Dear Secretary Moniz:
We are writing to express our concern regarding the position of the Department of Energy Office of Sustainable Environmental Stewardship that states only lumber certified by the Forest Stewardship Council (FSC), and not lumber certified by the Sustainable Forestry Initiative (SFI) or the American Tree Farm System (ATFS), would be suitable for federal purchasing.
As you may know, this determination by DOE was subsequently relied upon by the Environmental Protection Agency in their September 25, 2015 publication of Interim Recommendations for standards and ecolabels used by federal agencies.
Other federal agencies recognize a variety of forest certification regimes and therefore we encourage you to revisit your agency's position on lumber and consider adding recognition for wood products that have taken steps to provide certainty about their sustainability of the product. This includes those certified to SFI and ATFS standards.
Just like those forests certified to the FSC standard, ATFS and SFI certified forests provide a renewable timber resource, clean water, wildlife habitat, and thousands of jobs in the forest sector and related industries. Across the United States, there are more than 82 million acres of forestland certified to either SFI or ATFS standards. We are proud that our states have nearly 23 million acres combined that are certified to one of these two standards. There is no basis -- scientific or otherwise -- for excluding products from these forests for federal use.
We urge your agency to consider the position of the Department of Agriculture, which oversees the US Forest Service and has vast expertise in forest management. USDA, in its BioPreferred Program, recognizes and supports all forest certification standards.
We further encourage you to consider the recent announcement by the US Green Building Council (USGBC) to recognize products certified to SFI and ATFS standards within its Leadership in Energy and Environmental Design (LEED) rating systems. We understand that one of DOE's criteria for "priority products" is that they contribute to LEED points for existing buildings and new construction. With this change by USGBC, products certified by SFI and ATFS meet this criterion.
At a time when it is broadly appreciated that wood is one of the most environmentally friendly materials for building construction, it is important for your agency to take action to encourage, not limit, the use of responsibly sourced wood in government construction.