Attachment 9 -Public Comment -SFI

May 2, 2022
Alison Kinn Bennett
Data Gathering and Analysis Division (7406M)
Office of Pollution Prevention and Toxics
Environmental Protection Agency
1200 Pennsylvania Ave. NW
Washington, DC 20460-0001
Re: Docket Identification Number EPA-HQ-OPPT-2014-0838. Agency
Information Collection Activities; Proposed Reinstatement of an Existing
Collection and Request for Comment; Assessment of Environmental
Performance Standards and Ecolabels for Federal Procurement
Dear Ms. Kinn Bennett:
Thank you for the opportunity to comment on the federal register notice related to
the “Assessment of Environmental Performance Standards and Ecolabels for Federal
Procurement”. Although the focus of the FR Notice is the information collection
request, we understand that the EPA is also interested in comments on the overall
proposed approach.
The Sustainable Forestry Initiative (SFI) advances sustainability through forestfocused collaboration. We are an independent, nonprofit organization that works
collaboratively with our network – consisting of conservation groups, federal, state
and county governments, Indigenous peoples, private landowners, manufacturers,
universities and more – to leverage SFI-certified forests and products as powerful
tools to help solve sustainability challenges such as climate action, conservation of
biodiversity, provision of water, education of future generations, and sustainable
economic development (we invite you to learn more at forests.org).
The Administration has signaled the importance of tackling the climate crisis,
including through its federal procurement policy. Robust markets for forest products
help ensure we are keeping forests as forests, continuing to store carbon in our
forests and forest products. We urge the agency to take an inclusive approach to the
use of credible third-party verified standards in federal procurement policy. If the
agency is going to evaluate standards, we encourage the assessment Framework to:
1. Rely on voluntary consensus standards, transparent procedures, a
balance of stakeholder interests, and a clear dispute process.
SFI uses a voluntary consensus process to set standards, in alignment with the
criteria outlined in OMB Circular A-119 on Voluntary Consensus Standards. We are
committed to regularly reviewing and updating all our standards. The SFI 2022
Standards included input from more than 2,300 stakeholders from the conservation
community, Indigenous communities, the forest products sector, brand owners,
private forest landowners and public forest managers, government agencies, trade
associations, landowner associations, academia, and the public.

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2. Ensure that the agency’s consideration of environmental effectiveness appropriately
recognizes the value of single-attribute standards and relies on existing credible assessment
processes.
SFI standards require key elements of sustainable forest management, including requirements to conserve
wildlife habitat, provide clean water, train logging professionals, respect Indigenous rights, and support
conservation research. SFI-certified organizations must meet or exceed applicable water quality laws and
regulations, with measures to manage and protect wetlands and riparian zones. They must continually
evaluate habitat and biodiversity impacts from forest activities – which leads to improved habitat quality, and
protection of imperiled or critically imperiled species.
SFI requires every certified organization to report annually to SFI on a wide variety of practices that
collectively provide an extremely valuable source of aggregate data across the SFI footprint. SFI has added to
this base of knowledge through direct investments in “Conservation Impact” projects that measure the link
between forests certified to the SFI standards and conservation benefits that these forests provide. One
example is a study conducted by NatureServe, which found that SFI-certified provide significant area for
globally imperiled or vulnerable (G2 or G3) plant and animal species. Almost 75% of SFI-certified lands in the
areas studied were composed of “core areas” - areas with greater potential to support specialist species.
More information about these Conservation Impact research projects is available at
https://www.forests.org/conservation-impact-project/.
The SFI standards are widely recognized by the public and private sector, including by:
• USDA, whose 2011 study on the environmental and economic benefits of using wood in green
building construction found that “Sustainability of forest products can be verified using any credible
third-party rating system, such as SFI, FSC, or ATFS.”
• EPA, whose 2016 rule on forest roads and water quality recognized SFI for “important contributions
to improved BMP implementation through logger training, landowner outreach, and water quality
requirements.”
• The US Green Building Council, which updated its Leadership in Energy and Environmental Design
(LEED) rating system in 2016 to recognize wood and paper from SFI as part of an integrated
approach to encouraging environmentally responsible forest management in the building material’s
supply chain.
3. Rely on independent verification of standards.
Third-party independent certification is a cornerstone of SFI’s standards. It verifies that all the requirements
set out in the relevant SFI standard and supporting documents are appropriately met. A group of competent,
accredited, and independent certification bodies evaluate planning, procedures and processes in the forest, in
the mill or in the plant to ensure they conform to SFI requirements. This process is the same for the SFI
Forest Management Standard, the SFI Fiber Sourcing Standard, the SFI Chain-of-Custody Standard, and the
SFI Certified Sourcing Standard.
Thank you for your consideration of our comments. We look forward to continuing to engage with the agency
on its application of the assessment Framework.
Regards,
Nadine Block
Senior Vice President, Community and Government Relations
[email protected]
202-596-3456