Mr. S. Richard Fedrizzi
President, CEO & Founding Chairman
U.S. Green Building Council
2101 L Street, NW
Suite 500
Washington, DC 20037

Dear Mr. Fedrizzi:

On behalf of the National Association of State Foresters (NASF), I am writing to share our views about the revision of the U.S. Green Building Council (USGBC) Leadership in Energy and Environmental Design (LEED) standard. Specifically, State Foresters urge USGBC to revise LEED standards, benchmarks, and credits to clearly:

1. Enhance incentives to recognize wood as a renewable resource and preferred building material
2. Eliminate criteria that discriminate against wood by not equally and fully considering environmental impacts of alternate materials such as steel and concrete
3. Enhance incentives to recognize the environmental benefits of locally produced and domestically produced wood over imported wood and substitute materials
4. Provide incentives to broaden exemplary forestry practices by equally rewarding the American Tree Farm System (ATFS), the Forest Stewardship Council (FSC), the Sustainable Forestry Initiative (SFI), and other credible forest certification systems.

NASF is a non-profit organization comprised of the directors of forestry agencies in the states, territories and the District of Columbia of the United States. NASF promotes activities which advance the practice of sustainable forestry and the conservation of all forest lands. In carrying out public trust responsibilities for managing and protecting forests, NASF members recognize that viable markets are essential for forest sustainability.

NASF members support both forest certification and green building. LEED can and should grow the practice of green building by more fully recognizing the environmental benefits of wood as a material, and by expanding options for wood sourced from certified forests. While in different manners, the ATFS, FSC, and SFI systems include the fundamental elements of credibility and make positive contributions to forest sustainability. NASF members are forest experts who have first-hand knowledge of how these standards actually work on the ground throughout the nation. Based on our expertise and direct experience, we find all three standards credible and recognize the positive contributions they make to forest sustainability.

Proponents of individual certification programs may promote their option as the best or only option, but no forest certification program can credibly claim to be "best." The value of certification is derived from on-the-ground outcomes, not product brand names. LEED should reward forest certification, not one brand, and show leadership by promoting certified wood as preferable to the vast majority of wood sourced from unknown sources. Rewarding certification and increasing certification options will help green building grow consistent with its core objective.

I encourage you to explore the NASF official positions on forest certification and green building published on the NASF website (www.stateforesters.org) as two Resolutions approved by State Forester member consensus:

NASF Resolution No. 2008-7: Forest Certification Policy Statement
NASF Resolution No. 2008-6: Green Building and the Role of Wood Products

NASF applauds the USGBC for supporting green building and urges USGBC to revise LEED standards and incorporate benchmark and credit changes that promote wood and expand the practice of forest certification.

Sincerely,

Steven W. Koehn
President and Maryland State Forester