SC Comments on USGBC Benchmark 4th Comment Period

Jason Grant

Description

thSierra Club Forest Certification Committee - Comments on 4 Version of USGBC’s Forest Certification Benchmark After logging in, we are given the choice to submit comments as follows: • Benchmark Governance section • Benchmark Standards Substance section • Benchmark Chain of Custody section • Benchmark Accreditation and Certification Process section • General Comments Benchmark Governance Section If we choose “Benchmark Governance section,” we are presented with a list of the Governance prerequisites and credits that are open to public comment in this round. • Gp1 (Governing Structure) • Gp2 (Decision Making) • Gp3 (Balloting I) • Gp8 (Organization Type) • Gp9 (Dispute resolution for standards writing) • Gc4 (Balloting II) Selecting any of them opens two dialog boxes with the following prompts: Prereq/ “Do you believe that the “Do you have any suggestions on Credit prerequisite/credit is appropriate how to improve the technical for exemplary forest certification requirements of the (e.g. technical rigor, market prerequisite/credit? Please explain, usability, environmental providing citations to data and performance)? Please explain” research where possible” Gp1 No. The language and requirements The following language is suggested: are insufficiently specific to ensure “The entity responsible for the a balance of interests and Certification scheme has governance stakeholders. structures that 1) provide balanced representation ...

Informations

• Publié par: Octe
• Nombre de lectures: 14
• Langue: English

Extrait

1

Sierra Club Forest Certification Committee - Comments on 4

th

Version of USGBC’s Forest Certification Benchmark

After logging in, we are given the choice to submit comments as follows:

•

Benchmark Governance section

•

Benchmark Standards Substance section

•

Benchmark Chain of Custody section

•

Benchmark Accreditation and Certification Process section

•

General Comments

Benchmark Governance Section

If we choose “Benchmark Governance section,” we are presented with a list of the

Governance prerequisites and credits that are open to public comment in this round.

•

Gp1 (Governing Structure)

•

Gp2 (Decision Making)

•

Gp3 (Balloting I)

•

Gp8 (Organization Type)

•

Gp9 (Dispute resolution for standards writing)

•

Gc4 (Balloting II)

Selecting any of them opens two dialog boxes with the following prompts:

Prereq/

Credit

“Do you believe that the

prerequisite/credit is appropriate

for exemplary forest certification

(e.g. technical rigor, market

usability, environmental

performance)? Please explain”

“Do you have any suggestions on

how to improve the technical

requirements of the

prerequisite/credit? Please explain,

providing citations to data and

research where possible”

Gp1

No. The language and requirements

are insufficiently specific to ensure

a balance of interests and

stakeholders.

The following language is suggested:

“The entity responsible for the

Certification scheme has governance

structures that 1) provide balanced

representation of social, environmental

and economic interests; and 2) 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.”

Gp2

Yes.

None.

2

Gp3

Yes, but only partially.

The following language is suggested:

“The entity responsible for the

certification scheme requires that 1)

major changes to the entity’s policies

and standards be decided by

membership ballot; and 2) balloted

decisions be approved by at least 1/3

rd

of the votes from representatives of

environmental, social, and economic

interests, respectively.”

Gp8

Yes, but only partially.

The following language is suggested:

“The entity responsible for the

certification system is a member-based

organization open to all organizations

and individuals who demonstrate

commitment to the system’s guiding

principles. A majority of the entity’s

board of directors are elected by the

membership.”

Gp9

Yes.

None.

Gc4

Yes

None.

Benchmark Standards Substance Section

If we choose “Benchmark Standards Substance section,” we are presented with the

following prerequisites and credits that are open to public comment in this round.

•

Sp6 (Plantations)

•

Regulatory equivalent alternative compliance path

Prereq/

Credit

“Do you believe that the

prerequisite/credit is

appropriate for exemplary forest

certification (e.g. technical rigor,

market usability, environmental

performance)? Please explain”

“Do you have any suggestions on

how to improve the technical

requirements of the

prerequisite/credit? Please explain,

providing citations to data and

research where possible”

Sp6

No. Forestry operations that have

recently converted natural forests

into plantations should not be

recognized as exemplary forest

management.

The cut-off date for the prohibition on

the conversion from natural forests to

plantations should be no later than

1998, the year that LEED was

launched.

Regulatory

equivalent

No.

USGBC has opened up a large

loophole affording compliance with

3

alternative

compliance

path

the Benchmark through existing legal

structures. One of the central roles of

certification is independent

confirmation that laws are being

followed. Even in the most regulated

states in one of the most regulated

countries (e.g. California of the US),

auditors find non-compliance with

laws. Forest operations in the US are

renowned for violations of laws both

in the social realm dealing with

worker health and safety and well as

environmental laws.

Benchmark Chain of Custody Section

If we choose “Benchmark Chain of Custody section,” we are presented with the

following prerequisites and credits that are open to public comment in this round.

•

Cp3 (Acceptable non-certified sources for percent-based claims)

•

Cp4 (Definition of legality)

•

Regulatory equivalent alternative compliance path

Prereq/

Credit

“Do you believe that the

prerequisite/credit is

appropriate for exemplary forest

certification (e.g. technical rigor,

market usability, environmental

performance)? Please explain”

“Do you have any suggestions on

how to improve the technical

requirements of the

prerequisite/credit? Please explain,

providing citations to data and

research where possible”

Cp3

No.

Maintain language from version 3 of

the benchmark.

Cp4

Yes.

None.

Regulatory

equivalent

alternative

compliance

path

No.

USGBC has opened up a large

loophole affording compliance with

the Benchmark through existing legal

structures. One of the central roles of

certification is independent

confirmation that laws are being

followed. Even in the most regulated

states in one of the most regulated

countries (e.g. California of the US),

auditors find non-compliance with

laws. Forest operations in the US are

renowned for violations of laws both

in the social realm dealing with

worker health and safety and well as

4

environmental laws.

Benchmark Accreditation and Certification Process Section

If we choose “Benchmark Accreditation and Certification Process section,” we are

presented with the following prerequisites and credits that are open to public comment in

this round.

•

Ap8 (Dispute resolution)

•

Ac2 (International codes of practice)

•

Regulatory equivalent alternative compliance path

Prereq/

Credit

“Do you believe that the

prerequisite/credit is

appropriate for exemplary forest

certification (e.g. technical rigor,

market usability, environmental

performance)? Please explain”

“Do you have any suggestions on

how to improve the technical

requirements of the

prerequisite/credit? Please explain,

providing citations to data and

research where possible”

Ap8

Yes.

None.

Ac2

Yes.

None.

Regulatory

equivalent

alternative

compliance

path

No.

USGBC has opened up a large

loophole affording compliance with

the Benchmark through existing legal

structures. One of the central roles of

certification is independent

confirmation that laws are being

followed. Even in the most regulated

states in one of the most regulated

countries (e.g. California of the US),

auditors find non-compliance with

laws. Forest operations in the US are

renowned for violations of laws both

in the social realm dealing with

worker health and safety and well as

environmental laws.

General Comments

If we choose “General Comments,” we are presented with following dialog box:

“Do you have any general concerns about the revisions that cannot be addressed in the

comment fields for the individual credit or Benchmark revisions?”

In releasing this draft of the benchmark and associated documents, USGBC has

apparently disregarded previous comments submitted by Sierra Club and numerous

5

others to better define the Conformance Assessment Process (CAP) by which forest

certification systems will be judged against the benchmark.

USGBC also disregarded Sierra Club’s call EITHER for a return to the minimum level of

recognition contained in the second draft of the benchmark -- prerequisites plus 40% of

optional credits for minimum recognition OR for elevating a number of credits to the

status of prerequisites: Gc2, Gc4, Gc5, Sc3, Sc5, Sc6, Sc7, Sc9, Sc10, Sc11, Sc14, Sc15

and Ac1 should be made Prerequisite criteria for recognition of any certification system.

Finally, the revised Certified Wood Credit does not incentivize the use of products with

100% content from certified forests without unduly penalizing the use of products that

contain a mix of certified and non-certified content. This could be achieved by weighting

the former at 125% of their dollar value.