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4. Learning Objectives
Understand the goals and history of forest certification
Understand the differences between the major forest
certification systems in North America
Understand the role of the green building movement in
fostering market transformation in the forest products industry by
supporting credible and stringent forest certification.
5. Forest Certification…
Sets standards for forest management
Establishes procedures for verification
Labels products
Connects demand to managed forests
Is officially intended to provide quality assurance
7. Brief History of Forest Certification
10
Perfect Forest
Management
0
No Forest
Management
5
Average Forest
Management
7.5
2.5
1994-95 – Forest products industry in U.S. (SFI), Canada
(CSA), and Europe (PEFC) launch competing systems in effort
to co-opt FSC, defend status quo
SFI
etc.
1995 to present – FSC and industry-based systems compete,
driving improvements in the latter, compromises in the former
FSC
1993 – FSC launched (largely by environmental groups) to
identify and drive “leadership forestry”
8. Forest
Stewardship
Council
Non-profit, global, HQ in Bonne, Germany
(www.fsc.org)
National Initiatives, FSC US in DC
(www.fscus.org)
Origins: mostly ENGOs, the most progressive
forest products companies, UK retailers
Current drivers: LEED, corporate purchasing policies, ENGO support
and pressure
WWF, Collins Companies, EcoTimber, B&Q
9. Currently governed by DC non-profit SFB
(www.aboutsfi.org)
Origins: AF&PA and its member companies
Weyerhaeuser, International Paper, GP, LP, Boise Cascade, etc.
Part of PEFC, European-based,
global through mutual recognition
(www.pefc.org)
Current drivers: AF&PA and its member companies, some government
purchasing programs, Green Globes
CPET
10. Program of Canadian Standards Association
(www.csa-international.org)
Non-profit HQ’d in Toronto
Also part of PEFC
Origins: Canadian forest industry and trade associations
Interfor, MacMillan Bloedel, Canadian Wood Council, etc.
Current drivers: Canadian forest industry, some government purchasing
programs, Green Globes
11. Comparing FSC & SFI/CSA/etc.
Lots of comparisons have been done over the years
Most current:
Yale Report for USGBC
http://www.yale.edu/forestcertification/usgbc.htm
EEM Inc Report
http://www.marketsinitiative.org/resources
Websites:
www.woodfloorrg.com
www.metafore.org
www.dontbuysfi.com
12. Comparing FSC & SFI/CSA/etc.
FSC SFI CSA
Prohibits the use of
genetically modified trees
Yes No No
Prevents the conversion of
natural forest to
plantations
Yes
(with a few
exceptions)
No No
Annual Allowable Cut per
hectare (2.47 acres)
0.43 m3/ha 1.27 m3/ha 0.75 m3/ha
Maximum clearcut size Regional
standards
(Pacific Region
40 acres max.
avg.
Natural forest
60 acres max.
Plantation
80 acres max.)
Regulatory limits
established by
state or
provincial law
(120 acres max.
avg., WA state
240 acres max.
BC province
See CSA)
Provincial
regulatory
requirements
must be met
(BC province
100 acres
max. Coast & S.
interior;
150 acres max.
N. & S. Interior)
13. Comparing FSC & SFI/CSA/etc.
FSC SFI CSA
Pesticides Promotes non-
chemical
methods of
pest
management,
includes
parameters on
prohibited
pesticides
Standard calls
for “minimizing
chemical use
required to
achieve
management
objectives,”
local laws
apply
Has a public
participation
process
where
pesticide use
may be
addressed,
local
regulations
High Conservation Value
Forest
Prescribes
precautionary
approach.
Regional
standards add
detail.
No explicit
protection of
old growth.
“Manage
lands of
ecologic…
significance in
a manner that
recognizes
their special
qualities.”
Conserve
ecosystem
diversity at the
landscape
level.
14. Comparing FSC & SFI/CSA/etc.
FSC SFI CSA
Labeling and
Chain of Custody
FSC 100% label
FSC Mixed Sources
label
(non-certified
component controlled)
FSC recycled label
100% of the fiber
comes from SFI
certified forests
At least x% of the
fiber comes from SFI
certified forests
100% Recovered
fiber
CSA 100% label
Minimum 70%
Content from a
Certified Forest
label
Illegal wood No illegally logged
wood allowed. Risk
Registry under
development.
No harvest in
protected areas
(e.g. parks)
No harvest in
protected areas
(e.g. parks)
Governance Board and
membership
divided into Social,
Environmental, and
Economic
chambers
SFB governs;
members include
representatives
from industry,
academia, some
conservation
NGOs
Technical committee
determines standard;
members include
industry government,
academia, “general
interests”
15. Comparing FSC & SFI/CSA/etc.
FSC SFI CSA
Total land area covered
worldwide by
certifications (August
2007)
225 million
acres
128 million
acres
183 million
acres
Scope of application Worldwide US & Canada Canada
Key supporters Many large
international
ENGOs to the
exclusion of
other systems.
Growing
industry and
market support
Major US
forest industry
companies
and trade
associations
Sectors of the
Canadian
forest industry
Key detractors Major US and
Canadian
forest
companies
and their trade
associations
Rejected as
lately as
October 2005
by key
conservation
NGOs
Numerous
NGOs claim
standard needs
improvement
16. Who are the Players in FSC Certification?
• Certified companies and their products
• Forest Stewardship Council
Sets standards, accredits certifiers
The Forest
Stewardship Council
• Accredited 3rd-Party Certifiers
SmartWood, Scientific Certification Systems, SGS, WoodMark, Silva Forest
Foundation, and others perform audits and issue certificates
17. FSC Certified Forests in North America
FSC Certified Forests
North America: 21.01 Mha
• 2 Countries
• 126 certificates
% of global total certified area: 30.85%
North America: 70 M acres
% of global total: 31.23%
(as of June 2007)
19. FSC and LEED
The Forest
Stewardship
Council
About 30% of LEED projects
have achieved MR 7
20. Certified Wood and LEED: Framing the Issues
0–3 on the quality scale
Illegal cut-and-run logging – forest
mining – no management or replanting
Forest conversion – to
agriculture, cattle pasture, or
semi-desert
Quality of Forest Management
0
No Forest
Management
5
Average Forest
Management
7.5
2.5 10
Perfect Forest
Management
21. Is Illegal logging a Real Problem? You Bet It Is!
Eastern Europe
Estonia 50% of production
Latvia 20% of production
Russia 15-60% of production
15-50% of exports
Africa
Cameroon 30-65% of production
Equatorial Guinea 30% of production
Gabon 30% of production
Ghana 30-50% of production
Liberia 30-100% of production
Source: WWF’s “Keep It Legal” Guide
22. E & SE Asia
China 30-50% of production
30-32% of export products
Malaysia 5% of production
70% of log imports
Indonesia 60-80% of production
55% of plywood exports
100% of log exports
Papua New Guinea 20% of production
65% of log exports
Latin America
Brazil 15-37% of production
Ecuador 70% of production
Peru 70-90% of production
> 90% of exports (mahogany)
27. Tropical Deforestation, Global Warming,
and USGBC’s Carbon-Neutrality Goals
Global Canopy Programme Report (May 2007)
Burning of tropical forests #2 source of CO2 emissions
Daily emissions equivalent of flying 7 million people from
London to New York
If we’re serious about tackling climate change,
it’s not enough to build energy-efficient, green-
powered buildings – we also need to combat
illegal logging and the burning of tropical forests
28. Certified Wood and LEED: Framing the Issues
Driven largely by short-term profit objectives
3-7 on the quality scale
Quality of Forest Management
0
No Forest
Management
5
Average Forest
Management
7.5
2.5 10
Perfect Forest
Management
Legal industrial forestry (e.g. SFI, CSA, etc.)
Tree farms – converting ecosystems into monocultures
Heavy reliance on chemicals – herbicides and fertilizers
Little regard for biodiversity or high-conservation value
forests (outside of parks)
“Log and flog” – clear the forest, sell the land for real estate
development
29. Large-scale conversion of natural forests to monoculture tree
farms is NOT sustainable
Large-scale clear-cutting of
natural forest generally means:
Habitat destruction
Soil erosion
Damage to rivers, streams
Loss of biodiversity
Reduced wood quality
Loss of recreational value
34. Certified Wood and LEED: Framing the Issues
Triple bottom line
Quality of Forest Management
0
No Forest
Management
5
Average Forest
Management
7.5
2.5 10
Perfect Forest
Management
7-10 on the quality scale
Leadership forestry
Natural forests managed to preserve ecosystem values
and environmental services
Plantation management preserves soil and water quality, limits
chemical use
Plantations complement rather than replace natural forests
Long-term tenure & management plans
35. LEED-Driven Market
Transformation
of the Forest Products Industry
10
Perfect Forest
Management
0
No Forest
Management
5
Average Forest
Management
7.5
2.5
FSC forestry
Industrial forestry
SFI, CSA, PEFC
Illegal logging
LEED
36. “A rising
sea lifts
all boats”
Weyerhaeuser
B
o
i
s
e
International Paper
Forest
Management
“Sea”
SFI/CSA/PEFC etc
“A rising
sea lifts
all boats”
37. Basic Principles
1) Forests are crucial for global environmental health and
sustainability – reservoirs of biodiversity and providers of
environmental services
2) A leadership standard in green building should protect
forests by only rewarding a leadership standard in forest
management
3) No illegal wood belongs on a green building project,
and the green building movement should actively
combat illegal logging to help stem tropical deforestation
4) Sustainable is more important than renewable; all bio-
based materials should be sustainably produced
38. Recommendations to USGBC
1) LEED should continue to reward only FSC or its equivalent
2) LEED should continue to treat wood separately from other bio-
based materials
Forests are special
Most other bio-based materials are agricultural products
FSC 2 points, SFI 1 point is not a solution -- undermines market transformation, 15 years
of progress in forest certification
Establish the benchmark for what constitutes FSC equivalency, review periodically
3) A new LEED prerequisite should require that all wood used on
LEED projects be legal
Wood from high-risk regions should have to be verified legal in order to be used on LEED
projects
SFI/CSA/PEFC have weaknesses in their labeling and chain of custody requirements, but if
addressed their labels = “products of legal industrial forestry” and could satisfy prerequisite
4) All bio-based materials should have to meet minimum
sustainability standards to be rewarded by LEED
MR 6 currently rewards rapidly renewable materials, but from a sustainability
standpoint, rapid growth matters little
All bio-based materials should be held to standards that address sustainability
39. Get Involved!
If you support our recommendations:
1) Visit www.workingforests.com and
www.credibleforestcertification.org for more info
2) Spread the word to your local USGBC chapter colleagues
and leadership
Nadav Malin, MR TAG Chair nadav@buildinggreen.com
Rick Fedrizzi, USGBC CEO rfedrizzi@usgbc.org
3) Voice your opinion to the USGBC leaders
deciding the future of the wood credit:
4) Stay in touch with us as we track the process
Terry Campbell terry@forestproductssolutions.com Jason Grant jgrant@woodfloorrg.com
Hinweis der Redaktion
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Here are the key learning objectives of this presentation.
Forest certification was conceived to be a mechanism for identifying responsible forest practices and practitioners across the spectrum of forestry options. Forest certification is based conceptually on certification for organic agricultural produce. As in agricultural certification, the process is founded on a detailed set of standards, only these standards relate to forest management. With the standards in hand, certifying agencies can audit the on-the-ground forestry practices of a given operation against them. If the operation meets the standards, products that flow from it can bear the certifier’s label and be differentiated in the marketplace, the idea being to connect market demand to high quality forest management. Note that the quality assurance aspect of forest certification only exists if the underlying standards of a forest certification program are sufficiently stringent. The official intention of forest certification is to provide quality insurance, but as we will see, there may be other motives underlying forest certification as well.
Today a number of forest certification programs exist in North America. This is very confusing – and this confusion may not be entirely accidental.
It’s easier to understand the landscape of competing forest certification systems if you understand the history of forest certification. But first, let’s suppose that all forest management takes place on a quality scale of zero to ten, where zero equals rape and pillage and ten is totally sustainable forestry. Forest certification was first conceived by environmental groups who wanted to create a mechanism to identify environmentally responsible practices and players – let’s say seven and better on the quality scale. This seminal forest certification system was called the Forest Stewardship Council (FSC). Shortly after the FSC was launched, the mainstream forest products industry in the U.S, Canada, and Europe reacted by launching their own forest certification systems, named respectively the Sustainable Forestry Initiative (SFI), the Canadian Standards Association’s sustainable forestry program (CSA), and the Pan European Forest Certification System (PEFC). In the beginning these industry-based forest certification systems had very weak standards and essentially put a green stamp on industrial-forestry-as-usual. The industry goal was to confuse the public, to attempt to co-opt the FSC, and to preserve the status quo. The environmental groups, however, immediately attacked the industry-based systems and exposed their flaws. As the FSC slowly grew, a competitive dynamic developed between it and the industry-based systems, leading to improvements in the latter and probably a relaxation of standards in the former as it grappled with implementation and uptake by progressive forest products companies. This dynamic continues to the present day.
Let’s look at the major systems operating in North America one by one. The FSC is a non-profit currently based in Germany whose reach is now global. At the individual country level, national offices exist in many countries, including the U.S. and Canada. In the U.S., there are regional standards that are tailored to the forest types and conditions of different parts of the country, but all of these regional standards are in conformance with the ten overarching principles and criteria of FSC International. As mentioned before, FSC’s roots mainly lie in the environmental community, but progressive forest products companies and retailers, particularly in the UK, also played a critical role in FSC’s early development. Examples include World Wildlife Fund, the Collins Companies here in the U.S., and B&Q in England, which is a bit like Home Depot. The main current market drivers for FSC in North America are LEED, a growing number of corporate purchasing policies (including Home Depot’s), and environmental advocacy groups like the Sierra Club, Greenpeace, Forest Ethics, and Rainforest Action Network.
The SFI was originally managed by the American Forest & Paper Association (AF&PA), but this looked too much like the fox guarding the hen-coop, so in recent years a non-profit Sustainable Forestry Board was created. The SFB is composed of forest products industry representatives, academics, professional foresters, and recently representatives of at least two major conservation groups, The Nature Conservancy and Conservation International, both of which want to see the SFI continue along a path of gradual improvement. SFI is part of PEFC, which evolved from a European-based system to a global umbrella for industry-based forest certification systems around the world, keeping the same acronym but changing names from the Pan European Forest Certification scheme to the Programme for the Endorsement of Forest Certification. As we’ve noted, SFI’s origins lie huge forest products companies like Weyerhaeuser, IP, GP etc. and their trade association, AF&PA. The main drivers for SFI today are those same entities as well as certain government purchasing programs, including the Central Point of Expertise on Timber purchasing in the UK, as well as Green Globes, a competing green building rating system to LEED that treats all forest certification systems equally and has enjoyed extensive covert funding and public promotion by AF&PA and its members, extending the pattern of co-optation and confusion from the forest certification arena to the green building certification arena.
The Canadian Standards Association is a non-profit ANSI-accredited certifier of numerous Canadian products, including lighting and consumer goods as well as forest products. It is also under the PEFC umbrella. Like SFI, CSA’s forest certification program has its roots in industry and industry associations. Also like SFI, CSA is currently driven by the industry that created it as well as supporters in government procurement and its proxies in green building.
For those who want to better understand the differences between FSC and the industry-based systems, there are two very recent and thorough comparisons of FSC, CSA, and SFI . One of them was developed by the Yale School of Forestry for USGBC to help them find their way forward on the wood issue. This was released in draft form in September of 2007. The other was completed in spring of 2007 and also released in the fall, and was conducted by EEM Inc., an environmental management consultancy out of Montreal. The slides that follow draw information from both Yale and EEM’s work. There are also several websites that compare the systems, but these are somewhat more dated and perhaps less thorough and independent.
One of the great strengths of FSC is that, with rare exceptions, it doesn’t allow the conversion of biodiverse natural forests to ecologically impoverished monocultures. In comparing clearcut sizes, note that in Canada provincial regulations allow clearcuts to be located nearly adjacent to each other, separated by only a fringe of trees, and in Washington, state regulations allow an adjacent clearcut only four years after the first one.
Another important aspect of FSC is that it contains strong protections of high conservation value forests, which include most “old growth” or ancient forests. CSA and SFI contain no explicit protections for these forests outside of those afforded by law.
While all systems have labels that allow for a mix of certified and non-certified wood, only FSC places controls on the non-certified component of mixed sources products, prohibiting the use of wood from high conservation value forests, illegal logging, forest conversion, GMOs and other controversial sources. FSC is also developing a Risk Registry to better identify wood that comes from areas where there is a high risk of these types of activities. SFI has the weakest label, placing no minimum on certified content. Neither SFI or CSA controls non-certified content. Importantly, the systems also differ in how they define illegal wood. SFI and CSA have very narrow definitions of illegality, limiting it to the logging of trees in parks and preserves. In fact, a majority of the illegal logging in the developing world takes place outside of protected areas and can only be addressed by a broader and more comprehensive definition. Finally, the governance systems of SFI and CSA are clearly weighted to industry, while FSC has a unique tri-partite system at both the membership and board levels that balances social, environmental, and economic interests.
Both systems are large and growing, but the PEFC-endorsed industry-based schemes represent a larger land base overall. As one might expect, the major supporters of FSC are the main critics of SFI, CSA, et al. and vice versa. The executive summary of the EEM report concludes: “ EEM Inc finds that a sustainable forest is most likely to exist under an FSC certification. A CSA certification can be acceptable but further knowledge of the forest management practices is required to be sure that the environmental performance of the forest is adequately defined and managed. The SFI program is weaker with respect to forest management practices and the lack of independence in the certification process in the past means that it is still struggling with credibility issues. Some improvements have been made, but implementation of these will take time.”
Let’s take a quick look at FSC and how it works. FSC International sets the broad standards (Principles and Criteria) and accredits the certifiers who go out and perform the actual audits and issue certificates. Of course, the other key players are the certified companies and their products.
FSC has grown significantly in North America, especially in recent years. Today there are around 70 million acres of FSC certified forest in the U.S. and Canada, representing about 31% of the global total.
Much of the increase in FSC certified forests has been in temperate and boreal forests with more moderate growth in the tropics.
LEED is probably the largest factor in FSC’s growth in recent years. At first it was difficult for LEED projects to achieve the certified wood credit, MR 7, but it is getting easier as project teams grow more proficient at sourcing and the base of product manufacturers and distributors grows. About 30% of LEED projects have achieved MR 7.
Let’s frame the issues that USGBC faces in revising the certified wood credit, starting by returning to our quality scale and considering the bottom end – what does zero to three on the scale really mean? In general, it represents the worst of the worst – the illegal mining of timber with no view to the future. Such practices often result in conversion and deforestation.
Is illegal logging a problem? Oh yes it is! These figures come from World Wildlife Fund’s Keep It Legal Guide which is an excellent resource on the subject.
Most of the wood that China produces domestically is grown in plantations, but as manufacturer to the world, it imports huge quantities of illegal logs from around the world, launders the wood into value-added products like flooring and furniture, and exports much of it to us. Note that 100% of Indonesia’s log exports are illegal because it is against the law to export roundwood from Indonesia.
Logging is not the main direct cause of forest loss in the tropics, but irresponsible and illegal logging is often the first step in a process that ends in total deforestation. Loggers build roads into previously inaccessible areas of primary forest and harvest mature specimens of commercially-valuable tree species. Since these last usually grow dispersed in the forest, they leave plenty of trees behind, but they also leave a road, and the forest that remains no longer contains much valuable timber.
Roads made for logging and other types of development become pathways for settlement, often by the poorest of the poor. As populations in the developing world continue to swell, increasing numbers of landless and desperate people need places to live and ways to subsist. Often national and regional governments offer perverse incentives for forest conversion, granting land tenure to families who clear and settle forest land.
The most common survival activity for the poor people in the tropics who clear and settle previously forested areas is subsistence, slash-and-burn agriculture—growing crops to eat. Across much of the tropics, soil quality is very poor. When trees and other vegetation are cut down and burn, this releases a rich influx of nutrients into the soil, but these nutrients are soon used up by food crops and unless they are replaced, the crops will fail after a number of years and the subsistence farmer will move on.
The result is that every year hundreds of thousands of acres of tropical forest go up in smoke, quickly converting the richest ecosystems on the planet into atmospheric carbon dioxide which in turn contributes to global warming.
The burning of tropical forests is a major factor in climate change. A recent study by a UK-based consortium of scientists found that such burning represents the second largest source of carbon dioxide emissions after the energy sector, accounting for 18 to 25% of the total. If we want to combat global warming, we need to do more than design better buildings and make the transition to renewable energy – we also need to harness the power of the green building movement to combat illegal logging.
Now let’s take a look at the middle part of the quality scale – three to seven. This represents legal industrial forestry, and these are the practices that most SFI and CSA certifications represent. Industrial forestry is driven largely by profit maximization as it is dominated by publicly traded companies that must put shareholder value first. This leads to an agricultural model that relies on tree farms, which in turn are often created at the expense of natural forests. There is a heavy reliance on chemical herbicides and fertilizers. Sometimes logged-over forest is sold for development rather than being replanted. And in general, there is little regard for biodiversity or high conservation value forests outside of areas that are protected by law.
Industrial forestry of this kind is not sustainable. Landscape-level clearcutting and forest conversion harms the land and its inhabitants and damages the environmental services that healthy forests provide. It results in a dwindling of the reserves of biodiversity and ecological complexity that will be increasingly important in a world facing potentially rapid climate change.
What does SFI- and CSA-certified logging look like? Let’s see…
Does this look sustainable to you?
How about this?
Just two-three years prior to the bottom picture was taken, this was occupied habitat used by reproducing Spotted Owls. Spotted Owls are a listed species under the Endangered Species Act and harming them is illegal under federal law. This photograph depicts an area of Southwest Washington that was the subject of a federal court case brought by Seattle Audubon against Weyerhaeuser. A Federal Judge ordered Weyerhaeuser to stop logging in four occupied owl circles because any further logging would harm these owls. She made this decision in July, 2007. Clearly harm has been occurring throughout much of SW Washington wherever owls exist.
Finally, let’s consider the top end of the quality scale – seven to ten. This represents leadership forestry. Some of the hallmarks of leadership forestry are a triple bottom line – seeking to balance social, economic, and environmental goals and results. Long-term tenure and management are important to leadership forestry – the best managers tend to be those who have an enduring stake in the forest they are managing. Natural forests are managed in such a way that their essential ecological integrity is preserved, as are their environmental services. Plantations are managed responsibly, and crucially, they enhance rather than replace natural forests.
Now let’s consider the role that LEED has played in driving market transformation in the forest products industry. It has done this by focusing growing demand on the leadership forestry represented by FSC. 5 years ago or so, it looked like FSC in North America might fail. But with the growth in LEED, it rebounded and began to grow. The continuing existence of FSC, and the competitive dynamic between FSC and the industry-based systems that was described earlier, has driven important improvements in SFI and CSA. Because most industrial forests in North America are now certified under these systems, improving their minimum standards translates into important environmental gains across the board. However, the moment that LEED recognizes these systems by awarding a point for their products, improvement is likely to slow or cease.
Here is another way of conceptualizing this. We have all heard the expression, “A rising sea lifts all boats.” Industrial forestry and industry-based certification represent the “sea” of forest management, the baseline for acceptable practice in North America. The “boats” on this sea are the major forest products companies. In this analogy, FSC – and LEED – represent the “moon,” whose gravitational force raises the forest management sea and all the boats that float on it.
What really matters here is not one acronym or another. This is about fundamental principles of sustainability.
Our recommendations to USGBC are based on the preceding basic principles. LEED should continue to drive market transformation in the forest products industry by only recognizing FSC or its equivalent, and it should establish the benchmark for judging equivalency. A leadership standard in building should only reward a leadership standard in forestry, and today FSC is clearly the certification system that is most aligned with USGBC’s stated mission and guiding principles. Wood should be treated separately from other bio-based materials, almost all of which are agricultural products or by-products, whereas much wood comes from forest ecosystems rather than monocultures. LEED should establish and phase in a new prerequisite that prohibits the use of illegal wood on LEED projects. Illegal wood has no place in green building, and we need guarantees that wood from high-risk regions is legal. Crucially, the industry-based systems can provide this quality assurance with relatively modest improvements in their chain-of-custody and labeling rules. If they do so, then they can be relied on to satisfy the prerequisite requirements. Finally, all bio-based materials should have to meet minimal standards of sustainability and should eventually be certified as such. Renewable is only renewable over the long term if production is sustainable. Requirements for credible certification of non-wood bio-based materials should be developed and phased in to give industry time to adjust.
Our recommendations to USGBC are based on the preceding basic principles. LEED should continue to drive market transformation in the forest products industry by only recognizing FSC or its equivalent, and it should establish the benchmark for judging equivalency. A leadership standard in building should only reward a leadership standard in forestry, and today FSC is clearly the certification system that is most aligned with USGBC’s stated mission and guiding principles. Wood should be treated separately from other bio-based materials, almost all of which are agricultural products or by-products, whereas much wood comes from forest ecosystems rather than monocultures. LEED should establish and phase in a new prerequisite that prohibits the use of illegal wood on LEED projects. Illegal wood has no place in green building, and we need guarantees that wood from high-risk regions is legal. Crucially, the industry-based systems can provide this quality assurance with relatively modest improvements in their chain-of-custody and labeling rules. If they do so, then they can be relied on to satisfy the prerequisite requirements. Finally, all bio-based materials should have to meet minimal standards of sustainability and should eventually be certified as such. Renewable is only renewable over the long term if production is sustainable. Requirements for credible certification of non-wood bio-based materials should be developed and phased in to give industry time to adjust.