Application of the mean-profile energy budget analysis to forests is discussed, with regard to limitations imposed by the forest environment. These limitations are primarily associated with the diffuse structure and aerodynamically rough nature of forest canopies, which contrast with the dense and relatively smooth canopies of agricultural crops. Results of the few forest energy budgets that have been completed are reviewed by country of origin and number of articles. The results from these studies are compared with a clear weather energy budget for a second-growth Douglas-fir site on the Cedar River, Seattle, Washington. Despite obvious limitations upon interpretation of variability from the two estimates made, this appears to be the first forest study to replicate the energy budget measurements. (Modified author abstract)