
modified to avoid system bias. Throughout this area definitions and interpretation of the benchmark
is needed to better understand expectations and intent. As an example, do the provisions of
sections 1), 2) and 3) apply to non-certified sources and thereby excludes sources that are certified
or do they apply to sources from only those certification programs recognized by USGBC?
Furthermore, the term "forests of special social and environmental conservation value" needs to be
defined.

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?
Chain of Custody is an accounting system that varies little between the various forest certification
programs.

If yes, please explain indicate which systems comply and how they are compliant.
All chain of custody programs (SFI, PEFC and FSC) track fiber from certified forests, recycled content,
and ensure non-acceptable fiber does not enter the product. In the SFI Standard, Objective 8 has
requirements for responsible procurement. This ensures program participants take measures to
ensure the fiber was harvested legally, meet state, provincial and federal laws regarding threatened
and endangered species, encourage landowners to incorporate actions that identify and protect or
create habitat for wildlife, encourage landowners to reforest harvested lands, both naturally and
through replanting, encourage landowners to protect riparian zones and water quality, implement a
verifiable monitoring system to continually improve the effectiveness of encouraging landowners to
reforest harvested areas and apply best management practices to protect water quality, encourage
landowners to use loggers and resource professionals trained in sustainable forestry practices,
conserve biodiversity hotspots and major tropical wilderness areas outside the U.S. and Canada as
defined by Conservation International, encourage economically, environmentally and socially sound
practices outside the U.S. and Canada. A certification to Objective 8-13 is mandatory for primary
producers, in addition to a CoC certification.

If not, please explain how the existing systems are deficient.
Because this language seems biased towards FSC's controlled wood standard, it puts all other
certification programs as deficient. The non-acceptable sources should be written to avoid
controversial sources from the supply chain (i.e. Illegal Logging), but at the same time reward
programs like SFI's wood fiber procurement system that take a proactive approach that influence
millions of additional acres in North America and globally through the outreach, training and
education programs.

Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Most of the CoC and Labeling benchmarks are appropriate. The following benchmark needs to be
modified: Acceptable non-certified sources for % based claims: This language seems to follow
closely with language from the FSC Standard. This benchmark should be modified to avoid bias.
Plantations: No certification of plantations converted after 2007 unless change in ownership or
program to convert back to natural forest beginning in advance of the next harvest cycle. For this
purpose, the definition of plantations is consistent with the FAO definition. All certification programs
must deal with plantations, whether established or new. Plantations can have a positive benefit.
Prohibiting conversion under the LEED program is not practical given that all certification programs
deal with new and established plantations alike. Rather, the USGBC should support the certification
programs that limit the use of exotics in plantations, and that also ensure that the same
requirements for natural forest management exists for planted stands as well. GMO's: Prohibit the
use of genetically modified organisms. There are no commercially grown GMO's in North America.
However, research is important to the future of the world's forests. Therefore GMO's should not be
banned based on the requirements of one program because research involving biotechnology has
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.

USGBC should establish these benchamrks first beofe making this change. It is good that we are
considering other sustainable wood rating systems to mazimize flexibilty but we need to make sure
the benchmakrs are clear to make the submission process simple and avoid greenwashing.

If not, please explain how the existing systems are deficient.
The SFI BOD is elected by the existing board in a closed process. Thus the social and environmental
decision-makers are hand-selected by the existing board members.

Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
No. Perkins + Will feels that the USGBC should maintain a strong performance standard for Wood
Certification in the LEED rating system. As a reflection of the USGBC's core values, the standard
should require continuous improvement through market transformation and must retain rigorous
social and environmental requirements founded on the best available objective science. A strong
Certified Wood Credit is important because the health of our forest eco-systems and their
inhabitants is vital to the health of our planet and our civilization. Forests cover 30% of the world's
land area and store over 50% of the world's carbon. The Certified Wood credit is the only LEED
credit that explicitly establishes criteria for all three core elements of Sustainability and the Triple
Bottom Line: Environment, Economics and Social Equity. While the intent of moving to a
performance based criteria for the credit language is acceptable, the verification process for
certification is critical for the Benchmark to be successful. It must be objective and transparent. In
addition, the membership should be presented with the process before voting on the final revisions.

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?
Yes

If yes, please explain indicate which systems comply and how they are compliant.
The Forest Stewardship Council is a member organization.
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
No, these proposed changes completely undermines the core value of high performance buildings.
The proposed yes/no vote on an undefined system and process is an insufficient opportunity to
comment upon a complex issue. We are being asked to vote on a benchmark standard that has not
been defined in detail and appears to be lacking critical information. We support the idea of
benchmark criteria if it includes fully developed and consistent criteria that is not in any way "less
than" the current FSC requirement. It appears as though the proposed criteria are inconsistent, not
in accordance with the USGBC's Guiding Principles, and also not consistent with the
recommendations of the Yale report. This blantant disregard will undermine the credibility of USGBC
and will appear that the USGBC lessoned the standards to allow large production forestry
companies to undermine the standards of high-performance buildings. We urge the tag committee,
USGBC board, stakeholders, members, etc to visit the following site for more information:
www.dontbuysfi.com. Why are we proposing to weaken the most riquorous forestry scheme with
one that is diluted and does not appear to offer transperency, openess, disverse govering
stakeholder group.

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?
YES

If yes, please explain indicate which systems comply and how they are compliant.
FSC - THIRD-PARTY VERIFICATION - CHAIN-OF-CUSTODY - ANNUAL AUDITS
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
The benchmark is too closely aligned with the FSC program and should be modified to avoid system
bias. Definitions and interpretation of the benchmark is needed to better understand expectations
and intent.

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?
Do the provisions of sections 1), 2) and 3) apply to non-certified sources and thereby excludes
sources that are certified or do they apply to sources from only those certification programs
recognized by USGBC?
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
We believe that these benchmarks are headed in the right direction. We do feel, however, that once
again, the language is too prescriptive and in particular would limit the ability for a large number of
global certification programs to comply 100% with some benchmarks because that particular
language is not included in their policies, even though their goals and objectives are very much the
same. For example, some certification systems use terminology such as "controlled wood" others
use "non-controversial sources", but all work to ensure that wood is from legal and sustainable
sources. Additionally, we believe it is incorrect to define "legality" as "illegal harvest from protected
areas" only. We suggest that the last benchmark, "Verification of acceptable sources" be removed
and the first two benchmarks be modified to read: Restrictions on non-certified material:
Acceptable non-certified sources for percent-based claims. No virgin or pre-consumer recycled
wood from: 1) illegal or unauthorized sources 2) non-certified forests of special social and
environmental conservation value. 3) genetically-modified organisms, and 4) harvesting that
converts natural forest to plantations / non-forest. Restrictions on non-certified material - Definition
of legality. 1) No wood from illegal harvest 2) Compliance w/CITES

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?

Yes. The four standards used in British Columbia and Canada - the Canadian Standards Association's
Sustainable Forest Management Standard (CSA), the Forest Stewardship Council (FSC), the
Programme for the Endorsement of Forest Certification schemes (PEFC), and the Sustainable
Forestry Initiative (SFI) - all comply with the Chain of Custody and Labelling requirements.

If yes, please explain indicate which systems comply and how they are compliant.

The four standards used in British Columbia and Canada - CSA, FSC, PEFC, and SFI - have a chain-of-
custody option, and associated standard-specific product labels. All chain-of-custody standards
require screening of any uncertified wood sources to ensure they come from legal, authorized and
credible sources. The sources are termed controlled or non-controversial, depending on the
standards, and exclude wood that is illegally harvested, unauthorized, or stolen. All programs offer
labels that indicate certified and/or recycled content.
If not, please explain how the existing systems are deficient.
Not applicable.

If yes, please explain indicate which systems comply and how they are compliant.

FSC certification requires COC and has labeling requirements. I cannot speak to other schemes.

If not, please explain how the existing systems are deficient.
unsure.

Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
No. Not being taken into consideration is the risk-benefit impact to LEED as a result of COC
implementation throughout the value chain for assembled wood products. Acceptance by the
USGBC of a certified wood benchmark system establishing criteria for multiple certification schemes
to achieve recognition by LEED would create confusion and unnecessary expense in the
manufacturing and distribution of assemble certified wood products. This would likely have a
negative affect on the certified wood market currently established for FSC product by LEED. 1. FSC
has always maintained the highest environmental and social green standard and was therefore
recognized by LEED. Many assembled product companies have invested heavily in this certification,
in both time and resources, and have cultivated product lines that bear the FSC label, though a
portion of the wood in these products may not be FSC and is listed as controlled wood. Under the
proposed benchmark system, as components for assembled products come from many sources and
regions, it is most probable that manufacturers would be required to bear the expense and effort
required to secure multiple certifications in order to claim COC for controlled wood (non-FSC)
components certified by another certification scheme. They would have to do so in order to make

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?
Yes. FSC is the one I am most familiar with, and they comply with benchmark requirements, yet the
lack of market segment understanding in the implementation of COC is damaging the adoption of
certified wood by the market place "value-cahin".
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
No. Perkins + Will feels that the USGBC should maintain a strong performance standard for Wood
Certification in the LEED rating system. As a reflection of the USGBC's core values, the standard
should require continuous improvement through market transformation and must retain rigorous
social and environmental requirements founded on the best available objective science. A strong
Certified Wood Credit is important because the health of our forest eco-systems and their
inhabitants is vital to the health of our planet and our civilization. Forests cover 30% of the world's
land area and store over 50% of the world's carbon. The Certified Wood credit is the only LEED
credit that explicitly establishes criteria for all three core elements of Sustainability and the Triple
Bottom Line: Environment, Economics and Social Equity. While the intent of moving to a
performance based criteria for the credit language is acceptable, the verification process for
certification is critical for the Benchmark to be successful. It must be objective and transparent. In
addition, the membership should be presented with the process before voting on the final revisions.

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?
Yes

If yes, please explain indicate which systems comply and how they are compliant.
The Forest Stewardship Council is a member organization

If not, please explain how the existing systems are deficient.
The SFI BOD is elected by the existing board in a closed process. Thus the social and environmental
decision-makers are hand-selected by the existing board members.

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?
The FSC remains the only forestry certification program with a verifiable and responsible COC
program.

Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.

No. The benchmarks are significantly insufficient at addressing chain of custody requirements, illegal
harvest, and unverified material. This will result in increased irresponsible forestry practices.
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Transparency, types of product labels Given that some certification systems allow products to be
labeled as though they come from forests certified by those systems, when in fact the forests of
origin have not been certified by those systems, we believe that the benchmarks must distinguish
credible labeling approaches from those that are not credible. This should be a mandatory
benchmark. Transparency, minimum certified material We disagree with the benchmark's assertion.
A benchmark is needed here, and it should be a mandatory requirement. The benchmark needs to
include a requirement that the extent and nature of all label usage and all label claims are directly
proportionate to the extent to which labeled product lines contain wood from forests fully certified
to the substantive standards of the certification system in question. Currently, some certification
systems allow their labels to be used on product lines whose "certified" content is not from forests
certified to those certification systems' forest management standards. Likewise, some systems allow
their labels to be used more extensively than warranted by the amount of certified wood actually
used as an input to the product lines in question. Both problems call the credibility of label-based
market claims into serious question. This should be a mandatory benchmark. Restrictions on non-

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?
Decline Comment until Benchmark and Process are Defined

If not, please explain how the existing systems are deficient.
Decline Comment until Benchmark and Process are Defined

If yes, please explain indicate which systems comply and how they are compliant.
Decline Comment until Benchmark and Process are Defined
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
General Comments: The section is generally sound, and provides an excellent framework for non-
certified materials. Our primary concern in this section is with regards to the limited definition of
"legality" - which should be expanded to cover the illegal harvest of timber outside of protected
areas. This broader definition is necessary because in countries where illegal logging is widespread,
harvest in parks and preserves is only a small part of a larger problem. Recent revisions to U.S.
federal law (achieved through an amendment to the Lacey Act) that ban the importation of illegally-
harvested timber incorporate this broader definition of illegal logging. Comments on Specific
Benchmarks: Transparency - Types of product labels: No specific benchmark - not considered a core
issue, as long as other benchmarks are met. Some labeling systems are misleading in that wood
products carrying a specific label may actually be certified under a different scheme (with mutual
recognition of the schemes). If these two schemes have differing capacity to qualify for the
benchmarks, this will present a major conflict. The product label should ensure that all wood
products carrying that label have been certified to the standard of that label. Acceptable non-
certified sources for percent-based claims: No virgin or pre-consumer recycled wood from: 1) non-

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?
Decline comment until benchmarks and process are better defined.

If yes, please explain indicate which systems comply and how they are compliant.
Decline comment until benchmarks and process are better defined.

If not, please explain how the existing systems are deficient.
Decline comment until benchmarks and process are better defined.
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
No, definitions need to be developed to better understand the intent.

If yes, please explain indicate which systems comply and how they are compliant.
The Forest Stewardship Council is a member organization."

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?
yes

Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
No. The Criteria for Governance - Openness - Organizational type: "Membership organizations (i.e.
organizations governed by members) are open to all major interest groups, organizations and
individuals." should be changed. Proposed Revision: Membership organizations USGBC should
maintain a strong performance standard for Wood Certification in the LEED rating system. As a
reflection of the USGBC's core values, the standard should require continuous improvement through
market transformation and must retain rigorous social and environmental requirements founded on
the best available objective science. A strong Certified Wood Credit is important because the health
of our forest eco-systems and their inhabitants is vital to the health of our planet and our
civilization. Forests cover 30% of the world's land area and store over 50% of the world's carbon.
The Certified Wood credit is the only LEED credit that explicitly establishes criteria for all three core
elements of Sustainability and the Triple Bottom Line: Environment, Economics and Social Equity.
While the intent of moving to a performance based criteria for the credit language is acceptable, the
verification process for certification is critical for the Benchmark to be successful. It must be
objective and transparent. In addition, the membership should be presented with the process

If not, please explain how the existing systems are deficient.
The SFI BOD is elected by the existing board in a closed process. Thus the social and environmental
decision-makers are hand-selected by the existing board members
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Most of the CoC and Labeling benchmarks are appropriate; however, we suggest the following
benchmark be modified: Proposed Benchmark - Acceptable non-certified sources for % based
claims: non-certified forests of special social and environmental conservation value, 2.) genetically-
modified organisms, and 3.) harvesting that converts natural forest to plantations/ non-forest. 1.)
non-certified forests of special social and environmental conservation value: It is unclear what
constitutes non-certified forests of special social and environmental conservation value. 2.)
genetically-modified organisms: While this section deals specifically with non-certified sources , we
refer back to the Standard Substance section on GMOs, and reiterate our response. Proposed
Benchmark - Genetically-modified organisms: Prohibit use of genetically-modified organisms The
USGBC operates in North America where GMO forest products are not commercially available.
However, the GMO discussion is complicated and evolving as new information comes to light. For
example, biotechnology research can help to find new ways to make trees resistant to insects and
disease that can destroy significant tracts of forest land or restore trees with important ties to North
America's natural heritage, such as the American Chestnut. We would encourage the USGBC to take

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?
Chain of Custody is an accounting system that varies little between the various forest certification
programs. Because the current acceptable non-certified sources language seems to be based on the
FSC controlled wood standard, it is worthwhile to note that FSC does allow exceptions and therefore
one should not make the assumption that since it is the FSC requirement under controlled wood
that FSC abides by these same rules across its standards. For example, the FSC Boreal Standard,
which is responsible for over 60% of the FSC certified area in North America, has an exception under
section 6.10.2 that allows up to 5% of the productive forest to be converted, which is higher than
the rate of conversion in the US and Canada, at 1% and 0% respectively. Please refer to our
comments under the previous section for more information. More importantly, as previously stated,
over half of FSC certifications are in countries where there is no FSC fully endorsed standard.
Moreover, a review of the FSC audit reports reveals that what is a requirement in FSC is not
necessarily a requirement on the ground. On paper, it may appear that FSC does not allow intense
chemical use, or large clearcuts, or conversion to plantations, but upon collective review of FSC
regional standard variations, the lack of fully endorsed standards, and the results of audits, the net

If yes, please explain indicate which systems comply and how they are compliant.
Proposed Benchmark - Compliance with international normative institutions: Claims comply w/ ISO
14020 and 14021 or equivalent. From Annex 2 of the SFI Requirements for Fiber Sourcing, Chain of
Custody and Product Labels: 1.2 References: This standard incorporates by dated or undated
reference, provisions from other publications. These normative references are cited at the
appropriate places in the text and the publications are listed hereafter. For dated and undated
references the latest edition of the publication referred to applies. ISO / IEC Guide 65:1996 General
Requirements for bodies operating product certification systems ISO / IEC Guide 2:1996
Standardization and related activities - General vocabulary ISO 9000:2000 Quality management
systems - Fundamentals and vocabulary ISO 9001:2000 Quality management systems -
Requirements ISO 14001:2004 Environmental Management Systems - Specification with guidance
for use ISO 14020:2000 Environmental labels and declarations - General principles Note: ISO 14021
intended for self-declared environmental claims (Type II environmental labeling). Because the SFI
program is Type I labeling, only ISO 14020 applies. From the July 2008 SFI Auditing Procedures and
Qualifications: 7.2. Public Claims Any public communication by Program Participants shall be
If not, please explain how the existing systems are deficient.
All chain of custody programs (SFI, PEFC and FSC) track fiber from certified forests, recycled content,
and ensures non-acceptable fiber does not enter the product. The USGBC should give credit for
avoiding risky sources of supply (i.e. such as FSC controlled wood, SFI's/PEFC avoidance of
controversial sources as well as SFI's off-shore procurement, but the USGBC should also give
additional credit for being proactive and not just risk adverse on the uncertified lands. For example,
SFI does not stop just at avoiding unacceptable and controversial sources of supply, it asks its
program participants to get proactive when it comes to uncertified content in N. America and raise
the bar on forest management. In the SFI Standard, Objective 8 has requirements for responsible
procurement for fiber within North America and offshore. This is a proactive approach to uncertified
content and helps address the fact that 90% of the world's forests are non-certified. Objective 8 of
the SFI Standard ensures program participants take measures to, among other things: ensure the
fiber was harvested legally; meet state, provincial and federal laws regarding threatened and
endangered species; encourage landowners to incorporate actions that identify and protect or
create habitat for wildlife; encourage landowners to reforest harvested lands, both naturally and
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Most of the CoC and Labeling benchmarks are appropriate. The following benchmark needs to be
modified: Acceptable non-certified sources for % based claims: This language seems to follow
closely, language from the FSC Standard. This benchmark should be modified to avoid bias.
Plantations: No certification of plantations converted after 2007 unless change in ownership or
program to convert back to natural forest beginning in advance of the next harvest cycle. For this
purpose, the definition of plantations is consistent with the FAO definition. All certification programs
must deal with plantations, whether established or new. Plantations can have a positive benefit. For
example, in highly populated areas, they reduce pressure on naturally managed forests, while
providing fiber for the building products we need. Under the SFI Standard, all forest management
requirements, such as biodiversity, water quality, and wildlife habitat are implemented on naturally
regenerating and planted forests alike. The FSC standard has the exceptions listed under Principle
6.10, which allows for conversion under certain circumstances: Forest conversion to plantations or
non-forest land shall not occur, except in circumstances where conversion: a) entails a very limited
portion of the Forest Management Unit; and b) does not occur on High Conservation Value Forest

If yes, please explain indicate which systems comply and how they are compliant.
All chain of custody programs (SFI, PEFC and FSC) track fiber from certified forests, recycled content,
and ensure non-acceptable fiber does not enter the product. In the SFI Standard, Objective 8 has
requirements for responsible procurement. This ensures program participants take measures to
ensure the fiber was harvested legally, meet state, provincial and federal laws regarding threatened
and endangered species, encourage landowners to incorporate actions that identify and protect or
create habitat for wildlife, encourage landowners to reforest harvested lands, both naturally and
through replanting, encourage landowners to protect riparian zones and water quality, implement a
verifiable monitoring system to continually improve the effectiveness of encouraging landowners to
reforest harvested areas and apply best management practices to protect water quality, encourage
landowners to use loggers and resource professionals trained in sustainable forestry practices,
conserve biodiversity hotspots and major tropical wilderness areas outside the U.S. and Canada as
defined by Conservation International, encourage economically, environmentally and socially sound
practices outside the U.S. and Canada. A certification to Objective 8-13 is mandatory for primary
producers, in addition to a CoC certification.

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?

Chain of Custody is an accounting system that varies little between the various forest certification
programs. Because the current acceptable non-certified sources language seems to be based on the
FSC controlled wood standard, at this point, only FSC would qualify.

If not, please explain how the existing systems are deficient.
Because this language seems biased towards FSC's controlled wood standard, it puts all other
certification programs as deficient. The non-acceptable sources should be written to avoid
controversial sources from the supply chain (i.e. Illegal Logging), but at the same time reward
programs like SFI's wood fiber procurement system that take a proactive approach that influence
millions of additional acres in North America and globally through the outreach, training and
education programs.

If yes, please explain indicate which systems comply and how they are compliant.
The systems could comply if this were modified to address controversial sources, and the claims
were revised to accurately indicate best efforts were used, or such sources were minimized, rather
than avoided. Otherwise the claim is misleading.

Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
The benchmarks on non-certified wood are not realistic. I hope the irony is not lost on USGBC
members that wood from their own building sites should be burned or buried rather than used on
site, as it would violate the restriction on conversion.

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?
None of the systems could substantiate a claim that their products do not contain the list in the
benchmark on restrictions on non-certified material.
Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?
2. Chain of Custody ("CoC") is an accounting system that is similar among the primary North
American FC systems. The existing FC programs (PEFC, CSA, ATF, SFI and FSC) should be able to meet
the majority of benchmarks as currently drafted.

Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
1. Many of these proposed benchmarks contain solid, objective criteria, which is consistent with
internationally recognized assessments for determining the quality of certification systems.
However, the alignment with FSC standards concerning High Conservation Value Forests ("HCVF")
ignores the extensive controls provided by government organizations in the U.S. that protect these
areas. The USGBC criteria should take into account the due process and oversights required in the
U.S. for harvesting timber and not use an international standard that proposes to fill the void in the
process that occur in other areas of the world that lack appropriate oversight. As the USGBC reviews
benchmarks for certification, consideration should seriously be given to the fact that this is a North
American program. As such, the USGBC should recognize the extensive controls, due process,
stakeholder input and worker safety and rights that exist in the U.S. USGBC standards and
benchmarks need to recognize our well-developed systems already in place and avoid duplication of
controls that already exist. Although material can enter the product stream for environmentally
irresponsible sources, the Chain of Custody systems, such as SFI and PEFC, are fully capable of
ensuring inappropriate materials are kept out of the product stream and can ensure that LEED

If yes, please explain indicate which systems comply and how they are compliant.
3. The majority of the FC systems should be able to comply.

If not, please explain how the existing systems are deficient.

4. Current language seems biased to exclude programs other than FSC, casting them as somehow
deficient. We encourage the benchmark to recognize and reward programs, such as SFI's wood
procurement system, that take a proactive approach which influences millions of acres in North
America and abroad through training and education.
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
"No. Perkins + Will feels that the USGBC should maintain a strong performance standard for Wood
Certification in the LEED rating system. As a reflection of the USGBC's core values, the standard
should require continuous improvement through market transformation and must retain rigorous
social and environmental requirements founded on the best available objective science. A strong
Certified Wood Credit is important because the health of our forest eco-systems and their
inhabitants is vital to the health of our planet and our civilization. Forests cover 30% of the world's
land area and store over 50% of the world's carbon. The Certified Wood credit is the only LEED
credit that explicitly establishes criteria for all three core elements of Sustainability and the Triple
Bottom Line: Environment, Economics and Social Equity. While the intent of moving to a
performance based criteria for the credit language is acceptable, the verification process for
certification is critical for the Benchmark to be successful. It must be objective and transparent. In
addition, the membership should be presented with the process before voting on the final
revisions."

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?

No. The Criteria for Governance - Openness - Organizational type: "Membership organizations (i.e.
organizations governed by members) are open to all major interest groups, organizations and
individuals." should be changed. Proposed Revision: Membership organizations (i.e. organizations
governed by members) open to all major interest groups, organizations and individuals

If yes, please explain indicate which systems comply and how they are compliant.
The Forest Stewardship Council is a member organization.

If not, please explain how the existing systems are deficient.
The SFI BOD is elected by the existing board in a closed process. Thus the social and environmental
decision-makers are hand-selected by the existing board members.
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.

The benchmark language for this section is appropriate except for the first section referring to
"restrictions on non-certified material." The majority of wood products produced in the United
States are not certified. This is mainly due to private ownership, an established legal system and well-
regulated forests. The current LEED language does not properly address non-certified wood
products that are already responsibly and sustainably produced in the United States.

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?
Credible forest certification systems should meet the majority of the benchmarks set by LEED 2009.
Responsibly managed forests, such as those in the US, that are not certified should be given proper
consideration by the USGBC.

If yes, please explain indicate which systems comply and how they are compliant.
No comment.
If not, please explain how the existing systems are deficient.
No comment.
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.

Chain of custody must be a source to drive forward a product that is eventually 100% certified. In
addition the C of C needs to make sure that all the standards, environmental and social go through
the entire CofC. What sense is there in having paper from the most polluting paper mill in the world
or the most dangerious sawmill in the world be elgible for certification.

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?
Unknown

If yes, please explain indicate which systems comply and how they are compliant.
See above

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?
See above

Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.


(Same comment for all four sections of the proposed benchmarks:) If the proposed benchmarks do
not exclude SFI or other PEFC certification systems, then I think the proposal is okay. If they exclude
these systems, LEED is creating another forest certification system on top of those that already
exist, and it seems to be doing so even though benchmarks are nonexistent, or at least uncommon,
elsewhere in the LEED ratings. I don't know the answer to the following, but are there benchmarks
for harvesting of bamboo, or for modes of transport within the 500-mile radius, or for the
manufacture of bike racks, or for recycling of metals? If, politically, benchmarks are the best way to
appease the FSC-only crowd, then I support them. But, sooner or later, the FSC-only folks are going
to have to accept that there are other schemes that generate sustainable wood products. We
should be rewarding the use of forest products, not acting to restrict them.

If not, please explain how the existing systems are deficient.
See above
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Most CoC appropriate. The benchmarks need modification. Acceptable non-certified sources ...
Needs to be modified to avoid bias. Plantations - all certification programs must deal with
plantations. They can be positive. GMO's - keep options open
Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?
Chain of Custody is an accounting system that varies little between forest certification systems.
Because the current acceptable non-certified sources language seems to be based on the FSC
controlled wood standard only the FSC would qualify.

If yes, please explain indicate which systems comply and how they are compliant.

All chain of custody programs track fiber from certified forests. In the SFI Standard, Objective 8 has
requirements for responsible procurement. This ensures program participants take measures to
ensure harvest fiber meets a variety of social as well as environmental standards.

If not, please explain how the existing systems are deficient.
Because this langauage seems biased towardw FSC's controlled wood standards, it puts all other
certification programs as deficient.

If not, please explain how the existing systems are deficient.
No comment.

Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
No. Once again the benchmarks are biased towards one certification system and should be adjusted
accordingly.

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?
No comment.

If yes, please explain indicate which systems comply and how they are compliant.
No comment.




Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Definitions and interpretative guidance are needed re language governing acceptability of non-
certified sources for percent-based claims. The benchmark favors the FSC program and should be
broader to eliminate bias.
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Most of the CoC and Labeling benchmarks are appropriate. The following benchmark needs to be
modified: Acceptable non-certified sources for % based claims: This language seems to follow
closely with language from the FSC Standard. This benchmark should be modified to avoid bias.
Plantations: No certification of plantations converted after 2007 unless change in ownership or
program to convert back to natural forest beginning in advance of the next harvest cycle. For this
purpose, the definition of plantations is consistent with the FAO definition. All certification programs
must deal with plantations, whether established or new. Plantations can have a positive benefit.
Prohibiting conversion under the LEED program is not practical given that all certification programs
deal with new and established plantations alike. Rather, the USGBC should support the certification
programs that limit the use of exotics in plantations, and that also ensure that the same
requirements for natural forest management exists for planted stands as well. GMO's: Prohibit the
use of genetically modified organisms. There are no commercially grown GMO's in North America.
However, research is important to the future of the world's forests. Therefore GMO's should not be
banned based on the requirements of one program because research involving biotechnology has

If yes, please explain indicate which systems comply and how they are compliant.
All chain of custody programs (SFI, PEFC and FSC) track fiber from certified forests, recycled content,
and ensure non-acceptable fiber does not enter the product. In the SFI Standard, Objective 8 has
requirements for responsible procurement. This ensures program participants take measures to
ensure the fiber was harvested legally, meet state, provincial and federal laws regarding threatened
and endangered species, encourage landowners to incorporate actions that identify and protect or
create habitat for wildlife, encourage landowners to reforest harvested lands, both naturally and
through replanting, encourage landowners to protect riparian zones and water quality, implement a
verifiable monitoring system to continually improve the effectiveness of encouraging landowners to
reforest harvested areas and apply best management practices to protect water quality, encourage
landowners to use loggers and resource professionals trained in sustainable forestry practices,
conserve biodiversity hotspots and major tropical wilderness areas outside the U.S. and Canada as
defined by Conservation International, encourage economically, environmentally and socially sound
practices outside the U.S. and Canada. A certification to Objective 8-13 is mandatory for primary
producers, in addition to a CoC certification.

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?
Chain of Custody is an accounting system that varies little between the various forest certification
programs.

If not, please explain how the existing systems are deficient.
Because this language seems biased towards FSC's controlled wood standard, it puts all other
certification programs as deficient. The non-acceptable sources should be written to avoid
controversial sources from the supply chain (i.e. Illegal Logging), but at the same time reward
programs like SFI's wood fiber procurement system that take a proactive approach that influence
millions of additional acres in North America and globally through the outreach, training and
education programs.
If yes, please explain indicate which systems comply and how they are compliant.
No comment.

If not, please explain how the existing systems are deficient.

The lack of meaningful product label on dimensional lumber products invites confusion at all levels
of distribution and in the field. Homeowners, LEED certifiers, and building inspectors have difficult
(sometimes impossible) to decipher paper documentation as proof of origin of lumber products.
Estimating percent/value of certified wood content is difficult as well as value to be assigned "mixed
content" products. If a meaningful permanent label was applied by producing mill, the label would
serve as producer's warranty (subject to 3rd party inspection) of origin of timber, and with such
label providing permanent and transparent documentation of source throughout lifecycle of
product.

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?
If the proposed program requirements expansion is accepted, that is permanent on-product labeling
as sufficient evidence of chain of custody, existing FSC chain-of-custody procedures will not comply.
Other certification systems are likely to comply.

Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Program requirements should be expanded regarding dimension lumber products, to require an eco-
label identifying the LEED recognized forest certification system certifying the product permanently
marked by the producing mill on the face or side of each piece of dimension lumber. Such
permanent eco-label to serve as proof of wood certification throughout the life-cycle of the lumber
product after it leaves the producing mill. This special recognition of dimension lumber is justified by
its being the core element of all wood frame construction, and a significant portion of wood
products used in all buildings. The current processes for documenting the chain-of-custody of
dimension lumber in the supply chain (after production, from the mill to the construction site) are
constraining the supply of certified wood products to building projects, as documented at the recent
LBMI public forum. There are more than 6,000 suppliers in the US capable of supplying permanently
eco-labeled dimension lumber, but only a small fraction of them are chain-of-custody certificate
holders of any forest certification system. The potential for certified wood to flow through the
construction supply chain would increase multi-fold if this suggestion were accepted. A permanent
eco-label should identify the forest certification scheme of jurisdiction and specific producing mill on
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
No. As a member of the U.S. hardwood lumber industry for over 30 years, I am glad to take this
opportunity to comment on the USGBC Forest Certification Benchmark. Hardwood products grown
and processed in the United States are inherently green and environmentally friendly. The U.S.
Forest Service Forest Inventory Analysis FIA has proven that hardwoods grown in the U.S. come
from forests that are sustainable and have been sustainable for over 50 years. For example, in 2006
only 55.2% of net hardwood growth was removed. Products from hardwoods are some of the most
environmentally friendly of all products and their use should be encouraged by all true
environmentalists. Green certification processes add much cost to the product and must be passed
on to the consumer or taken from the grower. As costs increase consumers have less incentive to
use hardwoods and growers have less incentive to keep their land in forest cover. If the ultimate
goal of USGBC is to improve the environment, and encourage sustainable use of raw materials for
the present and the future while decreasing dependency on fossil fuels, then using a resource such
as hardwoods should be given every advantage and its use should be encourage in building and
design. I suggest that since hardwoods have been proven sustainable scientifically through U. S.
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.

FSC Mixed Source is misrepresenting of what the end user will possibly recieve. 20% of the wood I
believe, is supposed to be FSC, however, as it stands now, as long as 20% of the wood going through
a hardwood flooring plant is FSC wood, the FSC Mixed Source label can be used, even though an end
user might not recieve any FSC wood at all. That is misleading the public.
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
General Comments: The section is generally sound, and provides an excellent framework for non-
certified materials. Our primary concern in this section is with regards to the limited definition of
"legality" - which should be expanded to cover the illegal harvest of timber outside of protected
areas. This broader definition is necessary because in countries where illegal logging is widespread,
harvest in parks and preserves is only a small part of a larger problem. Recent revisions to U.S.
federal law (achieved through an amendment to the Lacey Act) that ban the importation of illegally-
harvested timber incorporate this broader definition of illegal logging. Comments on Specific
Benchmarks: Transparency - Types of product labels: No specific benchmark - not considered a core
issue, as long as other benchmarks are met. Some labeling systems are misleading in that wood
products carrying a specific label may actually be certified under a different scheme (with mutual
recognition of the schemes). If these two schemes have differing capacity to qualify for the
benchmarks, this will present a major conflict. The product label should ensure that all wood
products carrying that label have been certified to the standard of that label. Acceptable non-
certified sources for percent-based claims: No virgin or pre-consumer recycled wood from: 1) non-
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Based on the comments in Credit Language Revision section, we feel it is unnecessary to comment
on specific benchmarks. However, we encourage USGBC to ensure that its final benchmarks are
written to avoid any unfair bias toward one certification system over another. As the different
certification systems are working to address the challenges in certification for the hardwood
community, we urge USGBC to keep the door open for an assessment process that assures a fair and
balanced review of each certification system.
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
The chain of custody system benchmark requires further clarification. USGBC must clarify what is
defined by LEED as a third-party claim. Only systems employing true third-party certification
procedures under ISO standards should be considered as fulfilling this benchmark. Under the ISO
standards, "certification" refers to the written assurance provided by an independent third-party
body that audits an organization's management system and verifies that it conforms to the
requirements of the standard.
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
We believe the USGBC has some additional work that needs to be done to discern or clarify
terminology to avoid confusion. The intent of chain of custody is to give a level of confidence to the
end customer, contractor, specifier and supplier that the material was harvested with the
environment in mind. While 'illegal' may be the term of choice in North America (where there is
generally a very low risk of illegally harvested wood), consideration should be given to the
terminology of the source region. As well, in parts of Canada, areas that have been deemed 'special'
from a social, cultural or environmental perspective are not always removed from the land being
harvested. Special treatment is usually developed for these areas. First Nations groups who gain
access to traditional territories may need to use parts of these 'special' places to their community
benefit, notwithstanding the need for exemplary management. The wood from these areas should
not be seen as 'uncertifiable' just because the forest is special to someone who isn't dependent on
it. In addition, the proposed Benchmarks of 'Restrictions on non-certified material' is very narrowly
defined. It should be changed to something like: Restrictions on non-certified material: Acceptable

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?

Yes. The four standards used in Canada - the Canadian Standards Association's Sustainable Forest
Management Standard (CSA), the Forest Stewardship Council (FSC), the Programme for the
Endorsement of Forest Certification schemes (PEFC), and the Sustainable Forestry Initiative (SFI) - all
comply with the Chain of Custody and Labeling requirements.

If not, please explain how the existing systems are deficient.
n/a

If yes, please explain indicate which systems comply and how they are compliant.
The four standards used in Canada - CSA, FSC, PEFC, and SFI - have a chain-of-custody option, and
associated standard-specific product labels. All chain-of-custody standards require screening of any
uncertified wood sources to ensure they come from legal, authorized and credible sources. The
sources are termed controlled or non-controversial, depending on the standards, and exclude wood
that is illegally harvested, unauthorized, or stolen. All programs offer labels that indicate certified
and/or recycled content.
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.

The restrictions on non-certified material should be simplified and handled in a clear, less-
prescriptive statement. The intent is to ensure that when wood comes from uncertified sources it is
obtained legally through authorized sources, and does not come from sources over which there is
controversy. That may be GMOs in one situation, and land being converted to other uses in another
situation. And it may change over time with new information and society's expectations. We suggest
removing the last two benchmarks ("definition of legality" and "verification of acceptable sources" )
entirely, and focusing the "acceptable non-certified sources for percent based claims" benchmark on
legal and non-controversial sources.

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?
Yes. The major chain of custody systems used in Canada (CSA, FSC, PEFC and SFI) all comply with the
proposed chain of custody and labelling requirements.

If yes, please explain indicate which systems comply and how they are compliant.

CSA, FSC, PEFC and SFI all require screening of any uncertified wood sources to ensure they come
from legal (authorized) and credible, non-controversial sources. This may be called "controlled
wood", "areas of high risk" or "controversial sources". The use of both segregation and percentage-
based methods to calculate certified content is allowed with all of the standards.

If not, please explain how the existing systems are deficient.
Not applicable
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
September 5, 2008 Dear USGBC, The Northern California Chapter of the USGBC (NCC) is pleased to
respond to your invitation to comment on the proposed policy revisions for the Certified Wood
credit(s) in the LEED rating system. The Chapter applauds the USGBC's long history of leadership on
this important issue. To date, the Council's research-based approach and transparent public
consultation process advocating for sustainably produced wood and wood products attaining LEED
points is commendable, and the success of these actions to preserve and enhance forest health has
spawned competitive brands in the market. NCC, and other USGBC chapters such as Cascadia, is
uniquely positioned to comment on this critical issue as our region comprises significant lumber
producing areas in North America, with the largest areas of habitat and biodiversity tied to this
precious resource. Almost daily we are reminded that the economy is tied to the robustness of our
forests. Without a functioning and bio-diverse habitat in alignment with sound forestry practices,
our region would not be what it is today. It is in this context that we are commenting on both the
shift from third-party label recognition to benchmark criteria for the Certified Wood credit(s), and
on the specific criteria that will comprise the proposed set of benchmarks and measurement

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?
September 5, 2008 Dear USGBC, The Northern California Chapter of the USGBC (NCC) is pleased to
respond to your invitation to comment on the proposed policy revisions for the Certified Wood
credit(s) in the LEED rating system. The Chapter applauds the USGBC's long history of leadership on
this important issue. To date, the Council's research-based approach and transparent public
consultation process advocating for sustainably produced wood and wood products attaining LEED
points is commendable, and the success of these actions to preserve and enhance forest health has
spawned competitive brands in the market. NCC, and other USGBC chapters such as Cascadia, is
uniquely positioned to comment on this critical issue as our region comprises significant lumber
producing areas in North America, with the largest areas of habitat and biodiversity tied to this
precious resource. Almost daily we are reminded that the economy is tied to the robustness of our
forests. Without a functioning and bio-diverse habitat in alignment with sound forestry practices,
our region would not be what it is today. It is in this context that we are commenting on both the
shift from third-party label recognition to benchmark criteria for the Certified Wood credit(s), and
on the specific criteria that will comprise the proposed set of benchmarks and measurement

If yes, please explain indicate which systems comply and how they are compliant.
September 5, 2008 Dear USGBC, The Northern California Chapter of the USGBC (NCC) is pleased to
respond to your invitation to comment on the proposed policy revisions for the Certified Wood
credit(s) in the LEED rating system. The Chapter applauds the USGBC's long history of leadership on
this important issue. To date, the Council's research-based approach and transparent public
consultation process advocating for sustainably produced wood and wood products attaining LEED
points is commendable, and the success of these actions to preserve and enhance forest health has
spawned competitive brands in the market. NCC, and other USGBC chapters such as Cascadia, is
uniquely positioned to comment on this critical issue as our region comprises significant lumber
producing areas in North America, with the largest areas of habitat and biodiversity tied to this
precious resource. Almost daily we are reminded that the economy is tied to the robustness of our
forests. Without a functioning and bio-diverse habitat in alignment with sound forestry practices,
our region would not be what it is today. It is in this context that we are commenting on both the
shift from third-party label recognition to benchmark criteria for the Certified Wood credit(s), and
on the specific criteria that will comprise the proposed set of benchmarks and measurement
If not, please explain how the existing systems are deficient.
September 5, 2008 Dear USGBC, The Northern California Chapter of the USGBC (NCC) is pleased to
respond to your invitation to comment on the proposed policy revisions for the Certified Wood
credit(s) in the LEED rating system. The Chapter applauds the USGBC's long history of leadership on
this important issue. To date, the Council's research-based approach and transparent public
consultation process advocating for sustainably produced wood and wood products attaining LEED
points is commendable, and the success of these actions to preserve and enhance forest health has
spawned competitive brands in the market. NCC, and other USGBC chapters such as Cascadia, is
uniquely positioned to comment on this critical issue as our region comprises significant lumber
producing areas in North America, with the largest areas of habitat and biodiversity tied to this
precious resource. Almost daily we are reminded that the economy is tied to the robustness of our
forests. Without a functioning and bio-diverse habitat in alignment with sound forestry practices,
our region would not be what it is today. It is in this context that we are commenting on both the
shift from third-party label recognition to benchmark criteria for the Certified Wood credit(s), and
on the specific criteria that will comprise the proposed set of benchmarks and measurement
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.

No. Transparency - Types of product labels - No specific benchmark - not considered a core issue, as
long as other benchmarks are met. Proposed Revision: (Require labeling system based upon FSC)
Transparency Minimum certified material - No specific benchmark - not considered a core issue, as
long as other benchmarks are met. Proposed Revision: (Require labeling system based upon FSC)
Restrictions on non-certified material Definition of legality* - 1) No wood from illegal harvest in
protected areas. 2) Compliance w/ CITES. Proposed Revision: (Use FSC Criteria: Compliance w/
tenure and use rights, planning, royalties, transportation requirements. Low risk of systematic legal
violations. Compliance w/ CITES.)

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?
Yes

If yes, please explain indicate which systems comply and how they are compliant.
FSC
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
This benchmark is too closely aligned with the FSC program and should be modified to avoid system
bias. Definitions and interpretation of the benchmark is needed to better understand expectations
and intent. The chain of custody system benchmark requires further clarification. USGBC must
clarify what is defined by LEED as a third-party claim. Only systems employing true third-party
certification procedures under ISO standards should be considered as fulfilling this benchmark.
Under the ISO standards, "certification" refers to the written assurance provided by an independent
third-party body that audits an organization's management system and verifies that it conforms to
the requirements of the standard. Do the provisions of sections 1), 2) and 3) apply to non-certified
sources and thereby excludes sources that are certified or do they apply to sources from only those
certification programs recognized by USGBC? The term "forests of special social and environmental
conservation value" needs to be defined.
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.

Restrictions on non-certified material: The third benchmark under this title ("Verification of
acceptable sources") seems to be about wood imported from other countries, and Canada is a low
risk country. However, illegal logging is the real issue here, and illegal logging is actually covered
above under "Definition of legality". But it is wrong (misleading) to be defining legality as illegal
harvest from protected areas only. Therefore we suggest deleting the last benchmark ("Verification
of acceptable sources") entirely, and changing the first two benchmarks to read as follows:
Restrictions on non-certified material - Acceptable non-certified sources for percent-based claims.
No virgin or pre-consumer recycled wood from: 1) illegal or unauthorized sources 2) non-certified
forests of special social and environmental conservation value. 3) genetically-modified organisms,
and 4) harvesting that converts natural forest to plantations / non-forest. Restrictions on non-
certified material - Definition of legality. 1) No wood from illegal harvest (delete-in protected areas)
2) Compliance with CITES

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?
yes

If yes, please explain indicate which systems comply and how they are compliant.
The CSA forest certification program meets these requirements. It includes Chain of Custody (CSA
has adopted the PEFC Annex 4) and product marking components that link the CSA forest
management standard to forest products and consumers. This provides a measure of the portion of
a wood product that has been sourced from a certified forest and assurance that any uncertified
portion is from legal and non-controversial sources.

If not, please explain how the existing systems are deficient.
Not Applicable
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
LEED Certified Wood, Forest Certification System Benchmark The following comments represent the
position of the State of Oregon by and through the Oregon Department of Forestry, Oregon Forest
Resources Institute, and the Oregon Department of Energy. More information relevant to these
comments is available upon request. The State of Oregon does not support elements of the
proposed forest certification system benchmark that essentially restate Forest Stewardship Council
standards. The USGBC is encouraged to coordinate with the international Programme for the
Endorsement of Forest Certification (PEFC). PEFC already has a mature system for evaluating forest
certification systems in place and has established itself as the dominant global organization for this
purpose. Rather than developing a redundant new system for evaluating certification systems,
USGBC should consider developing an alliance with PEFC. The Oregon Board of Forestry has also
developed draft Oregon principles and recommended elements for the evaluation of voluntary,
market-based, forest management certification systems. The USGBC is encouraged to consult these
principles and elements and incorporate them where applicable into the proposed Benchmarks.
Important Oregon principles applicable to Chain of Custody and Labeling are described below: Chain
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
I think Chain of Custoday certification is not at all realistic. First, there are not many, if any at all that
can truly say that every step of the process, from tree to finished product, has included an FSC
certified entity. From landowner to logger to sawmiller to product manufacturer to distibution yard
to broker. Every step, really? This is extremely difficult to PROVE. And the FSC does not require that
the actual wood you are using in a project is FSC certified. Only a percentage of the wood that
particular FSC certified business says it has inventoried as certified. So, what does that label really
mean? It's just that...a label. But, according to the current LEED requirements and the FSC, as long as
that "label" is attached, it may as well come from heaven above. I think chain of custody
certification allows for fibbing, and manipulating the numbers, to allow an entity to claim FSC
certification. In reality all American grown trees come from sustainable sources. If they didn't the
industry would not continue to support itself by continuting to grow more wood than is harvested
each year. In conclusion, I am not in favor of the Chain of Custody certification method, however, I
am also against restricting the certification program to be limited to FSC. I think it's unfair and

If not, please explain how the existing systems are deficient.
N/A

Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Yes, however some of the language used in some benchmarks is not generic enough and is
reminiscent of a specific scheme rather than descriptive of a general concept. For example, the term
"controlled wood" is associated with the FSC standard while others used "non-controversial
sources". The commonality resides in their aim to exclude illegally harvested wood and wood from
unsustainably managed areas. On that point, it seems reasonable that, for the "Policy Criterion" of
"Acceptable non-certified sources for percent-based claims", the benchmark should also exclude
wood from "illegal or unauthorized sources" in addition to the three currently listed. Similarly, for
the criterion of "Definition of legality", the specification of "in protected areas" should be removed
from the benchmark to ensure all wood from illegal or unauthorized sources is excluded and not
only illegal wood that comes from protected areas.

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?
Yes. The four standards in use in British Columbia (Canadian Standards Association - CSA, Forest
Stewardship Council - FSC, Sustainable Forestry Initiative - SFI, Programme for the Endorsement of
Forest Certification schemes - PEFC) all comply with the Chain of Custody and Labelling
requirements listed.

If yes, please explain indicate which systems comply and how they are compliant.

The four standards in use in British Columbia (Canadian Standards Association - CSA, Forest
Stewardship Council - FSC, Sustainable Forestry Initiative - SFI, Programme for the Endorsement of
Forest Certification schemes - PEFC) have a Chain of Custody option and associated specific product
labels requirements. All require screening uncertified wood to ensure it comes from legal and
credible sources. All exclude wood illegally harvested or stolen. All programs offer labels that
indicate certified and/or recycled content.
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
WTCA - Representing the Structural Building Components Industry comment: With respect to the
benchmarks involving the acceptable non-certified sources for percent-based claims, WTCA believes
that the three criteria for virgin or pre-consumer recycled wood are vague as written. What is meant
by each of these three criteria should be precisely defined to prevent confusion over this
requirement. With respect to the entire Chain of Custody and Labeling section, if there are items
that do not have a specific standardized benchmark that can be measured or quantified in a specific
manner, WTCA believes they should be removed. Additionally, if items do not relate specifically to
forest certifications, they should be removed. For instance, if items not considered "core issues,"
why are they included? We believe that they should not be. Finally all benchmarks should be fully
defined and standardized using a consensus standard development procedure (e.g. ANSI, ASTM,
etc.). With respect to the entire Chain of Custody and Labeling section, it is clear that the
benchmarks presented are largely based on FSC certification criteria, which WTCA believes is
inappropriate. If the process of evaluating forest certification programs is to be done in an unbiased
manner, the criteria or benchmarks cannot be based on or driven by FSC, and should be based on a

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?
WTCA - Representing the Structural Building Components Industry has no comment.

If yes, please explain indicate which systems comply and how they are compliant.
WTCA - Representing the Structural Building Components Industry has no comment.

If not, please explain how the existing systems are deficient.
WTCA - Representing the Structural Building Components Industry has no comment.
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
This benchmark is too closely aligned with the FSC program and should be modified to avoid system
bias and allow greater opportunity for other certification programs which achieve the desired
outcomes to be considered.
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.

The language is too prescriptive and in particular would limit the ability for a large number of global
certification programs to comply 100% with some of the benchmarks because that particular
language is not included in their policies, even though their goals and objectives are very much the
same . For example, some systems use the term " controlled wood" others use "non-controversial
sources", but all work to ensure that wood is from legal and sustainable sources. Need to define the
term " forests of special social and environmental conservation value".

If not, please explain how the existing systems are deficient.
This should be determined through an independent evaluation, conducted by experts familiar with
all certification systems

Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Chain of custody system: 1st and 2nd party CoC should not be permitted. Third-party auditing is
critical to the integrity of the system. Labeling of certified products must only happen as a result of,
and in compliance with, a third-party audit process. It is impossible for LEED teams to verify claims
for each situation, ergo a third-party claim is required. Without this level of verification, a certified
label is meaningless and should not be eligible for recognition under LEED. As with LEED itself, the
third-party verification and labeling process is key to its credibility. Should also include requirements
for tracking the origin of wood products, to ensure they come from the specific forests they are
attributed to, to ensure those forests have been fully certified by the certification system in
question, and to ensure that those forests are managed in the manner being claimed. Types of
product labels: Benchmark should include requirement that labeling is only permitted for products
whose origin has been certified by the system that is labeling the product. Minimum cert'd content:
Benchmark should include requirement that labeling is only permitted for products whose origin has
been certified by the system that is labeling the product. A minimum threshold should be specified
before labeling is permitted. Acceptable non-cert'd sources: This benchmark should apply to all

If yes, please explain indicate which systems comply and how they are compliant.
This should be determined through an independent evaluation, conducted by experts familiar with
all certification systems

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?
This should be determined through an independent evaluation, conducted by experts familiar with
all certification systems

If not, please explain how the existing systems are deficient.
Current language needs to be expanded to include other CoC certification programs.

Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Yes.

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?
Chain of Custody is in all of the programs and needs to be accepted by the USGBC.

If yes, please explain indicate which systems comply and how they are compliant.
All programs track fiber.

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?
Yes, SFI and FSC are compliant.

Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Yes,

If yes, please explain indicate which systems comply and how they are compliant.
FSC and SFI are compliant with chain of custody certification and tracking. As is the forest
certification, the audits are conducted through third party independent audits that are transparent
and have identification of levels of non-certified material.

If not, please explain how the existing systems are deficient.
They are compliant.

If not, please explain how the existing systems are deficient.
The lack of meaningful product label on dimension lumber products invites confusion at all levels of
distribution and in the field. Homeowners, LEED certifiers, and building inspectors have difficulty
(sometimes impossible) to decipher paper documentation as proof of origin of lumber products.
Estimating percent/value of certified wood content is difficult as well as value to be assigned "mixed
content" products. If a meaningful permanent label were applied by producing mill, the label would
serve as producer's warranty (subject to 3rd party inspection) of origin of timber, and with such
label providing permanent and transparent documentation of source throughout lifecycle of
product.

Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
No. Program requirements should be expanded regarding dimension lumber products, to require an
eco-label identifying the LEED recognized forest certification system certifying the product
permanently marked by the producing mill on the face or side of each piece of dimension lumber.
Such permanent eco-label to serve as proof of wood certification throughout the life-cycle of the
lumber product after it leaves the producing mill. This special recognition of dimension lumber is
justified by its being the core element of all wood frame construction, and a significant portion of
wood products used in all buildings. The current processes for documenting the chain-of-custody of
dimension lumber in the supply chain (after production, from the mill to the construction site) are
constraining the supply of certified wood products to building projects, as documented at the recent
LBMI public forum. There are more than 8,000 suppliers in the US capable of supplying permanently
eco-labeled dimension lumber, but only a small fraction of them are chain-of-custody certificate
holders of any forest certification system. The potential for certified wood to flow through the
construction supply chain would increase multi-fold if this suggestion were accepted. A permanent
eco-label should identify the forest certification scheme of jurisdiction and specific producing mill on

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?

If the proposed program requirements expansion is accepted, that is permanent on-product labeling
as sufficient evidence of chain of custody, existing FSC chain-of-custody procedures will not comply.
SFI procedures will comply, and other certification systems are likely to comply.

If yes, please explain indicate which systems comply and how they are compliant.
No comment.

If yes, please explain indicate which systems comply and how they are compliant.
The Western Red Cedar Lumber Association supports and endorses the comments submitted by
Forestry Innovation Investment on this point: namely that "The four standards used in British
Columbia and Canada - CSA, FSC, PEFC, and SFI - have a chain-of-custody option, and associated
standard-specific product labels. All chain-of-custody standards require screening of any uncertified
wood sources to ensure they come from legal, authorized and credible sources. The sources are
termed controlled or non-controversial, depending on the standards, and exclude wood that is
illegally harvested, unauthorized, or stolen. All programs offer labels that indicate certified and/or
recycled content."

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?

The Western Red Cedar Lumber Association supports and endorses the comments submitted by
Forestry Innovation Investment on this point: namely that "The four standards used in British
Columbia and Canada - the Canadian Standards Association's Sustainable Forest Management
Standard (CSA), the Forest Stewardship Council (FSC), the Programme for the Endorsement of Forest
Certification schemes (PEFC), and the Sustainable Forestry Initiative (SFI) - all comply with the Chain
of Custody and Labelling requirements."

Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
The Western Red Cedar Lumber Association supports and endorses the comments submitted by
Forestry Innovation Investment on this point: namely that "We believe that these benchmarks are
headed in the right direction. We do feel, however, that once again, the language is too prescriptive
and in particular would limit the ability for a large number of global certification programs to comply
100% with some benchmarks because that particular language is not included in their policies, even
though their goals and objectives are very much the same. For example, some certification systems
use terminology such as "controlled wood" others use "non-controversial sources", but all work to
ensure that wood is from legal and sustainable sources. Additionally, we believe it is incorrect to
define "legality" as "illegal harvest from protected areas" only. We suggest that the last benchmark,
"Verification of acceptable sources" be removed and the first two benchmarks be modified to read:
Restrictions on non-certified material: Acceptable non-certified sources for percent-based claims.
No virgin or pre-consumer recycled wood from: 1) illegal or unauthorized sources 2) non-certified
forests of special social and environmental conservation value. 3) genetically-modified organisms,
and 4) harvesting that converts natural forest to plantations / non-forest. Restrictions on non-

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?

If the proposed program requirements expansion is accepted, that is permanent on-product labeling
as documentation of certification (as lumber grade stamp documents Grade Rules), existing FSC
chain-of-custody procedures will not comply. Other certification systems are likely to comply.

If yes, please explain indicate which systems comply and how they are compliant.
No comment.
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Program requirements should be expanded regarding dimension lumber products, to require an eco-
label identifying the LEED recognized forest certification system certifying the product permanently
marked by the producing mill on the face or side of each piece of dimension lumber. Such
permanent eco-label to serve as proof of wood certification throughout the life-cycle of the lumber
product after it leaves the producing mill. This special recognition of dimension lumber is justified by
its being the core element of all wood frame construction, and a significant portion of wood
products used in all buildings. The current processes for documenting the chain-of-custody of
dimension lumber in the supply chain (after production, from the mill to the construction site) are
constraining the supply of certified wood products to building projects, as documented at the recent
LBMI public forum. There are more than 8,000 suppliers in the US capable of supplying permanently
eco-labeled dimension lumber, but only a small fraction of them are chain-of-custody certificate
holders of any forest certification system. The potential for certified wood to flow through the
construction supply chain would increase multi-fold if this suggestion were accepted. A permanent
eco-label should identify the forest certification scheme of jurisdiction and specific producing mill on

If not, please explain how the existing systems are deficient.

The lack of meaningful product label on dimensional lumber products invites confusion at all levels
of distribution and in the field. Homeowners, LEED certifiers, and building inspectors have difficult
(sometimes impossible) to decipher paper documentation as proof of origin of lumber products.
Estimating percent/value of certified wood content is difficult as well as value to be assigned "mixed
content" products. If a meaningful permanent label was applied by producing mill, the label would
serve as producer's warranty (subject to 3rd party inspection) of origin of timber, and with such
label providing permanent and transparent documentation of source throughout lifecycle of
product.
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Approx. 70% of cerified wood is available from PEFC. The two largest forestry programs in North
America SFI and CSA are situated under the PEFC umbrella and create a central source for certified
timber in North America. Accepting PEFC certified wood products would open a tremendous new
resource pool for the green builing movement.

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?

Chain of custody is an accounting system that varies little between different certification programs.

If yes, please explain indicate which systems comply and how they are compliant.
PEFC - Chain of Custody certification PEFC - Chain of Custody certification is an assessment from an
independent, qualified and accredited expert who verifies in writing that the wood flow accounting
system applied by an enterprise to trace the flow of wood from certified forests through the
enterprise, meets the exacting requirements of the certification scheme. A wood-processing
enterprise, business-to business customer/supplier, trader or retailer who has put in place an
independently certified wood flow verification system can reassure customers that its product
sources are verifiable. The chain of custody certificate and associated documentation will inform the
customer on, the next enterprise in the chain, about the proportion of wood in the products from
certified sources. To make the system work effectively for all in the industry, your enterprise should
also have a certified chain of custody. Any enterprise interested in using a product label showing
that their wood has come from a certified forest must have implemented and be using an
independently certified system to monitor the origin of the wood. The wood's origin can be traced
in two different ways: by using a so-called percentage model (based on inventory control and the
accounting of wood/material flows) or by physical segregation of wood. These can be applied to a

If not, please explain how the existing systems are deficient.
-
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
LUMBER ASSOCIATION Of California & Nevada 3130 Fite Circle, Sacramento CA 95827 Telephone
916/369-7501 Fax 916/369-8271 www.lumberassociation.org September 1, 2008 US Green Building
Council 1800 Massachusetts Avenue NW, Suite 300 Washington DC 20036 RE: Revisions to LEED
certified wood credit Ladies and gentlemen: The Lumber Association of California & Nevada (LACN)
is pleased to offer its comments on the proposed changes in the LEED Green Building Rating System
expanding access to LEED credit to additional wood certification systems. LACN is a regional trade
association composed of approximately 270 lumber dealers (including those with multiple locations)
and an additional 200 wholesalers, suppliers and others who have a connection to the wood
products and building materials industry. LACN supports the changes allowing expanded access; and
further supports criteria that would include standards of sustainable and responsible forestry, the
ability to track products along the supply chain, and provide for independent third party verification
procedures. LACN understands and agrees that it is increasingly important for consumers to be
assured the building products they purchase are produced responsibly. A number of the wood
certification systems have requirements on harvesting methods, ensuring sustainability,

If not, please explain how the existing systems are deficient.
Because this language seems biased towards FSC's controlled wood standard, it puts all other
certification programs as deficient. The non-acceptable sources should be written to avoid
controversial sources from the supply chain (i.e. Illegal Logging), but at the same time reward
programs like SFI's wood fiber procurement system that take a proactive approach that influence
millions of additional acres in North America and globally through the outreach, training and
education programs.

Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Most of the CoC and Labeling benchmarks are appropriate. The following benchmark needs to be
modified: Acceptable non-certified sources for % based claims: This language seems to follow
closely, language from the FSC Standard. This benchmark should be modified to avoid bias.
Plantations: No certification of plantations converted after 2007 unless change in ownership or
program to convert back to natural forest beginning in advance of the next harvest cycle. For this
purpose, the definition of plantations is consistent with the FAO definition. All certification programs
must deal with plantations, whether established or new. Plantations can have a positive benefit. For
example, in highly populated areas, they reduce pressure on naturally managed forests, while
providing fiber for the building products we need. Under the SFI Standard, all forest management
requirements, such as biodiversity, water quality, and wildlife habitat are implemented on naturally
regenerating and planted forests alike. The FSC standard has the exceptions listed under Principle
6.10, which allows for conversion under certain circumstances: Forest conversion to plantations or
non-forest land shall not occur, except in circumstances where conversion: a) entails a very limited
portion of the Forest Management Unit; and b) does not occur on High Conservation Value Forest

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?

Chain of Custody is an accounting system that varies little between the various forest certification
programs. Because the current acceptable non-certified sources language seems to be based on the
FSC controlled wood standard, at this point, only FSC would qualify.

If yes, please explain indicate which systems comply and how they are compliant.
All chain of custody programs (SFI, PEFC and FSC) track fiber from certified forests, recycled content,
and ensure non-acceptable fiber does not enter the product. In the SFI Standard, Objective 8 has
requirements for responsible procurement. This ensures program participants take measures to
ensure the fiber was harvested legally, meet state, provincial and federal laws regarding threatened
and endangered species, encourage landowners to incorporate actions that identify and protect or
create habitat for wildlife, encourage landowners to reforest harvested lands, both naturally and
through replanting, encourage landowners to protect riparian zones and water quality, implement a
verifiable monitoring system to continually improve the effectiveness of encouraging landowners to
reforest harvested areas and apply best management practices to protect water quality, encourage
landowners to use loggers and resource professionals trained in sustainable forestry practices,
conserve biodiversity hotspots and major tropical wilderness areas outside the U.S. and Canada as
defined by Conservation International, encourage economically, environmentally and socially sound
practices outside the U.S. and Canada. A certification to Objective 8-13 is mandatory for primary
producers, in addition to a CoC certification.
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Wisconsin Division of Forestry believes this benchmark is too closely aligned with the FSC program
and should be modified to avoid system bias. Definitions and interpretation of the benchmark is
needed to better understand expectations and intent. The chain of custody system benchmark
requires further clarification. USGBC must clarify what is defined by LEED as a third-party claim. Only
systems employing true third-party certification procedures under ISO standards should be
considered as fulfilling this benchmark. Under the ISO standards, "certification" refers to the written
assurance provided by an independent third-party body that audits an organization's management
system and verifies that it conforms to the requirements of the standard. Do the provisions of
sections 1), 2) and 3) apply to non-certified sources and thereby excludes sources that are certified
or do they apply to sources from only those certification programs recognized by USGBC? The term
"forests of special social and environmental conservation value" needs to be defined.
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
THis benchmark should be modified to strengthen definitions and include them where they don't
exist.
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Most of the CoC and Labeling benchmarks are appropriate. The following benchmark needs to be
modified: · Acceptable non-certified sources for % based claims: This language seems to follow
closely, language from the FSC Standard. This benchmark should be modified to avoid bias. ·
Plantations: No certification of plantations converted after 2007 unless change in ownership or
program to convert back to natural forest beginning in advance of the next harvest cycle. For this
purpose, the definition of plantations is consistent with the FAO definition. All certification programs
must deal with plantations, whether established or new. Plantations can have a positive benefit. For
example, in highly populated areas, they reduce pressure on naturally managed forests, while
providing fiber for the building products we need. Under the SFI Standard, all forest management
requirements, such as biodiversity, water quality, and wildlife habitat are implemented on naturally
regenerating and planted forests alike. The FSC standard has the exceptions listed under Principle
6.10, which allows for conversion under certain circumstances: Forest conversion to plantations or
non-forest land shall not occur, except in circumstances where conversion: a) entails a very limited
portion of the Forest Management Unit; and b) does not occur on High Conservation Value Forest

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?

Chain of Custody is an accounting system that varies little between the various forest certification
programs. Because the current acceptable non-certified sources language seems to be based on the
FSC controlled wood standard, at this point, only FSC would qualify.

If yes, please explain indicate which systems comply and how they are compliant.
All chain of custody programs (SFI, PEFC and FSC) track fiber from certified forests, recycled content,
and ensure non-acceptable fiber does not enter the product. In the SFI Standard, Objective 8 has
requirements for responsible procurement. This ensures program participants take measures to
ensure the fiber was harvested legally, meet state, provincial and federal laws regarding threatened
and endangered species, encourage landowners to incorporate actions that identify and protect or
create habitat for wildlife, encourage landowners to reforest harvested lands, both naturally and
through replanting, encourage landowners to protect riparian zones and water quality, implement a
verifiable monitoring system to continually improve the effectiveness of encouraging landowners to
reforest harvested areas and apply best management practices to protect water quality, encourage
landowners to use loggers and resource professionals trained in sustainable forestry practices,
conserve biodiversity hotspots and major tropical wilderness areas outside the U.S. and Canada as
defined by Conservation International, encourage economically, environmentally and socially sound
practices outside the U.S. and Canada.

If not, please explain how the existing systems are deficient.
Because this language seems biased towards FSC's controlled wood standard, it puts all other
certification programs as deficient. The non-acceptable sources should be written to avoid
controversial sources from the supply chain (i.e. Illegal Logging), but at the same time reward
programs like SFI's wood fiber procurement system that take a proactive approach that influence
millions of additional acres in North America and globally through the outreach, training and
education programs.

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?
Yes, the CSA User Group members believe that the CSA SFM certification program chain of custody
and labelling provisions meet the benchmark requirements.

If yes, please explain indicate which systems comply and how they are compliant.
The CSA SFM certification program has adopted the PEFC Annex 4 Chain of Custody of Forest Based
Products Requirements and the accompanying logo use rules. Annex 4 is in compliance with ISO
rules and requires third-party verification. Appendix 7 of Annex 4 details requirements for avoiding
the procurement of raw material from controversial sources, including the provisions for carrying
out a risk assessment.

Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
We suggest that the benchmark structure could be simplified by omitting those Policy Criteria which
are not considered core issues. Restrictions on non-certified material - Acceptable non-certified
sources for percent-based claims: This benchmark is very prescriptive and precludes using wood
from "non-certified forests of special social and environmental conservation value" with no measure
of whether these special values are at risk. We suggest that this benchmark be removed. The next
two benchmarks deal with non-certified material in a more reasonable way. The real concern for the
non-certified material is legality and is there provision for a risk assessment to ensure that
important vales are not at risk. Restrictions on non-certified material - Definition of legality: This
benchmark should be amended to state no wood from illegal harvest period, not just in protected
areas.

If not, please explain how the existing systems are deficient.
The CSA User Group believes that the CSA SFM standard is not deficient.
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.


Most CoC and Labeling benchmarks appear reasonable and appropriate. Language related to
acceptable non-certified sources for percentage based claims appear to follow FSC Standard
language, especially as related to plantations and should be reviewed closely. The non-acceptable
sources should be written to avoid controversial sources from the supply chain (i.e., illegally logged)
but at the same time reward programs like SFI's wood procurement system that takes a positive
approach to influence millions of additional acres in North America through outreach, training and
educational programs. In summary, we would also like to express our support for the comments
submitted directly on this subject from Kathy Abusow at the Sustainable Forestry Initiative Program.
We look forward to future opportunities for input to the process.
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
We are concerned that the wording of this chapter could lead to the exclusion of locally derived and
produced wood due simply to the producer's inability to absorb the costs of compliance with chain-
of-custody documentation requirements. On the one hand, we continue to be concerned that
systems such as FSC which have overly cumbersome COC requirements will discourage otherwise
entirely preferably forest products from entering local markets. Thus, we would like clarification be
provided for evaluating the appropriateness of a chain-of-sustody standard. Perhaps a universally
recognized standard such as ISO could be of benefit. On the other hand, we are concerned that the
language is far too ambiguous with respect to providing metrics for consideration, in particular the
reference to "forests of special social and environmental conservation value" lends itself to local
interpretation as determined by an auditor and without the benefit of mutual discourse and
subesequent consensus. (In other words, this phrase is ripe for abuse from an individual's desire to
impose his own discriminatory interpretation of its meaning. What one person may claim should be
regarded as "special" could be widely regarded within the broader communities of forest

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?
n/a

If yes, please explain indicate which systems comply and how they are compliant.
n/a

If not, please explain how the existing systems are deficient.
n/a
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.

The NRLA is confident that responsible, consensus, and scientifically based certification systems
should be capable of meeting the Chain of Custody and Labeling standards. However, there is some
concern with the policy criteria requiring no virgin or pre-consumer recycled wood be from forest of
"special social and environmental conservation value." This description is broad and could only
result in subjective interpretation.

If yes, please explain indicate which systems comply and how they are compliant.
No comment.

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?

The NRLA is encouraged by the proposed revisions to the LEED standard and believes they are a sign
of movement in a positive direction. With minor amendments to the proposed revisions, several
additional existing internationally recognized certification systems should meet the requirements.
The NRLA would emphasize that should these existing certification systems meet the newly created
benchmarks they should be eligible and awarded equal credit as FSC under MR 7.

If not, please explain how the existing systems are deficient.
No comment.
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
No. The Chain of Custody (CoC) and Labelling requirements in the benchmark document do not
adequately ensure that a labelled product can be tracked back through the supply chain. A forest
certification system could have the most rigorous requirements for forest management, but if the
fibre from that forest is not effectively and transparently tracked all the way through the supply
chain to a final labeled product, then it is meaningless. Stating simply that Chain of Custody
procedures must be publicly available, does not say anything about what these procedures require.
The benchmarks need to address the transparency and rigour and of the CoC certification, and the
transparency of the labelling process. Minimum certified material: To the point made above, one of
the alternative certification systems to FSC has a CoC standard that allows certified wood products
to be mixed (no minimum) with wood products whose only requirement is 'legality'. These products
can still carry the certification system's label, meaning that all the label is really guaranteeing is
'legality' (according to their definition). At a minimum, ALL wood fibre in an FSC-certified and
labelled product must meet FSC's Controlled Wood requirements, which are far more rigorous than
simple 'legality'. We suggest that the benchmarks be written to require that all virgin fibre in a

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?
Yes, the Forest Stewardship Council (FSC)

If yes, please explain indicate which systems comply and how they are compliant.


The Forest Stewardship Council has a comprehensive Chain of Custody certification system that
requires all companies to undergo onsite auditing by independent third party Certification Bodies.
The FSC Chain of Custody standard is available online at www.fscus.org. FSC has set on-product
labeling requirements that allow consumers to identify who produced or sold an FSC-certified
product, and effectively track that product back through the supply chain. FSC's Controlled Wood
standard requires that all non-certified virgin fibre that is mixed with certified virgin fibre, or mixed
with recycled fibre, must be verified (through a risk assessment process) to not come from the
following sources: illegally harvested wood; wood harvested in violation of traditional and civil
rights; wood harvested in forests where high conservation values are threatened by management
activities; wood harvested in forests being converted to plantations or non-forest use; and wood
from forests in which genetically modified trees are planted.

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?
The current acceptable non-certified sources language seems to be biased towards the FSC
"controlled wood standard".

If yes, please explain indicate which systems comply and how they are compliant.
All chain of custody programs track fiber from certified forests, recycled content, and ensure non-
acceptable fiber does not enter the product. The SFI Standard is the only one with a procurement
component which strengthens the actual "chain of custody" from the forest to the mill gate and
eventully the finished product.
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
***Acceptable non-certified sources for % based claims - this language seems to be based on the
FSC Standard. Since all certification programs must eventually deal with wood from plantations,
commercially grown plantation species must need to be considered for the LEED chain-of-
custody/labeling systems.

If not, please explain how the existing systems are deficient.
The current language is biased towards FSC's controlled wood standard. Although the non-
acceptable sources should still contain language concerning illegal logging (definition) ... they should
also consider programs with "standard performance indicators" that target certified wood
procurement systems.
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.

All chain of custody programs (SFI, PEFC and FSC) track fiber from certified forests, recycled content,
and ensure non-acceptable fiber does not enter the product. In the SFI Standard, Objective 8 has
requirements for responsible procurement and USGBC should consider giving credit for a combined
program of the SFI Procurement Standard and FSC Controlled Wood Standard can meet the USGBC
chain of custody labeling benchmark intent. Recommended Benchmark: The SFI Procurement
Standard combined with the FSC Controlled Wood Standard would meet the intent of the chain of
custody and labeling requirements.

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?
No comment

If yes, please explain indicate which systems comply and how they are compliant.
No comment

If not, please explain how the existing systems are deficient.
No comment
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.

Missouri Forest Products Association feels the chain of custody system benchmark is unclear. USGBC
must clarify what is defined by LEED as a third-party claim. Only systems employing true third-party
certification procedures under ISO standards should be considered as fulfilling this benchmark.

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?
The existing certification systems (FSC, PEFC, SFI, Tree Farm, CSA) should be able to meet the
majority of the benchmarks as drafted.
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Chain of Custody: Many of these benchmarks are quite good. However, an important gap is that
the definition of Illegal logging is too narrow to be meaningful, and only addresses a small segment
of the problem. To be credible, the USGBC definition should be expanded to include other important
elements. WWF's definition is one good example: Illegal logging: When timber is harvested or
traded in violation of relevant national or sub-national laws or where access to forest resources or
trade in forest products is authorized through corrupt practices. In sum, we are supportive of a
benchmark approach, but feel that such an approach should set a high enough baseline that it
rewards leadership standards and provides incentives for other systems to improve. LEED has done
so much to promote well-managed forests through its recognition of leadership certification
standards to date. The USGBC should be proud of its accomplishments in this arena, and not allow
wood from forests managed to "business as usual" standards to be recognized within the system.
Now is not the time for LEED to effectively (and considerably) lower the bar for their certified credit,
especially just as credible forest certification is taking off in other forest products sectors, including
paper and furniture. LEED stands for "leadership" and that means that not all wood is appropriate to

If yes, please explain indicate which systems comply and how they are compliant.
All chain of custody programs (SFI, PEFC and FSC) track fiber from certified forests, recycled content,
and ensure non-acceptable fiber does not enter the product. In the SFI Standard, Objective 8 has
requirements for responsible procurement. This ensures program participants take measures to
ensure the fiber was harvested legally, meet state, provincial and federal laws regarding threatened
and endangered species, encourage landowners to incorporate actions that identify and protect or
create habitat for wildlife, encourage landowners to reforest harvested lands, both naturally and
through replanting, encourage landowners to protect riparian zones and water quality, implement a
verifiable monitoring system to continually improve the effectiveness of encouraging landowners to
reforest harvested areas and apply best management practices to protect water quality, encourage
landowners to use loggers and resource professionals trained in sustainable forestry practices,
conserve biodiversity hotspots and major tropical wilderness areas outside the U.S. and Canada as
defined by Conservation International, encourage economically, environmentally and socially sound
practices outside the U.S. and Canada. A certification to Objective 8-13 is mandatory for primary
producers, in addition to a CoC certification.

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?
Chain of Custody is an accounting system that varies little between the various forest certification
programs.

Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Most of the CoC and Labeling benchmarks are appropriate. The following benchmark needs to be
modified: Acceptable non-certified sources for % based claims: This language seems to follow
closely with language from the FSC Standard. This benchmark should be modified to avoid bias.
Plantations: No certification of plantations converted after 2007 unless change in ownership or
program to convert back to natural forest beginning in advance of the next harvest cycle. For this
purpose, the definition of plantations is consistent with the FAO definition. All certification programs
must deal with plantations, whether established or new. Plantations can have a positive benefit.
Prohibiting conversion under the LEED program is not practical given that all certification programs
deal with new and established plantations alike. Rather, the USGBC should support the certification
programs that limit the use of exotics in plantations, and that also ensure that the same
requirements for natural forest management exists for planted stands as well. GMO's: Prohibit the
use of genetically modified organisms. There are no commercially grown GMO's in North America.
However, research is important to the future of the world's forests. Therefore GMO's should not be
banned based on the requirements of one program because research involving biotechnology has

If not, please explain how the existing systems are deficient.
Because this language seems biased towards FSC's controlled wood standard, it puts all other
certification programs as deficient. The non-acceptable sources should be written to avoid
controversial sources from the supply chain (i.e. Illegal Logging), but at the same time reward
programs like SFI's wood fiber procurement system that take a proactive approach that influence
millions of additional acres in North America and globally through the outreach, training and
education programs.
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Most of the CoC and Labeling benchmarks are appropriate. The following benchmark needs to be
modified: Acceptable non-certified sources for % based claims: This language seems to follow
closely with language from the FSC Standard. This benchmark should be modified to avoid bias.
Plantations: No certification of plantations converted after 2007 unless change in ownership or
program to convert back to natural forest beginning in advance of the next harvest cycle. For this
purpose, the definition of plantations is consistent with the FAO definition. All certification programs
must deal with plantations, whether established or new. Plantations can have a positive benefit.
Prohibiting conversion under the LEED program is not practical given that all certification programs
deal with new and established plantations alike. Rather, the USGBC should support the certification
programs that limit the use of exotics in plantations, and that also ensure that the same
requirements for natural forest management exists for planted stands as well. GMO's: Prohibit the
use of genetically modified organisms. There are no commercially grown GMO's in North America.
However, research is important to the future of the world's forests. Therefore GMO's should not be
banned based on the requirements of one program because research involving biotechnology has

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?
Chain of Custody is an accounting system that varies little between the various forest certification
programs.

If yes, please explain indicate which systems comply and how they are compliant.
All chain of custody programs (SFI, PEFC and FSC) track fiber from certified forests, recycled content,
and ensure non-acceptable fiber does not enter the product. In the SFI Standard, Objective 8 has
requirements for responsible procurement. This ensures program participants take measures to
ensure the fiber was harvested legally, meet state, provincial and federal laws regarding threatened
and endangered species, encourage landowners to incorporate actions that identify and protect or
create habitat for wildlife, encourage landowners to reforest harvested lands, both naturally and
through replanting, encourage landowners to protect riparian zones and water quality, implement a
verifiable monitoring system to continually improve the effectiveness of encouraging landowners to
reforest harvested areas and apply best management practices to protect water quality, encourage
landowners to use loggers and resource professionals trained in sustainable forestry practices,
conserve biodiversity hotspots and major tropical wilderness areas outside the U.S. and Canada as
defined by Conservation International, encourage economically, environmentally and socially sound
practices outside the U.S. and Canada. A certification to Objective 8-13 is mandatory for primary
producers, in addition to a CoC certification.

If not, please explain how the existing systems are deficient.
Because this language seems biased towards FSC's controlled wood standard, it puts all other
certification programs as deficient. The non-acceptable sources should be written to avoid
controversial sources from the supply chain (i.e. Illegal Logging), but at the same time reward
programs like SFI's wood fiber procurement system that take a proactive approach that influence
millions of additional acres in North America and globally through the outreach, training and
education programs.

If yes, please explain indicate which systems comply and how they are compliant.
all aspects; too long to write here

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?
FSC

Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.

See comments under governance #1. Major concerns on legality issues and controlled wood. In
theory some other systems address the issues, however they lack rigor in performance and
transparency. It is critical that the "non-certified" portions of certified wood products, i.e. that
portion of a product that does not come from a certified forest, be controlled to ensure it is legal,
not from GMOs, not abridging human rights, not contributing to large scale conversions, and not
negatively affecting high conservation value forests.

If not, please explain how the existing systems are deficient.
PEFC systems do not include COC controls on various aspects. Some PEFC affiliated systems in
theory cover some areas, but the whole auditing and review process for this lacks rigor and
transparency.
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Most of the CoC and Labeling benchmarks are appropriate. The following benchmark needs to be
modified: Acceptable non-certified sources for % based claims: This language seems to follow
closely with language from the FSC Standard. This benchmark should be modified to avoid bias.
Plantations: No certification of plantations converted after 2007 unless change in ownership or
program to convert back to natural forest beginning in advance of the next harvest cycle. For this
purpose, the definition of plantations is consistent with the FAO definition. All certification programs
must deal with plantations, whether established or new. Plantations can have a positive benefit.
Prohibiting conversion under the LEED program is not practical given that all certification programs
deal with new and established plantations alike. Rather, the USGBC should support the certification
programs that limit the use of exotics in plantations, and that also ensure that the same
requirements for natural forest management exists for planted stands as well. GMO's: Prohibit the
use of genetically modified organisms. There are no commercially grown GMO's in North America.
However, research is important to the future of the world's forests. Therefore GMO's should not be
banned based on the requirements of one program because research involving biotechnology has

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?
Chain of Custody is an accounting system that varies little between the various forest certification
programs.

If yes, please explain indicate which systems comply and how they are compliant.
All chain of custody programs (SFI, PEFC and FSC) track fiber from certified forests, recycled content,
and ensure non-acceptable fiber does not enter the product. In the SFI Standard, Objective 8 has
requirements for responsible procurement. This ensures program participants take measures to
ensure the fiber was harvested legally, meet state, provincial and federal laws regarding threatened
and endangered species, encourage landowners to incorporate actions that identify and protect or
create habitat for wildlife, encourage landowners to reforest harvested lands, both naturally and
through replanting, encourage landowners to protect riparian zones and water quality, implement a
verifiable monitoring system to continually improve the effectiveness of encouraging landowners to
reforest harvested areas and apply best management practices to protect water quality, encourage
landowners to use loggers and resource professionals trained in sustainable forestry practices,
conserve biodiversity hotspots and major tropical wilderness areas outside the U.S. and Canada as
defined by Conservation International, encourage economically, environmentally and socially sound
practices outside the U.S. and Canada. A certification to Objective 8-13 is mandatory for primary
producers, in addition to a CoC certification.

If not, please explain how the existing systems are deficient.
Because this language seems biased towards FSC's controlled wood standard, it puts all other
certification programs as deficient. The non-acceptable sources should be written to avoid
controversial sources from the supply chain (i.e. Illegal Logging), but at the same time reward
programs like SFI's wood fiber procurement system that take a proactive approach that influence
millions of additional acres in North America and globally through the outreach, training and
education programs.
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Most of the CoC and Labeling benchmarks are appropriate, though the benchmarks regarding
plantations and GMO's need to be modified as previously discussed

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?

Chain of Custody is an accounting system that is used the delivery of a variety of products and varies
little between the various forest certification programs. It appears that the language proposed is
directly from the FSC controlled wood standard. If this is so, FSC would qualify and SFI would not.
USGBC should take a less biased approach to this topic and clearly state why these criteria have
been chosen as benchmarks for CoC and labeling.

If yes, please explain indicate which systems comply and how they are compliant.

Chain of Custody is an accounting system that is used the delivery of a variety of products and varies
little between the various forest certification programs. It appears that the language proposed is
directly from the FSC controlled wood standard. If this is so, FSC would qualify and SFI would not.
USGBC should take a less biased approach to this topic and clearly state why these criteria have
been chosen as benchmarks for CoC and labeling.

If not, please explain how the existing systems are deficient.

Chain of Custody is an accounting system that is used the delivery of a variety of products and varies
little between the various forest certification programs. It appears that the language proposed is
directly from the FSC controlled wood standard. If this is so, FSC would qualify and SFI would not.
USGBC should take a less biased approach to this topic and clearly state why these criteria have
been chosen as benchmarks for CoC and labeling.
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.

The requirements appear to be specific to FSC and should be modified to be more inclusive of other
certification programs such as SFI and ATFS. Specific requirements for plantations, GMOs and forests
of special social and environmental conservation value should be determined by multi-stakeholder
experts associated with each certification system.

If yes, please explain indicate which systems comply and how they are compliant.
See response in question 2.

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?
Given the proposed benchmarks closely follow the FSC controlled wood standard, it appears only
FSC would qualify with the CoC and Labeling requirements; However, there is little variation among
the Chain of Custody accounting systems between the certification programs which suggest SFI and
ATFS (and possibly others) should be able to comply with the benchmarks.

If not, please explain how the existing systems are deficient.
See response in question 2.

If not, please explain how the existing systems are deficient.

As an accredited auditor for both FSC and SFI (Sustainable Forest Initiative), I wish to point out a
FATAL FLAW in the SFI Chain of Custody (CoC) system relating to both Transparency and CoC
Procedures. In the SFI CoC system, distributors are NOT REQUIRED to (and do not) become SFI CoC
certified. The orginal SFI producer, of course, must be. However, the COC requirement(in SFI) is
DROPPED when SFI product enters distribution. I sincerely encourage the appropriate USGBC TAG to
look into this situation in detail as the applicability of the SFI CoC to meet USGBC expectations must
be examined.

If yes, please explain indicate which systems comply and how they are compliant.

The Forest Stewardship Council (FSC) policies, criteria, and indicators relating to Chain of Custody
Certification address in detail each USGBC Concept cited. Certification bodies and their auditors
must completely and accurately examine all concerns in the course of an FSC Chain of Custody audit.

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?
Only one system, FSC, is fully compliant with all the benchmarks listed.

Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
The benchmarks relating to forest certification system Chain of Custody and labeling are appropriate
and on-target.
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.

Please excuse my ignorance, but I only want to comment on the fact that in Canada (British
Columbia) we are forced to buy wood from the Washington/Oregan area to meet LEED criteria. This
makes it necessary to transport the wood from outside our local/regional area thus affecting our
carbon footprint negatively. If CSA approved wood could be used in the accreditation process we
could buy would from within our local regional market area. So if LEED acreditation is truly going to
be effective it must allow other approved forests to be used/available other than those in the US.
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
Probably. Though not currently in place, chain of custody is easily documented with individual urban
trees and the results would be sigificant. The US Forest Service has estimated that more than 25% of
the nation's annual hardwood needs could be met if all the trees normally removed from the urban
forest and currently treated as waste, were reclaimed. These trees, over the course of decades, give
continual environmental, health, aesthetic, and energy conservation benefits. People living in cities
and towns often have a deep connection to their community trees. Fostering the harvesting of
urban timber and facilitating their use in LEED green building, demonstrates sustainability visibly and
dramatically. The US Forest Service also estimates that an urban tree is 15 times more effective at
CO2 reduction through avoided carbon, than its forest counterpart. Capturing urban timber allows
completion of the life cycle of the urban tree.

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?
Not yet. Though Tree City USA could become the certifier of urban forests inclusive of urban timber
harvesting.

If yes, please explain indicate which systems comply and how they are compliant.

Model systems in place currently in the Chicago area, document the location of individual trees by
street address and the labeling follows through to timber processing. Baseball bats made from ash
trees killed by the invasive emerald ash borer are currently being distributed in the region and these
can be traced back to the indivdual wood donor's property.
Do the proposed USGBC benchmarks relating to forest certification system Chain of Custody and
Labeling establish appropriate program requirements? Please explain and/or suggest how the
requirements might be improved.
By and large, yes. Comments noted below. 1. Under "Restrictions on non-certified material"--I note
that is is improper for wood to come from a natural forest that is then converted to a plantation.
This goes back to an earlier objection with the plantation language I had in another section. Here is
an example. If I have a nice naturally regenerated longleaf pine stand in south Mississippi, and use
prescribed fire every third year to improve wildlife habitat, so far so good. If I cut the majority of the
trees but retain sufficient seed trees to seed the next stand, then this is OK too. Once the young
trees are established, I can come in and remove the seed trees, resulting in a natural longleaf pine
stand, and reinstate my burn program to keep the hardwoods out. What I cannot do to that same
stand is remove all the trees, plant with containerized longleaf pine to take advantage of genetic
improvements, and produce a stand that is virtually identical to the first one, only it grows faster. I
do understand that the intent is to prevent converting, in my area, bottomland hardwood into pine
plantations, and I am OK with that. However, this goes back to the fact that we have many different
forest types and appropriate management strategies, and overly prescriptive language does not

Do any of the existing systems comply with the Chain of Custody and Labeling requirements as
established in the USGBC benchmarks?
Unsure. The CoC issue is a challenge, but I am confident that a teenager will write a computer
program to handle all of this.

If yes, please explain indicate which systems comply and how they are compliant.
Capabilities are in place to get this done with ATFS, FSC, and SFI.

If not, please explain how the existing systems are deficient.

I believe one of the main problems is that we are still in an embryonic stage in terms of certified
wood as a percentage of the overall market. Howver, as this percentage increases, and as mills get
more requests and demands for certified products from their clients, this need will filter down to
the local level. This will be a "non-issue" in another 5 years. I appreciate the opportunity to provide
comments to USGBC regarding certification issues, as this is something we have been working on for
several years from the private, nonindustrial landowner perspective.
USGBC Response
Thank you for your comments. USGBC recognizes the complexities of the "legality" issue, hopes the
revisions begin to address your concerns, and is committed to creating a benchmark that is
comprehensive and rigorous.




Thank you for your comments. At this time, USGBC respectfully feels that genetically-modified
organisms should not be labeled as certified for the purpose of this credit. Please refer to the
Standards Substance comments and responses for further elaboration.




Thank you for your comments. USGBC recognizes that there is not an explicit path in LEED for
project teams to earn credit for sourcing their materials from small-scale producers or farmers. As
such, it is recommended that project teams seek a point in the Innovation and Design credit
category, explicitly noting how the strategy is comprehensive, quantifiable, and applicable to other
projects. To clarify, however, the Governance section contains a Distinguishing benchmark whereby
certifications schemes are encouraged to provide accessibility to diverse ownership types.




Thank you for your comments. USGBC has reviewed and carefully considered the letter submitted
by the Cascadia Region Green Building Council.




Thank you for your comments. The responses to each of your main points are as follows:
1. The "Chain of Custody system" benchmark has been revised to explicitly state that schemes
require third-party claims.
2. USGBC respectfully believes that its revised "Compliance with international normative
institutions" benchmark sufficiently covers this topic and provides enough guidelines for
certifications schemes to follow and USGBC’s third-party evaluators to use to determine possible
compliance.
3. While MRc7 will continue to now allow recycled content to count towards attaining MRc7, USGBC
has created a benchmark for this issue to reflect its presence in most certification schemes. The
presence of this issue warranted a benchmark against which to evaluate a scheme’s level of rigor.
Thank you for your comments. The responses to each of your main points are as follows:
1. The "Chain of Custody system" benchmark has been revised to explicitly state that schemes
require third-party claims.
2. USGBC respectfully believes that its revised "Compliance with international normative
institutions" benchmark sufficiently covers this topic and provides enough guidelines for
certifications schemes to follow and USGBC’s third-party evaluators to use to determine possible
compliance.
3. While MRc7 will continue to now allow recycled content to count towards attaining MRc7, USGBC
has created a benchmark for this issue to reflect its presence in most certification schemes. The
presence of this issue warranted a benchmark against which to evaluate a scheme’s level of rigor.




Thank you for your comments. USGBC will consider how FSC references controversial wood but will
not use the FSC approach as the standard on which it will determine its own benchmark.




Thank you for your comments. Please refer to the comments and responses of the Standards
Substance section for elaboration on your suggestion.




Thank you for your comments. Please be assured that these benchmarks are not intended to
decrease USGBC's expected level of performance from compliant certification schemes. And your
specific commentary on these certification schemes is helpful. In the end, a forest certification
scheme will be deemed compliant by an independent, third-party evaluation of its criteria against
the Forest Certification Schemes Benchmarks requirements.
scheme will be deemed compliant by an independent, third-party evaluation of its criteria against
the Forest Certification Schemes Benchmarks requirements.




Thank you for your comments. The responses to each of your main points are as follows:
1. USGBC does not intend for any benchmark to be biased towards a particular forest certification
scheme. Instead, USGBC intends for the benchmarks collectively present the organization's
definition of exemplary forest certification in all aspects of a certification scheme, independent of
any one scheme's previously established guidelines.
2. The provisions of the sections you list apply to non-certified sources that are included in the wood
product that nonetheless includes certified material.
3. Please see the comments and responses in the Standards Substance section for more on “forests
of social and environmental conservation value.”
4. USGBC has high expectations for any scheme that gains recognition in LEED. As such, it will
maintain clear – and in some instances, specific – benchmarks to ensure that the recognized scheme
is exemplary.




Thank you for your comments. The responses to your main points are as follows:
1. To confirm your impression, a forest certification scheme will be deemed compliant by an
independent, third-party evaluation of its criteria against the Forest Certification Schemes
Benchmarks requirements. The benchmarks have been established independent from any
certification scheme. USGBC does not intend for any benchmark to be biased towards a particular
forest certification scheme. Instead, USGBC intends for the benchmarks collectively present the
organization's definition of exemplary forest certification in all aspects of a certification scheme,
independent of any one scheme's previously established guidelines.
2, USGBC has appreciatively utilized the insight from Yale University and is grateful for the guidance
their experts have shown throughout the process.
3. USGBC recognizes the complexities of the issue you mention, hope that the revisions begin to
address your concerns, and is committed to creating a benchmark that is comprehensive and
rigorous.
Thank you for your comments. The responses to each of your main points are as follows:
1. USGBC does not intend for any benchmark to be biased towards a particular forest certification
scheme. Instead, USGBC intends for the benchmarks collectively present the organization's
definition of exemplary forest certification in all aspects of a certification scheme, independent of
any one scheme's previously established guidelines.
2. The provisions of the sections you list apply to non-certified sources that are included in the wood
product that nonetheless includes certified material.
3. Please see the comments and responses in the Standards Substance section for more on “forests
of social and environmental conservation value.”
4. Please see the accompanying draft Conformance Assessment to learn how USGBC intends to
evaluate the forest certification schemes against the finalized benchmarks.
5. The “Continual improvement” benchmark can be found in Governance section.
Thank you for your comments. Your specific commentary on these certification schemes is helpful.
In the end, a forest certification scheme will be deemed compliant by an independent, third-party
evaluation of its criteria against the Forest Certification Schemes Benchmarks requirements.

And USGBC does not intend for any benchmark to be biased towards a particular forest certification
scheme. Instead, USGBC intends for the benchmarks collectively present the organization's
definition of exemplary forest certification in all aspects of a certification scheme, independent of
any one scheme's previously established guidelines.




Thank you for your comments. The responses to each of your main points are as follows:
1. USGBC does not intend for any benchmark to be biased towards a particular forest certification
scheme. Instead, USGBC intends for the benchmarks collectively present the organization's
definition of exemplary forest certification in all aspects of a certification scheme, independent of
any one scheme's previously established guidelines.
2. The provisions of the sections you list apply to non-certified sources that are included in the wood
product that nonetheless includes certified material.
3. Please see the comments and responses in the Standards Substance section for more on “forests
of social and environmental conservation value.”

Thank you for your comments. The responses to your main points are as follows:
1. USGBC sincerely appreciates your insight on this certification scheme’s requirement. It helps
educate the process of finalizing the benchmarks.
2. USGBC does not intend for any benchmark to be biased towards a particular forest certification
scheme. Instead, USGBC intends for the benchmarks collectively present the organization's
definition of exemplary forest certification in all aspects of a certification scheme, independent of
any one scheme's previously established guidelines.
3. The “Plantations” benchmark is a part of USGBC’s high expectations for exemplary forest
certification; it has been identified as a Required benchmark. Please see the comments and
responses in the Standards section for more.
4. As with the “Plantations” benchmark, the GNO benchmark is a part of USGBC’s high expectations
for exemplary forest certification and has been labeled as Required. While USGBC understands the
importance of sound science for biotechnology, it does not believe that exemplary forest
certification should allow for those practices in active forests until the science is well established.
Please see the comments and responses in the Standards section for more.
Thank you for your comment. USGBC is close to finalizing the Forest Certification Scheme
Benchmarks so their output (the actual evaluation of schemes for possible inclusion in LEED) can be
implemented. USGBC will use a third-party review process to determine which scheme(s) meets the
benchmarks' requirements.




Thank you for your comments. USGBC agrees that any revision to LEED credits should motivate
market transformation and should advance more sustainable practices. As such, the proposed
changes to the Certified Wood credits are intended to motivate change, in this instance the forest
certification market. The USGBC benchmarks are intended to be an objective and transparent
collection of standards against which forest certification schemes will be evaluated to determine
which meet USGBC's level of rigor and then gain recognition in LEED.

Regarding the verification process, please see the accompanying Conformance Assessment Process
document to learn how USGBC intends to evaluate the forest certification schemes against the
finalized benchmarks.
collection of standards against which forest certification schemes will be evaluated to determine
which meet USGBC's level of rigor and then gain recognition in LEED.

Regarding the verification process, please see the accompanying Conformance Assessment Process
document to learn how USGBC intends to evaluate the forest certification schemes against the
finalized benchmarks.




Thank you for your comments. The Forest Certification Scheme Benchmarks posted for this 2nd
Public Comment Period are revised to be clearer, better aligned with USGBC's Guiding Principles,
and more consistently present stringent requirements. Additionally, the benchmarks are meant to
increase the transparency by which USGBC chooses one or more scheme for recognition in those
credits. The rigor of the benchmarks ensures that wood used to earn a point in the credit will
continue to come from exemplary forest management practices.
Thank you for your comments. The responses to each of your main points are as follows:
1. USGBC does not intend for any benchmark to be biased towards a particular forest certification
scheme. Instead, USGBC intends for the benchmarks collectively present the organization's
definition of exemplary forest certification in all aspects of a certification scheme, independent of
any one scheme's previously established guidelines.
2. The provisions of the sections you list apply to non-certified sources that are included in the wood
product that nonetheless includes certified material.




Thank you for your comments. The responses to your main points are as follows:
1. USGBC believes that prescriptive benchmarks are necessary to ensure compliance with its own
definition of exemplary forest certification. To gain recognition in LEED, a forest certification
scheme does not need to fulfill every benchmark. Please see the accompanying Conformance
Assessment Process to learn how USGBC intends to evaluate the forest certification schemes against
the finalized benchmarks.
2. Your specific commentary on these certification schemes is helpful. In the end, a forest
certification scheme will be deemed compliant by an independent, third-party evaluation of its
criteria against the Forest Certification Scheme Benchmarks.
Thank you for your comments. Your concerns about the Chain of Custody requirements is
understandable; USGBC appreciates the insight you've provided about the experience of entities in
your business sector.




Thank you for your comments. USGBC agrees that any revision to LEED credits should motivate
market transformation and should advance more sustainable practices. As such, the proposed
changes to the Certified Wood credits are intended to motivate change, in this instance the forest
certification market. The USGBC benchmarks are intended to be an objective and transparent
collection of standards against which forest certification schemes will be evaluated to determine
which meet USGBC's level of rigor and then gain recognition in LEED.

Regarding the verification process, please see the accompanying Conformance Assessment Process
document to learn how USGBC intends to evaluate the forest certification schemes against the
finalized benchmarks.
Thank you for your comments. USGBC agrees that any revision to LEED credits should motivate
market transformation and should advance more sustainable practices. As such, the proposed
changes to the Certified Wood credits are intended to motivate change, in this instance the forest
certification market. The USGBC benchmarks are intended to be an objective and transparent
collection of standards against which forest certification schemes will be evaluated to determine
which meet USGBC's level of rigor and then gain recognition in LEED.

Regarding the verification process, please see the accompanying Conformance Assessment Process
document to learn how USGBC intends to evaluate the forest certification schemes against the
finalized benchmarks.




Thank you for your comments and your support of the current credit. USGBC intends for its Forest
Certification Scheme Benchmarks to recognize exemplary schemes and does not intend to decrease
the rigor of the Certified Wood credit. The proposed credit changes and accompanying Forest
Certification Scheme Benchmarks are meant to increase the transparency by which USGBC chooses
one or more scheme for recognition in those credits. USGBC hopes that the revisions to the
benchmarks both clarify and elaborate on the stringent requirements.




Thank you for your comments. USGBC appreciates your insight on these benchmarks. The responses
to your questions are as follow:
1. Regarding credible labeling approaches, USGBC will rely on a third-party evaluation to determine
which forest certification schemes meet the requirements of the benchmarks. Be assured that the
revised benchmarks are meant to uphold the integrity of the credit.
2. Your input regarding CITES is valuable. Please refer to the comments and responses of the
Standards Substance section for elaboration on your suggestion to clarify “special social and
environmental value.”
3. USGBC recognizes the complexities of the issue you mention, hopes that the revisions begin to
address your concerns, and is committed to creating a benchmark that is comprehensive and
rigorous.
Thank you for your comments. USGBC appreciates your insight on these benchmarks. The responses
to your questions are as follow:
1. Regarding credible labeling approaches, USGBC will rely on a third-party evaluation to determine
which forest certification schemes meet the requirements of the benchmarks. Be assured that the
revised benchmarks are meant to uphold the integrity of the credit.
2. Your input regarding CITES is valuable. Please refer to the comments and responses of the
Standards Substance section for elaboration on your suggestion to clarify “special social and
environmental value.”
3. USGBC recognizes the complexities of the issue you mention, hopes that the revisions begin to
address your concerns, and is committed to creating a benchmark that is comprehensive and
rigorous.




Thank you for your comments. The responses to your questions are as follows:
1. Please refer to the comments and responses of the Standards Substance section for elaboration
on your suggestion for definition clarification.
2. Regarding credible labeling approaches, USGBC will rely on a third-party evaluation to determine
which forest certification schemes meet the requirements of the benchmarks. Be assured that the
revised benchmarks are meant to uphold the integrity of the credit.
3. Your input regarding this benchmark is valuable. USGBC believes that prescriptive benchmarks are
necessary to ensure compliance with its own definition of exemplary forest certification.
Thank you for you comments. The benchmarks posted for this 2nd Public Comment Period are
revised to be clearer, better aligned with USGBC's Guiding Principles, and more consistently present
rigorous requirements.

Thank you for your comments. USGBC agrees that any revision to LEED credits should motivate
market transformation and should advance more sustainable practices. As such, the proposed
changes to the Certified Wood credits are intended to motivate change, in this instance the forest
certification market. The USGBC benchmarks are intended to be an objective and transparent
collection of standards against which forest certification schemes will be evaluated to determine
which meet USGBC's level of rigor and then gain recognition in LEED.

Regarding the verification process, please see the accompanying draft Conformance Assessment to
learn how USGBC intends to evaluate the forest certification schemes against the finalized
benchmarks.




Thank you for your comments. The responses to your main points are as follows:
1. USGBC sincerely appreciates your insight on this certification scheme’s requirement. It helps
educate the process of finalizing the benchmarks.
2. USGBC does not intend for any benchmark to be biased towards a particular forest certification
scheme. Instead, USGBC intends for the benchmarks collectively present the organization's
definition of exemplary forest certification in all aspects of a certification scheme, independent of
any one scheme's previously established guidelines.
3. The “Plantations” benchmark is a part of USGBC’s high expectations for exemplary forest
certification. This benchmark is not required to gain recognition in LEED but will help a scheme
towards gaining recognition. Please see the comments and responses in the Standards section for
more.
4. As with the “Plantations” benchmark, this benchmark is a part of USGBC’s high expectations for
exemplary forest certification. While USGBC understands the importance sound science for
biotechnology, it does not believe that exemplary forest certification should allow for those
Thank you for your comments. The responses to your main points are as follows:
1. USGBC sincerely appreciates your insight on this certification scheme’s requirement. It helps
educate the process of finalizing the benchmarks.
2. USGBC does not intend for any benchmark to be biased towards a particular forest certification
scheme. Instead, USGBC intends for the benchmarks collectively present the organization's
definition of exemplary forest certification in all aspects of a certification scheme, independent of
any one scheme's previously established guidelines.
3. The “Plantations” benchmark is a part of USGBC’s high expectations for exemplary forest
certification. This benchmark is not required to gain recognition in LEED but will help a scheme
towards gaining recognition. Please see the comments and responses in the Standards section for
more.
4. As with the “Plantations” benchmark, this benchmark is a part of USGBC’s high expectations for
exemplary forest certification. While USGBC understands the importance sound science for
biotechnology, it does not believe that exemplary forest certification should allow for those
practices in active forests until the science is well established. Please see the comments and
responses in the Standards section for more.
Thank you for your comments. The responses to your main points are as follows:
1. USGBC sincerely appreciates your insight on this certification scheme’s requirement. It helps
educate the process of finalizing the benchmarks.
2. USGBC does not intend for any benchmark to be biased towards a particular forest certification
scheme. Instead, USGBC intends for the benchmarks collectively present the organization's
definition of exemplary forest certification in all aspects of a certification scheme, independent of
any one scheme's previously established guidelines.
3. The “Plantations” benchmark is a part of USGBC’s high expectations for exemplary forest
certification. This benchmark is not required to gain recognition in LEED but will help a scheme
towards gaining recognition. Please see the comments and responses in the Standards section for
more.
4. As with the “Plantations” benchmark, this benchmark is a part of USGBC’s high expectations for
exemplary forest certification. While USGBC understands the importance sound science for
biotechnology, it does not believe that exemplary forest certification should allow for those
practices in active forests until the science is well established. Please see the comments and
responses in the Standards section for more.
responses in the Standards section for more.




USGBC believes that prescriptive benchmarks are necessary to ensure compliance with its own
definition of exemplary forest certification. To gain recognition in LEED, a forest certification
scheme does not need to fulfill every benchmark. Please see the accompanying Conformance
Assessment Process to learn how USGBC intends to evaluate the forest certification schemes against
the finalized benchmarks.
Thank you for your comments.
1.Your specific commentary on these certification schemes is helpful. Please see the Standards
Substance questions and response for information regarding compliance with existing laws.
2.In the end, a forest certification scheme will be deemed compliant by an independent, third-party
evaluation of its criteria against the Forest Certification Schemes Benchmarks requirements.
3.USGBC does not intend for any benchmark to be biased towards a particular forest certification
scheme. Instead, USGBC intends for the benchmarks collectively present the organization's
definition of exemplary forest certification in all aspects of a certification scheme, independent of
any one scheme's previously established guidelines.




Thank you for your comments. USGBC agrees that any revision to LEED credits should motivate
market transformation and should advance more sustainable practices. As such, the proposed
changes to the Certified Wood credits are intended to motivate change, in this instance the forest
certification market. The USGBC benchmarks are intended to be an objective and transparent
collection of standards against which forest certification schemes will be evaluated to determine
which meet USGBC's level of rigor and then gain recognition in LEED.

Regarding the verification process, please see the accompanying draft Conformance Assessment to
learn how USGBC intends to evaluate the forest certification schemes against the finalized
benchmarks.
Thank you for your comments. USGBC agrees that any revision to LEED credits should motivate
market transformation and should advance more sustainable practices. As such, the proposed
changes to the Certified Wood credits are intended to motivate change, in this instance the forest
certification market. The USGBC benchmarks are intended to be an objective and transparent
collection of standards against which forest certification schemes will be evaluated to determine
which meet USGBC's level of rigor and then gain recognition in LEED.

Regarding the verification process, please see the accompanying draft Conformance Assessment to
learn how USGBC intends to evaluate the forest certification schemes against the finalized
benchmarks.




Thank you for your comments. USGBC recognizes that there is not an explicit path for project teams
to earn credit for sourcing their materials from small-scale producers or farmers who use
sustainable practices but are not certified. As such, it is recommended that project teams seek a
point in the Innovation and Design credit category, explicitly noting how the strategy is
comprehensive, quantifiable, and applicable to other projects.
Thank you for your comments. Please be assured that USGBC will maintain the rigor of the current
credit and agrees that only wood from farmers and/or producers using sustainable practices should
be considered for the purpose of this credit.




Thank you for your comments. USGBC has not yet determined whether additional certification
schemes will be recognized in LEED. Instead, the proposed benchmarks are meant to indicate what
USGBC expects from exemplary certification schemes. Additionally, they are meant to maintain the
rigor by which certified wood credits are currently achieved. USGBC agrees that sustainable wood
products and responsible forestry practices should be rewarded and believes that the intent of
these changes embodies those principles. There are not currently benchmarks for the other credits
in question.




Thank you for your comments. The responses to your main points are as follows:
1. USGBC sincerely appreciates your insight on this certification scheme’s requirement. It helps
educate the process of finalizing the benchmarks.
2. USGBC does not intend for any benchmark to be biased towards a particular forest certification
scheme. Instead, USGBC intends for the benchmarks collectively present the organization's
definition of exemplary forest certification in all aspects of a certification scheme, independent of
any one scheme's previously established guidelines.
3. The “Plantations” benchmark is a part of USGBC’s high expectations for exemplary forest
certification. This benchmark is not required to gain recognition in LEED but will help a scheme
towards gaining recognition. Please see the comments and responses in the Standards section for
more.
2. USGBC does not intend for any benchmark to be biased towards a particular forest certification
scheme. Instead, USGBC intends for the benchmarks collectively present the organization's
definition of exemplary forest certification in all aspects of a certification scheme, independent of
any one scheme's previously established guidelines.
3. The “Plantations” benchmark is a part of USGBC’s high expectations for exemplary forest
certification. This benchmark is not required to gain recognition in LEED but will help a scheme
towards gaining recognition. Please see the comments and responses in the Standards section for
more.
4. As with the “Plantations” benchmark, this benchmark is a part of USGBC’s high expectations for
exemplary forest certification. While USGBC understands the importance sound science for
biotechnology, it does not believe that exemplary forest certification should allow for those
practices in active forests until the science is well established. Please see the comments and
responses in the Standards section for more.




Thank you for your comments. USGBC does not intend for any benchmark to be biased towards a
particular forest certification scheme. Instead, USGBC intends for the benchmarks collectively
present the organization's definition of exemplary forest certification in all aspects of a certification
scheme, independent of any one scheme's previously established guidelines.




Thank you for your comments. Please see the comments and responses in the Standards section for
further guidance.

 USGBC does not intend for any benchmark to be biased towards a particular forest certification
scheme. Instead, USGBC intends for the benchmarks collectively present the organization's
definition of exemplary forest certification in all aspects of a certification scheme, independent of
any one scheme's previously established guidelines.
Thank you for your comments. The responses to your main points are as follows:
1. USGBC sincerely appreciates your insight on this certification scheme’s requirement. It helps
educate the process of finalizing the benchmarks.
2. USGBC does not intend for any benchmark to be biased towards a particular forest certification
scheme. Instead, USGBC intends for the benchmarks collectively present the organization's
definition of exemplary forest certification in all aspects of a certification scheme, independent of
any one scheme's previously established guidelines.
3. The “Plantations” benchmark is a part of USGBC’s high expectations for exemplary forest
certification. This benchmark is not required to gain recognition in LEED but will help a scheme
towards gaining recognition. Please see the comments and responses in the Standards section for
more.
4. As with the “Plantations” benchmark, this benchmark is a part of USGBC’s high expectations for
exemplary forest certification. While USGBC understands the importance sound science for
biotechnology, it does not believe that exemplary forest certification should allow for those
practices in active forests until the science is well established. Please see the comments and
responses in the Standards section for more.
Thank you for your comments and suggestions. USGBC appreciates your insight regarding
permanent labeling. USGBC will consider how eco-labeling might benefit the Chain of Custody
process but not will not make it a Required benchmark at this time.




Thank you for your comments. USGBC believes that prescriptive benchmarks are necessary to
ensure compliance with its own definition of exemplary forest certification. USGBC recognizes that
there is not an explicit path for project teams to earn credit for sourcing their materials from
producers or farmers who use sustainable practices, but are not certified. As such, it is
recommended that project teams seek a point in the Innovation and Design credit category,
explicitly noting how the strategy is comprehensive, quantifiable, and applicable to other projects.
Thank you for your comments. USGBC believes that prescriptive benchmarks are necessary to
ensure compliance with its own definition of exemplary forest certification. USGBC recognizes that
there is not an explicit path for project teams to earn credit for sourcing their materials from
producers or farmers who use sustainable practices, but are not certified. As such, it is
recommended that project teams seek a point in the Innovation and Design credit category,
explicitly noting how the strategy is comprehensive, quantifiable, and applicable to other projects.




Thank you for your comments. USGBC recognizes the complexity of this issue you mention, hope
that the revisions begin to address your concerns, and is committed to creating a benchmark that is
comprehensive and rigorous.




Thank you for your comments. The responses to your questions are as follows:
1. Please refer to the comments and responses of the Standards Substance section for elaboration
on your suggestion for definition clarification.
2. Regarding credible labeling approaches, USGBC will rely on a third-party evaluation to determine
which forest certification schemes meet the requirements of the benchmarks. Be assured that the
revised benchmarks are meant to uphold the integrity of the credit.
3. Your input regarding this benchmark is valuable. USGBC believes that prescriptive benchmarks are
necessary to ensure compliance with its own definition of exemplary forest certification.




Thank you for your comments. USGBC does not intend for any benchmark to be biased towards a
particular forest certification scheme. Instead, USGBC intends for the benchmarks collectively
present the organization's definition of exemplary forest certification in all aspects of a certification
scheme, independent of any one scheme's previously established guidelines.
Thank you for your comments. USGBC does not intend for any benchmark to be biased towards a
particular forest certification scheme. Instead, USGBC intends for the benchmarks collectively
present the organization's definition of exemplary forest certification in all aspects of a certification
scheme, independent of any one scheme's previously established guidelines.




*comments about third party certification benchmarks???




Thank you for your comments.

Please refer to the comments and responses of the Standards Substance section for elaboration on
your suggestion for clarification.

Your specific commentary on these certification schemes is helpful. In the end, a forest certification
scheme will be deemed compliant by an independent, third-party evaluation of its criteria against
the Forest Certification Schemes Benchmarks requirements.
Thank you for your comments. USGBC believes that prescriptive benchmarks are necessary to
ensure compliance with its own definition of exemplary forest certification. To gain recognition in
LEED, a forest certification scheme does not need to fulfill every benchmark. Please see the
accompanying Conformance Assessment Process to learn how USGBC intends to evaluate the forest
certification schemes against the finalized benchmarks.
Your specific commentary on these certification schemes is helpful. In the end, a forest certification
scheme will be deemed compliant by an independent, third-party evaluation of its criteria against
the Forest Certification Schemes Benchmarks requirements.




Thank you for your comments and concern. Rest assured that USGBC does not wish to diminish the
rigor of the certified wood credit as it stands now. The proposed changes and accompanying Forest
Certification Scheme Benchmarks are meant to increase the transparency by which USGBC chooses
one or more scheme for recognition in those credits. The stringency of the benchmarks ensures
that wood used to earn a point in the credit will continue to come from exemplary forest
management practices.

Additionally, USGBC has relied upon the guidance previously provided by Yale University. Their
experts should be credited with offering important insight that has greatly helped to educate the
process.

In the end, a forest certification scheme will be deemed compliant by an independent, third-party
evaluation of its criteria against the Forest Certification Schemes Benchmarks requirements.
Thank you for your comments and concern. Rest assured that USGBC does not wish to diminish the
rigor of the certified wood credit as it stands now. The proposed changes and accompanying Forest
Certification Scheme Benchmarks are meant to increase the transparency by which USGBC chooses
one or more scheme for recognition in those credits. The stringency of the benchmarks ensures
that wood used to earn a point in the credit will continue to come from exemplary forest
management practices.

Additionally, USGBC has relied upon the guidance previously provided by Yale University. Their
experts should be credited with offering important insight that has greatly helped to educate the
process.

In the end, a forest certification scheme will be deemed compliant by an independent, third-party
evaluation of its criteria against the Forest Certification Schemes Benchmarks requirements.
Thank you for your suggestions. USGBC does not intend for any benchmark to be biased towards a
particular forest certification scheme. Instead, USGBC intends for the benchmarks collectively
present the organization's definition of exemplary forest certification in all aspects of a certification
scheme, independent of any one scheme's previously established guidelines. Please be assured that
the rigor of the current requirements will be upheld.




Thank you for your suggestions. USGBC does not intend for any benchmark to be biased towards a
particular forest certification scheme. Instead, USGBC intends for the benchmarks collectively
present the organization's definition of exemplary forest certification in all aspects of a certification
scheme, independent of any one scheme's previously established guidelines. Please refer to the
Standards Substance comments and responses for further clarification. The provisions of those
sections apply to non-certified sources that are included in the wood product that nonetheless
includes certified material.
Thank you for your suggestions. USGBC does not intend for any benchmark to be biased towards a
particular forest certification scheme. Instead, USGBC intends for the benchmarks collectively
present the organization's definition of exemplary forest certification in all aspects of a certification
scheme, independent of any one scheme's previously established guidelines. Please refer to the
Standards Substance comments and responses for further clarification. The provisions of those
sections apply to non-certified sources that are included in the wood product that nonetheless
includes certified material.




Thank you for your comments. Regarding your questions about definition of legality, please see the
comments and responses in the Standards Substance section. USGBC respectfully believes that its
revised benchmark sufficiently covers this topic and provides enough guidelines for certifications
schemes to follow and USGBC’s third-party evaluators to use to determine possible compliance.

Your specific commentary on the CSA certification scheme is helpful. In the end, a forest
certification scheme will be deemed compliant by an independent, third-party evaluation of its
criteria against the Forest Certification Schemes Benchmarks requirements.




Thank you for your comments. USGBC does not intend for any benchmark to be biased towards a
particular forest certification scheme. Instead, USGBC intends for the benchmarks collectively
present the organization's definition of exemplary forest certification in all aspects of a certification
scheme, independent of any one scheme's previously established guidelines. USGBC has not yet
determined whether additional certification schemes will be recognized in LEED. Your specific
commentary on PEFC is helpful. In the end, a forest certification scheme will be deemed compliant
by an independent, third-party evaluation of its criteria against the Forest Certification Schemes
Benchmarks requirements.
Thank you for your comments. USGBC does not intend for any benchmark to be biased towards a
particular forest certification scheme. Instead, USGBC intends for the benchmarks collectively
present the organization's definition of exemplary forest certification in all aspects of a certification
scheme, independent of any one scheme's previously established guidelines. USGBC has not yet
determined whether additional certification schemes will be recognized in LEED. Your specific
commentary on PEFC is helpful. In the end, a forest certification scheme will be deemed compliant
by an independent, third-party evaluation of its criteria against the Forest Certification Schemes
Benchmarks requirements.




Thank you for your comments. USGBC does not intend for any benchmark to be biased towards a
particular forest certification scheme. Instead, USGBC intends for the benchmarks collectively
present the organization's definition of exemplary forest certification in all aspects of a certification
scheme, independent of any one scheme's previously established guidelines. Please be assured that
USGBC will make every effort to uphold the integrity of the certified wood credit.




Thank you for your comments. USGBC does not intend for any benchmark to be biased towards a
particular forest certification scheme. Instead, USGBC intends for the benchmarks collectively
present the organization's definition of exemplary forest certification in all aspects of a certification
scheme, independent of any one scheme's previously established guidelines. Please see revised
benchmark, which includes references to “illegal or unauthorized sources.”

Your specific commentary on these certification schemes is helpful. In the end, a forest certification
scheme will be deemed compliant by an independent, third-party evaluation of its criteria against
the Forest Certification Schemes Benchmarks requirements.
scheme, independent of any one scheme's previously established guidelines. Please see revised
benchmark, which includes references to “illegal or unauthorized sources.”

Your specific commentary on these certification schemes is helpful. In the end, a forest certification
scheme will be deemed compliant by an independent, third-party evaluation of its criteria against
the Forest Certification Schemes Benchmarks requirements.




Thank you for your comments and suggestions. The benchmarks posted for this 2nd Public
Comment Period are revised to be clearer, better aligned with USGBC's Guiding Principles, and more
consistently present rigorous requirements. Additionally, USGBC does not intend for any benchmark
to be biased towards a particular forest certification scheme. Instead, USGBC intends for the
benchmarks collectively present the organization's definition of exemplary forest certification in all
aspects of a certification scheme, independent of any one scheme's previously established
guidelines.
Thank you for your comments. USGBC does not intend for any benchmark to be biased towards a
particular forest certification scheme. Instead, USGBC intends for the benchmarks collectively
present the organization's definition of exemplary forest certification in all aspects of a certification
scheme, independent of any one scheme's previously established guidelines.


Thank you for your comments. USGBC believes that prescriptive benchmarks are necessary to
ensure compliance with its own definition of exemplary forest certification. To gain recognition in
LEED, a forest certification scheme does not need to fulfill every benchmark. Please see the
accompanying Conformance Assessment Process to learn how USGBC intends to evaluate the forest
certification schemes against the finalized benchmarks.




Thank you for your comments and your extensive recommendations. USGBC hopes that the
revisions address some of your concerns about inconsistency, vagueness, and/or lack of rigor. The
revisions are intended to 1) clarify and elaborate on the benchmarks and 2) find a balance between
the valid concerns of the expert commenters and the central values and objectives of USGBC. The
revised benchmarks, whether Required or Distinguishing, collectively present USGBC's definition of
exemplary forest certification and its high standards to earn recognition in LEED.
Thank you for your comments.




Thank you for your comments and support. Your specific commentary on these certification
schemes is helpful. In the end, a forest certification scheme will be deemed compliant by an
independent, third-party evaluation of its criteria against the Forest Certification Schemes
Benchmarks requirements.




Thank you for your comments and suggestions. USGBC appreciates your insight regarding
permanent labeling. USGBC will consider how eco-labeling might benefit the Chain of Custody
process but not will not make it a required benchmark at this time.
Thank you for your comments and suggestions. USGBC appreciates your insight regarding
permanent labeling. USGBC will consider how eco-labeling might benefit the Chain of Custody
process but not will not make it a required benchmark at this time.




Thank you for your comments. The responses to your main points are as follows:
1. USGBC believes that prescriptive benchmarks are necessary to ensure compliance with its own
definition of exemplary forest certification. To gain recognition in LEED, a forest certification
scheme does not need to fulfill every benchmark. Please see the accompanying Conformance
Assessment Process to learn how USGBC intends to evaluate the forest certification schemes against
the finalized benchmarks.
2. Your specific commentary on these certification schemes is helpful. In the end, a forest
certification scheme will be deemed compliant by an independent, third-party evaluation of its
criteria against the Forest Certification Schemes Benchmarks requirements.
Thank you for your comments. The responses to your main points are as follows:
1. USGBC believes that prescriptive benchmarks are necessary to ensure compliance with its own
definition of exemplary forest certification. To gain recognition in LEED, a forest certification
scheme does not need to fulfill every benchmark. Please see the accompanying Conformance
Assessment Process to learn how USGBC intends to evaluate the forest certification schemes against
the finalized benchmarks.
2. Your specific commentary on these certification schemes is helpful. In the end, a forest
certification scheme will be deemed compliant by an independent, third-party evaluation of its
criteria against the Forest Certification Schemes Benchmarks requirements.




Thank you for your comments and suggestions. USGBC appreciates your insight regarding
permanent labeling. USGBC will consider how eco-labeling might benefit the Chain of Custody
process but not will not make it a required benchmark at this time.
Thank you for your comments. Your specific commentary on PEFC is helpful. In the end, a forest
certification scheme will be deemed compliant by an independent, third-party evaluation of its
criteria against the Forest Certification Schemes Benchmarks requirements.
Thank you for your comments and support of the proposed changes. USGBC will consider how to
require exemplary building materials in those sectors that have not yet established a third-party
certification program.




Thank you for your comments. The responses to your main points are as follows:
1. USGBC sincerely appreciates your insight on this certification scheme’s requirement. It helps
educate the process of finalizing the benchmarks.
2. USGBC does not intend for any benchmark to be biased towards a particular forest certification
scheme. Instead, USGBC intends for the benchmarks collectively present the organization's
definition of exemplary forest certification in all aspects of a certification scheme, independent of
any one scheme's previously established guidelines.
3. The “Plantations” benchmark is a part of USGBC’s high expectations for exemplary forest
certification. This benchmark is not required to gain recognition in LEED but will help a scheme
towards gaining recognition. Please see the comments and responses in the Standards section for
more.
4. As with the “Plantations” benchmark, this benchmark is a part of USGBC’s high expectations for
exemplary forest certification. While USGBC understands the importance sound science for
biotechnology, it does not believe that exemplary forest certification should allow for those
practices in active forests until the science is well established. Please see the comments and
responses in the Standards section for more.
certification. This benchmark is not required to gain recognition in LEED but will help a scheme
towards gaining recognition. Please see the comments and responses in the Standards section for
more.
4. As with the “Plantations” benchmark, this benchmark is a part of USGBC’s high expectations for
exemplary forest certification. While USGBC understands the importance sound science for
biotechnology, it does not believe that exemplary forest certification should allow for those
practices in active forests until the science is well established. Please see the comments and
responses in the Standards section for more.




Thank you for your comments. The responses to each of your main points are as follows:
1. USGBC does not intend for any benchmark to be biased towards a particular forest certification
scheme. Instead, USGBC intends for the benchmarks collectively present the organization's
definition of exemplary forest certification in all aspects of a certification scheme, independent of
any one scheme's previously established guidelines.
2. The provisions of those sections apply to non-certified sources that are included in the wood
product that nonetheless includes certified material.
3. Please see the comments and responses in the Standards Substance section for more on “forests
of social and environmental conservation value.”
Thank you for your comments. The responses to each of your main points are as follows:
1. USGBC does not intend for any benchmark to be biased towards a particular forest certification
scheme. Instead, USGBC intends for the benchmarks collectively present the organization's
definition of exemplary forest certification in all aspects of a certification scheme, independent of
any one scheme's previously established guidelines.
2. The provisions of those sections apply to non-certified sources that are included in the wood
product that nonetheless includes certified material.
3. Please see the comments and responses in the Standards Substance section for more on “forests
of social and environmental conservation value.”




Thank you for your comments. The benchmarks posted for this 2nd Public Comment Period are
revised to be clearer, better aligned with USGBC's Guiding Principles, and more consistently present
rigorous requirements.


Thank you for your comments. The responses to your main points are as follows:
1. USGBC sincerely appreciates your insight on this certification scheme’s requirement. It helps
educate the process of finalizing the benchmarks.
2. USGBC does not intend for any benchmark to be biased towards a particular forest certification
scheme. Instead, USGBC intends for the benchmarks collectively present the organization's
definition of exemplary forest certification in all aspects of a certification scheme, independent of
any one scheme's previously established guidelines.
3. The “Plantations” benchmark is a part of USGBC’s high expectations for exemplary forest
certification. This benchmark is not required to gain recognition in LEED but will help a scheme
towards gaining recognition. Please see the comments and responses in the Standards section for
more.
4. As with the “Plantations” benchmark, this benchmark is a part of USGBC’s high expectations for
exemplary forest certification. While USGBC understands the importance sound science for
biotechnology, it does not believe that exemplary forest certification should allow for those
practices in active forests until the science is well established. Please see the comments and
responses in the Standards section for more.
Thank you for your comments. USGBC believes that prescriptive benchmarks are necessary to
ensure compliance with its own definition of exemplary forest certification. To gain recognition in
LEED, a forest certification scheme does not need to fulfill every benchmark.

Please refer to the comments and responses of the Standards Substance section for elaboration on
your suggestion.

Your specific commentary on these certification schemes is helpful. In the end, a forest certification
scheme will be deemed compliant by an independent, third-party evaluation of its criteria against
the Forest Certification Schemes Benchmarks requirements.
Thank you for your support. Please note that it is not the intention of USGBC for the proposed
benchmarks to mirror any one certification scheme.




Thank you for your comments and concern. The responses to your specific comments are as follows:
1.USGBC recognizes that there is not an explicit path for project teams to earn credit for sourcing
their materials from small-scale producers or farmers. As such, it is recommended that project
teams seek a point in the Innovation and Design credit category, explicitly noting how the strategy is
comprehensive, quantifiable, and applicable to other projects.
2. Please note that it is not the intention of USGBC for the proposed benchmarks to mirror any one
certification scheme.
3.Please refer to the comments and responses of the Standards Substance section for elaboration
on your suggestion.
Thank you for your comments. Please refer to the comments and responses of the Standards
Substance section for elaboration on your suggestion.




Thank you for your comments and your extensive recommendations. USGBC hopes that the
revisions address some of your concerns about inconsistency, vagueness, and/or lack of rigor. The
revisions are intended to 1) clarify and elaborate on the benchmarks and 2) find a balance between
the valid concerns of the expert commenters and the central values and objectives of USGBC. The
revised benchmarks, whether Required or Distinguishing, collectively present USGBC's definition of
exemplary forest certification and its high standards to earn recognition in LEED.
Thank you for your comments and your extensive recommendations. USGBC hopes that the
revisions address some of your concerns about inconsistency, vagueness, and/or lack of rigor. The
revisions are intended to 1) clarify and elaborate on the benchmarks and 2) find a balance between
the valid concerns of the expert commenters and the central values and objectives of USGBC. The
revised benchmarks, whether Required or Distinguishing, collectively present USGBC's definition of
exemplary forest certification and its high standards to earn recognition in LEED.




Thank you for your comments. USGBC does not intend for any benchmark to be biased towards a
particular forest certification scheme. Your specific commentary on SFI and FSC certification
schemes is helpful. In the end, a forest certification scheme will be deemed compliant by an
independent, third-party evaluation of its criteria against the Forest Certification Schemes
Benchmarks requirements. The “Plantations” benchmark is a part of USGBC’s high expectations for
exemplary forest certification. This benchmark is not required to gain recognition in LEED but will
help a scheme towards gaining recognition. Please see the comments and responses in the
Standards section for more.
Thank you for your comments. Your specific commentary on these certification schemes is helpful.
In the end, a forest certification scheme will be deemed compliant by an independent, third-party
evaluation of its criteria against the Forest Certification Schemes Benchmarks requirements.




Thank you for your comments. The benchmarks posted for this 2nd Public Comment Period are
revised to be clearer and better aligned with USGBC's Guiding Principles. Your specific commentary
on these certification schemes is helpful. In the end, a forest certification scheme will be deemed
compliant by an independent, third-party evaluation of its criteria against the Forest Certification
Schemes Benchmarks requirements.
Thank you for your comments. Rest assured that USGBC does not intend to decrease the rigor of the
Certified Wood credits. The proposed changes and accompanying Forest Certification Scheme
Benchmarks are meant to increase the transparency by which USGBC chooses one or more scheme
for recognition in those credits. The stringency of the benchmarks ensures that wood used to earn a
point in the credit will continue to come from exemplary forest management practices. Additionally,
please refer to the comments and responses of the Standards Substance section for elaboration on
your suggestion.




Thank you for your comments. The responses to your main points are as follows:
1. USGBC sincerely appreciates your insight on this certification scheme’s requirement. It helps
educate the process of finalizing the benchmarks.
2. USGBC does not intend for any benchmark to be biased towards a particular forest certification
scheme. Instead, USGBC intends for the benchmarks collectively present the organization's
definition of exemplary forest certification in all aspects of a certification scheme, independent of
any one scheme's previously established guidelines.
3. The “Plantations” benchmark is a part of USGBC’s high expectations for exemplary forest
certification. This benchmark is not required to gain recognition in LEED but will help a scheme
towards gaining recognition. Please see the comments and responses in the Standards section for
more.
4. As with the “Plantations” benchmark, this benchmark is a part of USGBC’s high expectations for
exemplary forest certification. While USGBC understands the importance sound science for
biotechnology, it does not believe that exemplary forest certification should allow for those
practices in active forests until the science is well established. Please see the comments and
responses in the Standards section for more.
Thank you for your comments. The responses to your main points are as follows:
1. USGBC sincerely appreciates your insight on this certification scheme’s requirement. It helps
educate the process of finalizing the benchmarks.
2. USGBC does not intend for any benchmark to be biased towards a particular forest certification
scheme. Instead, USGBC intends for the benchmarks collectively present the organization's
definition of exemplary forest certification in all aspects of a certification scheme, independent of
any one scheme's previously established guidelines.
3. The “Plantations” benchmark is a part of USGBC’s high expectations for exemplary forest
certification. This benchmark is not required to gain recognition in LEED but will help a scheme
towards gaining recognition. Please see the comments and responses in the Standards section for
more.
4. As with the “Plantations” benchmark, this benchmark is a part of USGBC’s high expectations for
exemplary forest certification. While USGBC understands the importance sound science for
biotechnology, it does not believe that exemplary forest certification should allow for those
practices in active forests until the science is well established. Please see the comments and
responses in the Standards section for more.
Thank you for your comments. Your specific commentary on this certification scheme is helpful. In
the end, a forest certification scheme will be deemed compliant by an independent, third-party
evaluation of its criteria against the Forest Certification Schemes Benchmarks requirements.
Thank you for your comments. The responses to your main points are as follows:
1. USGBC sincerely appreciates your insight on this certification scheme’s requirement. It helps
educate the process of finalizing the benchmarks.
2. USGBC does not intend for any benchmark to be biased towards a particular forest certification
scheme. Instead, USGBC intends for the benchmarks collectively present the organization's
definition of exemplary forest certification in all aspects of a certification scheme, independent of
any one scheme's previously established guidelines.
3. The “Plantations” benchmark is a part of USGBC’s high expectations for exemplary forest
certification. This benchmark is not required to gain recognition in LEED but will help a scheme
towards gaining recognition. Please see the comments and responses in the Standards section for
more.
4. As with the “Plantations” benchmark, this benchmark is a part of USGBC’s high expectations for
exemplary forest certification. While USGBC understands the importance sound science for
biotechnology, it does not believe that exemplary forest certification should allow for those
practices in active forests until the science is well established. Please see the comments and
responses in the Standards section for more.
Thank you for your comments and suggestions. USGBC does not intend for any benchmark to be
biased towards a particular forest certification scheme.




Thank you for your comments. USGBC does not intend for any benchmark to be biased towards a
particular forest certification scheme. Instead, USGBC intends for the benchmarks collectively
present the organization's definition of exemplary forest certification in all aspects of a certification
scheme, independent of any one scheme's previously established guidelines. The “Plantations” and
“GMO” benchmarks are a part of USGBC’s high expectations for exemplary forest certification. The
benchmarks are not required to gain recognition in LEED.
Thank you for your comments regarding the FSC and SFI. In the end, a forest certification scheme
will be deemed compliant by an independent, third-party evaluation of its criteria against the Forest
Certification Schemes Benchmarks requirements. Please note that it is not the intention of USGBC
for the proposed benchmarks to mirror any one certification scheme.




Thank you. Your specific commentary on the CSA is helpful. In the end, a forest certification scheme
will be deemed compliant by an independent, third-party evaluation of its criteria against the Forest
Certification Schemes Benchmarks requirements.




Thank you for your comments and suggestions regarding urban forests.
Thank you for your comments and suggestions regarding urban forests.




Thank you for your comments and insight on your particular experiences. USGBC appreciates your
feedback and the example you provide, for it will greatly inform the process to finalize the
certification scheme benchmarks.
Public Comments
Do the proposed USGBC benchmarks relating to forest certification system Accreditation and
Auditing establish appropriate forest management requirements? Please explain and/or suggest
how the requirements might be improved.
Yes I believe so because auditing is conducted stringently.

Do any of the existing systems comply with the Accreditation and Auditing requirements as
established in the USGBC benchmarks?
Yes I believe FSC complies.

If yes, please explain indicate which systems comply and how they are compliant.
Yes I believe FSC complies.

If not, please explain how the existing systems are deficient.
I do not know.
Do the proposed USGBC benchmarks relating to forest certification system Accreditation and
Auditing establish appropriate forest management requirements? Please explain and/or suggest
how the requirements might be improved.
No. One of the hallmarks of the USGBC is third-party certification, and the Certified Wood credit(s)
relies on this independent oversight to maintain integrity. However, there are instances where this
level of rigor is undermined with a broader base for acceptance. For example, Funding: Making
funding sources publicly available does not necessarily equate to openness. The contrary is possible -
and highly likely - if the financial flow is motivated by the potential to sway regulation to assuage
private interests. In addition to publicizing monetary sources, there should be restrictions on
funding that prohibit contributions from those directly impacted by the regulations. Verification of
Acceptable Sources: Second-party claims are not sufficient to verify the legality of logging activities.
If Third Party auditing is required per the Accreditation section of the System Benchmark, it should
blanket the entire framework. Please refer to the comprehensive statement submitted to the
"Credit Language Revisions" comments page by the Cascadia Chapter of the USGBC.


Do any of the existing systems comply with the Accreditation and Auditing requirements as
established in the USGBC benchmarks?

I fully support the Cascadia Region Green Building Council formal response letter available at:
http://www.cascadiagbc.org/advocacy/Cascadia-Certifiedwood-letter

If yes, please explain indicate which systems comply and how they are compliant.
I fully support the Cascadia Region Green Building Council formal response letter available at:
http://www.cascadiagbc.org/advocacy/Cascadia-Certifiedwood-letter

If not, please explain how the existing systems are deficient.
I fully support the Cascadia Region Green Building Council formal response letter available at:
http://www.cascadiagbc.org/advocacy/Cascadia-Certifiedwood-letter
Do the proposed USGBC benchmarks relating to forest certification system Accreditation and
Auditing establish appropriate forest management requirements? Please explain and/or suggest
how the requirements might be improved.
I fully support the Cascadia Region Green Building Council formal response letter available at:
http://www.cascadiagbc.org/advocacy/Cascadia-Certifiedwood-letter
Do the proposed USGBC benchmarks relating to forest certification system Accreditation and
Auditing establish appropriate forest management requirements? Please explain and/or suggest
how the requirements might be improved.
Yes. I am not expert in accreditation and auditing, but the list of benchmarks seem adequate to
ensure a reliable accurate system of certification.

Do any of the existing systems comply with the Accreditation and Auditing requirements as
established in the USGBC benchmarks?
I am not prepared to comment on any particular forest certification system. It was my impression
from the materials supplied by USGBC that the Council was interested in comments on the
proposed benchmarks. I assumed that once the benchmarks were established, USGBC would use
them to assess individual forest certification systems and make a decision as to whether or not
individual systems qualified for certified wood credits under LEED. It seems out of place to be asked
to comment on which certification systems qualify when USGBC has not yet completed their
benchmarks for judging qualifications. Benchmarks should be established independent and separate
from judging any one certification system. Otherwise the benchmarks are open to bias for or against
one or another forest certification system. I am concerned that many of the benchmarks presented
for review by USGBC appear to be pulled directly from the current status quo wood credit certifier,
Forest Stewardship Council. I refer specifically to the Governing board structure, Plantations,
Chemical use, Aboriginal land and tenure rights and Acceptable non-certified sources for percent-
based claims. This practice, of course, creates an immediate bias in the comment process. USGBC
would be better served by following Yale University's lead in their assessment of current
Do the proposed USGBC benchmarks relating to forest certification system Accreditation and
Auditing establish appropriate forest management requirements? Please explain and/or suggest
how the requirements might be improved.
The benchmarks in certifier accreditation are appropriate and relfect internationally accepted
protocols.

Do any of the existing systems comply with the Accreditation and Auditing requirements as
established in the USGBC benchmarks?
Yes.

If yes, please explain indicate which systems comply and how they are compliant.
SFI has a fully independent certification body accreditaion program.

If not, please explain how the existing systems are deficient.
FSC auditors are approved and licensed by FSC and can not be viewed as independent to FSC.
Do the proposed USGBC benchmarks relating to forest certification system Accreditation and
Auditing establish appropriate forest management requirements? Please explain and/or suggest
how the requirements might be improved.


VFPA again has a concern that requiring certification through a separate program puts many family
owned and/or small business as a disadvantage, particularly where constant review of the resource
(by government entities) as well as resource protection laws and regulations support the end goals
of resource sustainability and environmental protection. VFPA furthermore feels that other
materials (such as steel, aluminum, concrete and masonry) should also be required to meet
certifications that their materials have been produced in a manner which insures all of the goals that
are desired with wood-based certification. To have a unique requirement that basically impacts only
one segment of the marketplace is unfair.

Do the proposed USGBC benchmarks relating to forest certification system Accreditation and
Auditing establish appropriate forest management requirements? Please explain and/or suggest
how the requirements might be improved.




Yes, the benchmarks in certifier accreditation are appropriate and reflect internationally accepted
protocols.

Do any of the existing systems comply with the Accreditation and Auditing requirements as
established in the USGBC benchmarks?
The SFI Program complies with the benchmarks.

If yes, please explain indicate which systems comply and how they are compliant.
The SFI Program has a fully independent certification body accreditation program. Accreditation
programs are overseen by IAF members. Further, there are specific accreditation programs for the
2005-2009 SFI Standard and for the SFI chain-of-custody and labeling standard, which comply with
their respective ISO guides. Accredited certification bodies are witnessed annually by the
accreditation body. The SFI certification process can only be completed by an accredited
certification body, which is an independent third party. The certification process requires field and
desk audits, consultation with stakeholders, and a public summary report is available on the SFI
website. Certification must be maintained with annual surveillance audits and re-certification every
5 years. The SFI Program has an open and transparent dispute resolution process that is overseen by
the accreditation bodies.


If not, please explain how the existing systems are deficient.
The FSC program is deficient in the following areas: · Certification Body Accreditation: According to
an ITTO report from October 2007: FSC was not fully compying with the ISO 17011 as the same
organization had responsibility for the setting of standards and the accreditation of certification
bodies. The problem was partially addressed through the separation of the standard and
accreditation service functions by creation of a new subsidiary company, ASI-Accreditation Services
International GmbH. Accreditation decisions are still made by the FSC Board of Directors upon the
recommendation of ASI which has carried out the evaluation on applicant certification bodies. ·
Dispute Resolution Process: The FSC program does not maintain an open and transparent dispute
resolution process. Only FSC members can file a dispute, and they must pay for it themselves. FSC
does not have an established process for handling disputes, only a interim document, dated April
1998.

Do the proposed USGBC benchmarks relating to forest certification system Accreditation and
Auditing establish appropriate forest management requirements? Please explain and/or suggest
how the requirements might be improved.
Same comments as before - USGBC should establish what accrediting and auditing is acceptable
before rolling out this change....
Do the proposed USGBC benchmarks relating to forest certification system Accreditation and
Auditing establish appropriate forest management requirements? Please explain and/or suggest
how the requirements might be improved.
No. Perkins + Will feels that the USGBC should maintain a strong performance standard for Wood
Certification in the LEED rating system. As a reflection of the USGBC's core values, the standard
should require continuous improvement through market transformation and must retain rigorous
social and environmental requirements founded on the best available objective science. A strong
Certified Wood Credit is important because the health of our forest eco-systems and their
inhabitants is vital to the health of our planet and our civilization. Forests cover 30% of the world's
land area and store over 50% of the world's carbon. The Certified Wood credit is the only LEED
credit that explicitly establishes criteria for all three core elements of Sustainability and the Triple
Bottom Line: Environment, Economics and Social Equity. While the intent of moving to a
performance based criteria for the credit language is acceptable, the verification process for
certification is critical for the Benchmark to be successful. It must be objective and transparent. In
addition, the membership should be presented with the process before voting on the final revisions.




Do any of the existing systems comply with the Accreditation and Auditing requirements as
established in the USGBC benchmarks?
Yes

If yes, please explain indicate which systems comply and how they are compliant.
The Forest Stewardship Council is a member organization.

If not, please explain how the existing systems are deficient.
The SFI BOD is elected by the existing board in a closed process. Thus the social and environmental
decision-makers are hand-selected by the existing board members.
Do the proposed USGBC benchmarks relating to forest certification system Accreditation and
Auditing establish appropriate forest management requirements? Please explain and/or suggest
how the requirements might be improved.



No, these proposed changes completely undermines the core value of high performance buildings.
The proposed yes/no vote on an undefined system and process is an insufficient opportunity to
comment upon a complex issue. We are being asked to vote on a benchmark standard that has not
been defined in detail and appears to be lacking critical information. We support the idea of
benchmark criteria if it includes fully developed and consistent criteria that is not in any way "less
than" the current FSC requirement. It appears as though the proposed criteria are inconsistent, not
in accordance with the USGBC's Guiding Principles, and also not consistent with the
recommendations of the Yale report. This blantant disregard will undermine the credibility of USGBC
and will appear that the USGBC lessoned the standards to allow large production forestry
companies to undermine the standards of high-performance buildings. We urge the tag committee,
USGBC board, stakeholders, members, etc to visit the following site for more information:
www.dontbuysfi.com. Why are we proposing to weaken the most riquorous forestry scheme with
one that is diluted and does not appear to offer transperency, openess, disverse govering
stakeholder group.

Do any of the existing systems comply with the Accreditation and Auditing requirements as
established in the USGBC benchmarks?
YES

If yes, please explain indicate which systems comply and how they are compliant.
FSC
If not, please explain how the existing systems are deficient.

Not applicable.

If yes, please explain indicate which systems comply and how they are compliant.
Various other benchmarking exercises such as that conducted by the Central Point of Expertise on
Timber have concluded that the predominant North American forest certification standards are
compliant. The four programs all provide for compliance with international normative institutions.
They have open membership, and clear and established accreditation and auditing processes. And
they all remain current and relevant through a regular standard review and assessment cycle.
International governments, notably the United Kingdom, Germany, France, European Union, Japan,
New Zealand and Switzerland, have reached similar conclusions through their research of these
standards, and recognize all four standards in operation in North America.


Do any of the existing systems comply with the Accreditation and Auditing requirements as
established in the USGBC benchmarks?
Yes. The four standards used in British Columbia and Canada - the Canadian Standards Association's
Sustainable Forest Management Standard (CSA), the Forest Stewardship Council (FSC), the
Programme for the Endorsement of Forest Certification schemes (PEFC), and the Sustainable
Forestry Initiative (SFI) - all comply with the Accreditation and Auditing requirements.


Do the proposed USGBC benchmarks relating to forest certification system Accreditation and
Auditing establish appropriate forest management requirements? Please explain and/or suggest
how the requirements might be improved.
The criteria for accrediting certifiers and auditing could be simplified, and references to accredited
certification bodies could be handled in a separate and clear policy statement. An additional policy
criterion should be added for certifier or registrar independence. The benchmark should require
that the certifier or registrar be completely independent of the accreditation body. This is necessary
to ensure there is no conflict or perceived conflict between the accreditation body and the certifiers
or registrars. Additionally, we ask that the USGBC exercise the same high level of openness,
transparency and independence as it proceeds with its own evaluation of the certification systems
against its benchmarks. We believe that the evaluation team should include independent, objective
evaluators separate from the teams that helped developed the benchmarks, to ensure that the
credibility and integrity of LEED and the USGBC are maintained.


Do the proposed USGBC benchmarks relating to forest certification system Accreditation and
Auditing establish appropriate forest management requirements? Please explain and/or suggest
how the requirements might be improved.
No. Perkins + Will feels that the USGBC should maintain a strong performance standard for Wood
Certification in the LEED rating system. As a reflection of the USGBC's core values, the standard
should require continuous improvement through market transformation and must retain rigorous
social and environmental requirements founded on the best available objective science. A strong
Certified Wood Credit is important because the health of our forest eco-systems and their
inhabitants is vital to the health of our planet and our civilization. Forests cover 30% of the world's
land area and store over 50% of the world's carbon. The Certified Wood credit is the only LEED
credit that explicitly establishes criteria for all three core elements of Sustainability and the Triple
Bottom Line: Environment, Economics and Social Equity. While the intent of moving to a
performance based criteria for the credit language is acceptable, the verification process for
certification is critical for the Benchmark to be successful. It must be objective and transparent. In
addition, the membership should be presented with the process before voting on the final revisions.




Do any of the existing systems comply with the Accreditation and Auditing requirements as
established in the USGBC benchmarks?
Yes

If yes, please explain indicate which systems comply and how they are compliant.
The Forest Stewardship Council is a member organization.

If not, please explain how the existing systems are deficient.
The SFI BOD is elected by the existing board in a closed process. Thus the social and environmental
decision-makers are hand-selected by the existing board members.
Do the proposed USGBC benchmarks relating to forest certification system Accreditation and
Auditing establish appropriate forest management requirements? Please explain and/or suggest
how the requirements might be improved.




Accreditation process; public input We disagree with the draft benchmark's assertion here. Public
consultation during certifier accreditation audits is a key requirement for credible certification
systems. It is an essential part of the information gathering process needed to ensure that all
relevant issues and information is addressed during accreditation audits. There should be a
mandatory benchmark. Certification process; public input; consultation of stakeholders This is an
important but highly insufficient benchmark. The scope and quality of a certification system's
consultation process is just as important as whether the process exists. Consultation needs to be
required for all certification audits, and needs to be broadly accessible to all knowledgeable and
interested stakeholders, not just those directly affected by the forest management in question. This
should be a mandatory benchmark. Certification process; quality control; peer review We disagree.
A benchmark is needed here. Peer review of certification audits and certification reports is an
important part of ensuring their quality, and is required by the world's more credible certification
systems.

Do any of the existing systems comply with the Accreditation and Auditing requirements as
established in the USGBC benchmarks?
Decline Comment until Benchmark and Process are Defined

If yes, please explain indicate which systems comply and how they are compliant.
Decline Comment until Benchmark and Process are Defined

If not, please explain how the existing systems are deficient.
Decline Comment until Benchmark and Process are Defined
Do the proposed USGBC benchmarks relating to forest certification system Accreditation and
Auditing establish appropriate forest management requirements? Please explain and/or suggest
how the requirements might be improved.
General Comments: Comments on Specific Benchmarks: Transparency- Reporting: Accreditation
reports are made publicly available. To achieve a meaningful level of transparency, the benchmark
should be strengthened to include public access to surveillance reports, any required corrective
actions or other disciplinary measures, and any complaints lodged against the certification body.
Accreditation Process - Public input: No specific benchmark - not considered a core issue, as long as
other benchmarks are met. The value of transparency (see item above) is contingent upon the
capacity of the public to submit input. Further, in many cases, only the local public has sufficient
local knowledge to adequately judge the quality of work by a certification body. This is a key issue
and public input mechanisms should be a stated benchmark. Public input - Notification (of
stakeholders by certifier): No specific benchmark - not considered a core issue, as long as other
benchmarks are met. This should be reconsidered as a core issue. Notification of the certification is
a central part of transparency and a credible certification system. Public input - Consultation (of
stakeholders by certifier): There is written policy that consultation with external stakeholders is

Do any of the existing systems comply with the Accreditation and Auditing requirements as
established in the USGBC benchmarks?
Decline comment until benchmarks and process are better defined.

If yes, please explain indicate which systems comply and how they are compliant.
Decline comment until benchmarks and process are better defined.

If not, please explain how the existing systems are deficient.
Decline comment until benchmarks and process are better defined.
Do any of the existing systems comply with the Accreditation and Auditing requirements as
established in the USGBC benchmarks?

Probably

If yes, please explain indicate which systems comply and how they are compliant.
You know, likely SFI. They have continually responded to public constructive criticism to improve
their program. If FSC would respond in the same fashion we'd have two GOOD programs to work
with.

If not, please explain how the existing systems are deficient.
FSC gives us no way to register and lobby our concerns. Just because I fabricate products from wood
they assume I don't care about the environment. Arrogant idiots.

Do the proposed USGBC benchmarks relating to forest certification system Accreditation and
Auditing establish appropriate forest management requirements? Please explain and/or suggest
how the requirements might be improved.
I like it.
Do the proposed USGBC benchmarks relating to forest certification system Accreditation and
Auditing establish appropriate forest management requirements? Please explain and/or suggest
how the requirements might be improved.
No, too closely aligned with FSC system.
Do any of the existing systems comply with the Accreditation and Auditing requirements as
established in the USGBC benchmarks?




yes

If not, please explain how the existing systems are deficient.
The SFI BOD is elected by the existing board in a closed process. Thus the social and environmental
decision-makers are hand-selected by the existing board members.

If yes, please explain indicate which systems comply and how they are compliant.
The Forest Stewardship Council is a member organization."

Do the proposed USGBC benchmarks relating to forest certification system Accreditation and
Auditing establish appropriate forest management requirements? Please explain and/or suggest
how the requirements might be improved.
No. The Criteria for Governance - Openness - Organizational type: "Membership organizations (i.e.
organizations governed by members) are open to all major interest groups, organizations and
individuals." should be changed. Proposed Revision: Membership organizations (i.e. organizations
governed by members) open to all major interest groups, organizations and individuals USGBC
should maintain a strong performance standard for Wood Certification in the LEED rating system. As
a reflection of the USGBC's core values, the standard should require continuous improvement
through market transformation and must retain rigorous social and environmental requirements
founded on the best available objective science. A strong Certified Wood Credit is important
because the health of our forest eco-systems and their inhabitants is vital to the health of our planet
and our civilization. Forests cover 30% of the world's land area and store over 50% of the world's
carbon. The Certified Wood credit is the only LEED credit that explicitly establishes criteria for all
three core elements of Sustainability and the Triple Bottom Line: Environment, Economics and
Social Equity. While the intent of moving to a performance based criteria for the credit language is
acceptable, the verification process for certification is critical for the Benchmark to be successful. It
Do the proposed USGBC benchmarks relating to forest certification system Accreditation and
Auditing establish appropriate forest management requirements? Please explain and/or suggest
how the requirements might be improved.
NO SFI - only FSC should be used.
Do the proposed USGBC benchmarks relating to forest certification system Accreditation and
Auditing establish appropriate forest management requirements? Please explain and/or suggest
how the requirements might be improved.
Yes, the benchmarks in certifier accreditation are appropriate and reflect internationally accepted
protocols.

Do any of the existing systems comply with the Accreditation and Auditing requirements as
established in the USGBC benchmarks?
The SFI Program complies with the Benchmarks

If yes, please explain indicate which systems comply and how they are compliant.
Proposed Benchmark - Accreditation system: Accreditation systems are specifically designed for
forest mgmt. and CoC. From the July 2008 SFI APQ: All certification, recertification and surveillance
audits to the SFI Standard shall be conducted by certification bodies accredited by the SCC or ANAB
to conduct SFI certification. Accredited certification bodies are required to: maintain audit processes
consistent with the requirements of International Organization for Standardization (ISO) 17021:2006
conformity assessment-Requirements for bodies providing audit and certification of management
systems; and conduct audits in accordance with the principles of auditing contained in the ISO
19011:2002 guidelines for quality and/or