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LEED Pilot Credit to Promote Product Transparency-Not Performance

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USGBC wants to increase product transparency through certifications, but will its members buy the idea that approved standards are not being endorsed?

USGBC wants to increase product transparency through certifications, but will its members buy the idea that approved standards are not being endorsed?

By Nadav Malin

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Product content eligible for Pilot Credit 43 has to comply with one or more of these attributes, and may receive weighted credit.

U.S. Green Building Council

In its newly released Pilot Credit 43, the U.S. Green Building Council (USGBC) has created a new incentive for product manufacturers to obtain third-party certification of their environmental claims, and to release environmental footprint data. The new credit is available for use immediately and applies to all the Building Design & Construction and Interiors Design & Construction LEED rating systems, such as LEED-NC and LEED-CI. The credit includes two parallel tracks: products can either be certified to approved standards or manufacturers can offer product data in approved formats.

It’s about disclosure, not environmental performance

Existing LEED credits, most famously the certified wood credit, have focused on the environmental attributes behind certifications, leading USGBC and its members and stakeholders to choose favored programs, notably the Forest Stewardship Council (FSC). In contrast, “This credit is about identifying certification types, nothing about our preferences about them,” Whit Faulconer, director of LEED, explained to EBN, noting that as long as the information is public or certified even products with poor environmental footprints can qualify. That’s why, according to Faulconer, there is only one point associated with the credit: product performance is rewarded elsewhere in LEED.

Performance vs. transparency

There is already confusion on the difference between performance and transparency, though. According to Chris Nelson, director of commercial development for UL Environment, which has been watching the credit, Pilot Credit 43 “works to underpin USGBC’s focus on both performance and transparency,” with the certifications supporting performance and the product declarations providing transparency.

The difference in interpretation is not just academic: in releasing this credit, USGBC also published a preliminary list of approved product standards and programs that can be used in claiming this credit. The list is evolving rapidly, according to Faulconer. For example, product emissions certifications such as Greenguard are not included in the initial version because of how the credit evolved, but will be added very shortly. The list includes forest certification programs such as the Sustainable Forestry Initiative, that have been highly controversial in relation to LEED’s certified wood credit—something that is likely to provoke environmental advocates.

The credit language also refers to a forthcoming (and long-awaited) “LEED Standard for Standards” document that will provie criteria that certification programs have to meet to be approved.

As with all LEED pilot credits, a project team can earn an innovation point just for documenting an earnest attempt to earn the credit and filling out a survey about their experience (the number of innovation points a project can earn is limited). If this pilot credit were to become adopted as a regular credit in LEED, however, it would require that at least 10% of products and materials, by dollar value, are certified or supported by a conforming life-cycle assessment (LCA) or environmental product declaration (EPD).

Different rewards for different certifications

Different types of certifications and declarations are rewarded differently (see table). In the certifications pathway single-attribute claims such as recycled content earn 50 cents on the dollar, while multi-attribute certifications are worth the full dollar, and those based on standards supported by LCAs and full EPDs get double value. No such standards meeting this last requirement exist today, according to both Faulconer and Nelson, because there is not yet enough consistent LCA data to create the benchmark for those standards; this option is included as a indicator of where USGBC wants the market to go.

In the EPD pathway, an LCA that meets specific requirements but is not third-party validated is valued at half, an LCA-based EPD that applies to an entire industry gets full value, and a product-specific LCA-based EPD earns double credit. There are not many product-specific EPDs available right now, but this credit may help change that. “We’re looking to go to market quickly with our EPD program, so those in the industry can see what’s going on with LCA and data,” said Nelson of UL Environment. In the meantime Melissa Vernon, director of sustainable strategies at InterfaceFLOR confirmed that their EPDs will already qualify at the 200% level. Also, the credit allows for double-counting across the two pathways, and most InterfaceFLOR products are also certified under a multi-attribute standard (NSF-140), so they’ll actually count at 300%.

With this pilot credit USGBC is attempting to release an incentive tied to process (independent validation and transparency), not results, but it’s hard to keep those separate. It won’t be easy to keep people from looking at the certifications as establishing LEED’s position on desirable performance.

For more information:

LEED Pilot Credit Librarywww.usgbc.org

Pilot Credit 43 Form on LEEDuserwww.leeduser.com

 

Comments (4)

1 product transparency posted by Lloyd Alter on 06/17/2011 at 05:43 am

I am very confused about this. I received an email from the Sierra Club:

After years of debate over which forest certification systems are worthy of LEED recognition, in this pilot credit, USGBC suddenly and without explanation ranks all forest certification systems - FSC, SFI, American Tree Farm, PEFC and CSA - as equivalent (see list of Pre-approved Certifications and Labels at the end of the pilot credit)...FSC gets half the weight of "Type 1 Environmental Labels" defined as "voluntary, multi-criteria based third party program[s]...which authorize the use of environmental labels on products indicating overall environmental preferability of a product within a particular product category based on life cycle considerations." Pre-approved labels/programs include NSF's Sustainability Assessment for Resilient Floor Coverings, ULE's standard for Gypsum board, and CCD's standard for Energy Efficient Harmonic Cancelation Transformers. By this reckoning, dioxin-producing but above-average vinyl flooring, non-renewable but above-average gyp-board, and energy-saving harmonic cancelation transformers (whatever those are) are all twice as green as certified sustainably harvested wood.

I don't see that at all.

2 response to Lloyd posted by Tristan Roberts on 06/17/2011 at 06:55 am

I think the issue is that the Pilot Credit makes the FORM of certifications the priority, in broader strokes than the kind of deep study that USGBC made into the substance of FSC vs. SFI et al.

As long as certifications meet basic thresholds for transparency, LEED is treating them equally for the purposes of this pilot credit. Emphasis on "for the purposes of this pilot credit." This credit is valid for one innovation point in current versions of LEED and is not being considered for LEED 2012.

Clearly there is going to some reaction to this approach -- that the substance of the certification can't be completely separated from its form -- and it will be interesting to see how strongly that critique carries the day vs. the view that transparency is important enough in itself to reward modestly.

3 USGBC is trying to separate p posted by Nadav Malin on 06/17/2011 at 06:56 am

USGBC is trying to create an incentive here for process (getting products certified and/or releasing data in EPDs) that is divorced from the substance--what those certifications actually mean. They think this makes sense because the substance issues are addressed in the specific credits (MRc7, EQc4, etc.) But clearly that distinction is lost on the Sierra Club, and many others (as noted in the story above).

What do you think--is that a valid distinction?

4 Transparency should mean just posted by Jason Grant on 06/17/2011 at 06:55 pm

If the point of this credit is to promote product transparency, not performance, then it should stick to LCA and LCA-based EPDs - as well as other transparency tools like Pharos.

Instead, this credit intermingles performance standards - ones with very different levels of rigor - with LCA-based tools. What a mess.

It renders FSC equivalent to SFI, which is not only unfair and inaccurate, it's plain stupid given the history of the controversy over forest certification in LEED - this is the political equivalent of giving the finger to the environmental community and many sustainable design leaders who have argued strenuously to maintain LEED's preference for FSC.

Is this the "thinking" that we can expect to inform the soon-to-be-released next version of LEED 2012? If so, the controversy over the certified wood credit revision may pale in comparison to the controversy to come.

The real question here is, what is the future of USGBC and LEED? Going forward, will LEED be a true leadership standard dedicated to driving market transformation in the built environment and the myriad industries that supply it? Will it focus on the top 20% of practice, or will it be a mainstream, something-for-everyone kind of affair, where the basic philosophy is "a rising sea lifts all ships" and incremental progress over the status quo is better than no progress at all? If the latter, then perhaps leadership will be focused on relatively non-controversial areas, like energy efficiency and carbon footprinting. The real sustainable design professionals and ENGOs will look elsewhere for cutting-edge thinking, courageous leadership and market transformation.

If it's the latter, however, then the active USGBC membership and the board of directors should come out and say so. If LEED is truly a leadership standard - and intends to remain one - then the reference standards and LEED 2012 credits should all reflect this core mission.

This is about the soul of USGBC, the heart of LEED, and the enduring meaning of green. No small thing.

But if

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June 16, 2011