The Honorable Stephanie Herseth Sandlin
United States House of Representatives
Washington, DC 20515

The Honorable John Thune
United States Senate
Washington, DC 20510

Dear Mrs. Herseth Sandlin and Senator Thune:

The National Association of State Foresters (NASF) greatly appreciates your continued leadership in promoting the development and use of cellulosic ethanol derived from woody biomass from the nation's forests. NASF is a non-profit organization comprised of the directors of all of the nation's state and territorial forest management agencies. Our members have a public trust responsibility for managing and protecting two-thirds of the nation's forestland, which is held in private or non-federal public ownership. We join you in recognizing the flaws found in the current definition for renewable biomass included in the Renewable Fuels Standard (RFS) and support a broadened definition such as the one introduced in the Renewable Biomass Facilitation Act (HR 1190) and its companion bill in the Senate (S 636).

As it stands, the RFS definition severely constrains the ability of non-federal forest lands to supply feedstock to our nation's renewable fuels goals. Limiting the ability of private forest landowners to participate in new markets increases the likelihood that their forest will subsequently be converted to some form of non-forest use. The current definition also excludes the ability of our public forest lands to supply feedstock for renewable fuels. Permitting federal forest lands to supply feedstock would provide a multitude of benefits, including improved overall forest health and the reduction of hazardous fuels that serve as the lynchpin for catastrophic wildfire. These exclusions are overly restrictive particularly in light of the extensive network of federal and state laws and regulations alongside other voluntary programs that successfully promote the sustainability of the nation's forests.

A renewable biomass definition that includes a diversity of cellulosic materials will be necessary to reach the national goal of producing 36 billion gallons of renewable fuels by the year 2022. Restricting the availability of woody biomass is irresponsible particularly at a time when the Energy Information Administration projects the nation will fall short of this goal by six billion gallons. Neglecting to meet these goals means continued reliance on non-renewable fuels and delays in achieving our country's energy security.

Diverse and robust markets for the broad spectrum of forest products are essential for sustainably managing forests in a way that provides a range of forest ecosystem benefits. New markets can help cover the rising costs of forest health and fuel reduction treatments at a time when warming climates and limited budgets suggest it is needed most. A broadened definition in the RFS will help establish renewable fuels markets that-in turn-can create family-wage jobs in forest-based communities and reduce the risk of wildfire that threaten as many as 64,000 communities in the U.S. each year.

NASF would like to thank you for your commitment to amending the renewable biomass definition in the RFS and hope you will consider us a resource as you consider other renewable energy proposals including federal renewable electricity standard (RES) legislation. We share your vision that a broad, consistent definition-in both the RFS and RES-will help streamline implementation and result in healthier forests, greater economic development opportunities and more secure energy supplies.

Sincerely,

Leah W. MacSwords
President