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December 26, 2000 Mr. Bob Tillman Dear Mr. Tillman: Lowe's Companies' recently announced policies and preferences in sourcing wood and paper products for its stores give us cause for concern. In that release, you state it will be your intention to purchase lumber, paper, and other wood products manufactured from trees that were harvested only from lands that have been third-party certified as being "well managed" and that you will give preference to wood or products that have been certified by The Forest Stewardship Council. We certainly support the objective of sustainable forest management and feel third-party certification can play a vital role in helping to achieve that objective on industry and some public forestlands. We also feel third-party certification is unnecessary, impractical, and not economic for most individual small private forest landowners. For those smaller ownerships, we need to develop program, group, or regional certification systems that do no impose a cost burden or create a trade restraint on the owners. The Forest Stewardship Council's principles and certification system were developed to try to use the marketplace as a vehicle to control deforestation in the tropical rainforests. Its forest management requirements are heavily interlaced with social and political beliefs and requirements that might be appropriate for those regions but are senseless, inappropriate, and totally out of place for landowners in the United States. The United States has the best forest practices overall of any country in the world, and we take a back seat to nobody in that regard! Unlike most of the rest of the world, where forests are owned by governments, and often mismanaged or exploited, the majority of our forests are owned by almost 10 million non-industrial private landowners who have a passionate regard for the stewardship of their lands. We have worked for several years to develop laws, regulations, and Best Management Practices in all the states of this nation to ensure our forests will continue to be available for both this and future generations. We have developed extensive landowner assistance programs, both public and private, that provide advice and on-the-ground service to many of our private owners. Management services to forest landowners are provided by a whole host of individuals and privately owned companies, from consulting foresters, tree planters, road building contractors, surveyors, and site preparation contractors to tax attorneys and estate planners. Timber harvesting and processing of the wood products that come from these lands are accomplished by thousands of independent logging firms and sawmills located all across the country. Many, if not most, of the millions of individuals and companies that own the land, provide the services, and do the logging and processing of the wood products are customers or potential customers of your stores. It is a complete mystery to us why Lowe's would choose to adopt a procurement policy that places these individuals at an economic and competitive disadvantage. The Forest Resources Association is a 67-year-old national trade association, representing 1,600 forest-dependent enterprises, ranging from multi-plant paper and building products manufacturers to two-man logging businesses. We are a diverse organization of forest managers and timber harvesting contractors and suppliers of those businesses. Most of us are graduate foresters with several years of field and administrative experience. Geographically, we are spread so widely over the United States' forested regions that we doubt if more than a dozen of our 3,400 member personnel share the same zip code. We are committed to a vision of ensuring the sustainability of our forests for both the commodity and non-commodity benefits to present and future generations. We feel Lowe's procurement policy statement, while well-intentioned, is anti-competitive and misrepresents the quality of sound environmental management most private forests in the United States receive. In giving preference to the FSC certification scheme, it seeks to impose unwarranted and unnecessary social, political, and biological requirements and restrictions on the forest landowners of this country. There are other management systems and certification systems (where desired) that are far more appropriate and applicable for the United States and North America-the Sustainable Forestry Initiative, the Canadian Standards Association, and the American Tree Farm System, to name just a few. If Lowe's is serious about supporting sustainable forest management practices, understanding what they are, what motivates them, and how to create incentives to advance their application, we have the experience, resources, and the on-the-ground access to contribute substantially to such an effort. We are the foresters, timber harvesters, and forest industry suppliers of the United States, and we hope to be in business as long as you are. We also hope we can feel justified in continuing to support and do business with Lowe's. We would like to offer Lowe's the advantage of our experience, expertise, and perspective. We would be more than willing to meet with you to discuss this subject and our concerns in more detail. Sincerely, Bill Baughman
Richard Lewis
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