22-0222 Exception for Responsible Sourcing of 50% FSC


The project team is requesting ILFI consider an exception for C6 Responsible Materials requirements for our Core Certification (Standard v09). This request is in relation to the Wood Sourcing requirement for this imperative. The intent of the Wood Sourcing requirement is sustainable extraction, and we have chosen the most sustainably extracted material available for the project's needs whilst meeting its performance requirements.

As we are working on an Electrical Substation project (Infrastructure Typology), we have designed the structure to comply with fire/earthquake safety requirements required for the function of the building, as well as providing a modular prefabricated design that enables the substation to be relocated and reused in its entirety at some point in the future. The design for this substation will be the Blueprint for all future substations and the Client is accordingly considering VOLUME certification for this design.

Typically substations throughout New Zealand are constructed of concrete and steel and through this project we are looking to completely re- imagine what "Good" may look like for an Electrical substation.

CLT is the preferred structure for the following reasons;

  1. Ability to meet the required seismic and fire performance of the sub-station.
  2. Ability to meet safety design thresholds for a failure event of the substation (A timber framed construction would not meet the performance requirements of the substation in this regard)
  3. If we were to construct the substation as a timber framed construction we would need to use intumescent paints to provide the required fire rating which will likely necessitate the use of Red List Chemicals.
  4. CLT is the preferred structure for minimising waste throughout the life of the building.(cradle to gate)

FSC Sourced CLT was available in New Zealand in 2019 and will be available again next year from a local NZ CLT fabrication plant which is coming online at the end of 2021, but is unfortunately not available this year for project construction programme of this FIRST initial substation. FSC CLT is available for purchase in Europe but doesn't meet the durability requirements of NZ Building Code and also does not meet our requirements for local economy sourcing.

The current closest CLT fabrication plant to New Zealand is the XLAM PEFC CLT plant in Melbourne Australia and we have chosen to continue with procurement of XLAM PEFC CLT from Australia for this first substation. Future substations using this design will source FSC CLT timber from the new CLT plant in New Zealand.

Since CLT is only currently available in Australia it is therefore rated PEFC and not FSC, classifying as low risk instead of FSC. (All XLam products sold in New Zealand, which don't include CLT, are FSC). Because the PEFC CLT is equivalent to around 50% of our timber budget and is considered 'low risk' timber, we will not meet our goal of 50% FSC. However, all of our other project timber product requirements will be FSC, low risk, and salvaged. We are proposing a temporary exception to use PEFC CLT for construction for this first building due to NZ market limitations, as it is the most responsibly sourced option that meets the functional requirements of the design for the sub-stations whilst meeting the intent of the LBC. The other option we had was to use concrete, which would also meet our fire and safety requirements. However, we concluded that CLT better fit the intent of Core, as it will reduce our carbon footprint.

We believe that we have made the best possible decisions to meet the intent of this imperative and all others within Core. We have advocated for FSC CLT timber to be available in New Zealand for future projects.

We look forward to your response.


CLT manufacturers in Europe won't comply with the durability requirements of NZ Building Code because the timber isn't treated to the standard requirements of NZS3602:2003 (B2 Durability section). 

In addition, an inability to procure H3.2 Framing Timber that is both FSC certified and not CCA treated was caused by a nationwide shortage of timber due to Covid and a recent upswing of NZ Government building projects. We are attaching a due diligence document which outlines the options we researched in our intent to get FSC timber that was not CCA treated (Please see attached MCA vs FSC Due Diligence Evidence). We made the call to prioritise red-list free treated local timber and found a supplier who is not FSC certified but is in the process and will undertake the audit stage shortly after we begin construction. 


ILFI recognizes that the primary difficulty in meeting the required FSC percentage was due to the timing of CLT manufacturing modifications outside of the project team’s control. The Institute also appreciates the project team’s efforts to avoid Red List chemicals, but also notes that the Responsible Materials requirements for Core certification reflect the challenge posed by the suite of its requirements together and set the quantity of FSC wood required and omitted Red List compliance accordingly.

The requested exception is not granted, however the project owner may pursue a project-specific alternative compliance path of installing on a subsequent project, FSC lumber in excess of what would otherwise be required for that project. Certification of the posting Core project would be contingent upon verification that excess FSC lumber, in at least the amount of the shortfall, had been purchased and assigned to a receiving project. In addition, the project team must provide affirmation that the excess is above and beyond what would be required for the receiving project, for example if that project is also pursuing certification. In other words, affirmation that the FSC lumber is not being double-counted is required.

To pursue this option, prior to the Ready Audit, the project team must submit for approval by ILFI a proposal that:

  1. confirms the amount of the FSC shortfall of the current project, and
  2. lays out a plan for both identifying an FSC wood beneficiary and tracking procurement and transfer of the excess FSC lumber.

For the certification audit, submitted documentation must include:

  1. receipts showing FSC lumber (including Chain of Custody number(s)) was purchased for and transferred to the receiving project, in an amount at least equal to the shortfall, and
  2. affirmation from the receiving project that:
    1. it received the designated FSC amount, and
    2. none of that amount is being counted towards any other compliance requirements that may be applicable to the receiving project. 

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