17-0721 v3.1/FSC Exception or Additional Support

NOTE:  On 10/12/22 this exception was revised (see 22-1012 Revisions to FSC Last Link and Market Limitations Exceptions). The exception as reflected in the 22-1012 revision only, is available to projects registered under LBC 4.0 and Core. Project teams pursuing previous versions of LBC may use either the exception as specified below, in its entirety, or the exception as provided in the 22-1012 revision, in its entirety. 

QUESTION:

The project team is requesting an exception to the rule for FSC sourced wood, or guidance from the ILFI (alternate contacts) regarding how to feasibly attain the materials petal given challenges of project site and budget limitations of a single family residence. The intent of this project is to create a recognizable market value, and uptake of the LBC in our region within the residential market. Please see the options explored by the team below for an overview of all listed wood sourcing options that have been explored and evaluated. Additional backup documentation can be requested (i.e. email communication). Please note we have also contacted the Western Canadian regional manager who advised that the only list they have is what is available online and already thoroughly exhausted by the team, with a note back to FSC that many of the suppliers listed have very limited offerings (i.e. 2x4 only and only in 8’ lengths) which are not adequate for many structural or design requirements. Please note that the project has successfully eliminated composite wood products (i.e. plywood and OSB) from the structure entirely but still struggle with many of the other necessary structural wood components to meet this imperative.

ANSWER:

FSC Certification is not necessary for beetle killed pine or any other wood under I12-E3 Invasive Species. Referring to "Option 2" in the attachment, it is acceptable to use beetle killed pine or FSC wood supplied by Canfor. If FSC 100% is unavailable, you may use FSC Mix.

Unused wood purchased from online second hand sources is allowed if it meets the criteria of the updated v3.0 I12-E5 7/2015 Surplus Wood. At a minimum, the wood on page 4 of the attached, labeled "Free Wood - Assortment of Lumber and Plywood", is acceptable for use in an LBC project.

To acknowledge market realities and provide a means forward for teams experiencing difficulty in sourcing compliant wood for Living Building Challenge projects after concerted effort, the Institute is creating the following new Exceptions:

I12-E9 FSC Last Link in COC
In the case where FSC wood can be tracked by COC to a “last link” before the project receives the wood, but

  • the team is unable to convince the one “missing link” to get FSC certification, and 
  • there is no viable "outsourcing" option (through an FSC certified entity or a project contractor), and
  • the next closest supplier is more than more than 1000 km away by land or 5000 km by water, 

the team may use the products from the “last link”.

Documentation 
I12-a Additional Narrative - efforts to locate compliant wood, including to coordinate outsourcing.
I12-c Advocacy Letter - advocacy to suppliers within the 1000 km radius to get certified, including providing information about group certification
I12-e Due Diligence Documentation (new) - showing that the final link is accurately attributing the FSC wood that came into their facility to the LBC project, and not double counting that wood for other projects (e.g. a signed statement from the foreman, owner, or other responsible party).

I12-E10 FSC Market Limitations
Project teams may use non-FSC wood if all the following criteria are met:

1) The team demonstrates due diligence in attempting to locate wood that is either FSC (100% or Mix), salvaged, or meets an existing exception:

  • E1 - Intentionally Harvested Wood
  • E2 - Pending FSC Certification
  • E3 - Invasive Species (of tree or organism)
  • E4 - Underwater Salvaged Wood
  • E5 - Surplus Wood (12/1/17 update)
  • E6 - Urban Harvested Wood
  • E8 - Storm-felled Wood
  • E9 - FSC Last Link in Chain of Custody

2) The team advocates to at least three local suppliers to participate in group certification

3) Where FSC wood is available, it is more than 1000 km from the project by land, or more than 5000 km by water, as confirmed by the local FSC sourcing representative. 

Exception Documentation
I12-a Additional Narrative - Narrative describing the team's efforts to locate compliant wood, and why the team sourced the wood they did.
I12-c Advocacy Letter - Advocacy letters to three local suppliers advocating for either individual or group certification.
I12-e Due Diligence Documentation (new) - Supporting documentation of relevant communications with a local FSC representative.

Post ID 6613

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