August 16, 2017

Dear Supervisor Jaeger,

Scoping Comments Introductory Remarks

My scoping comments on the proposed LaVa timber sale are shown below. Each comment is clearly labeled. There are 5 comments. Please prepare 5 meaningful (emphasis added) responses to my comments in the pending draft NEPA document. They are indented and numbered using the word Comment # that’s bold, purple, 11- pitch font, and underlined.

Your forest has had many acres of Mtn. Pine Beetle activity in the LPP. The dead trees are not visually attractive. Your proposal to log these trees will create clearcuts that are worse from a visual standpoint.

I retired from the USFS in 2003 after 31 years with the agency. I saw it all. I worked with intelligent, caring resource specialists and I worked with so-called specialists who would knowingly trash and even destroy important natural resources in their witless quest to assure their Ranger or Supervisor would get their precious volume.

Comment #1 I spent 9 years as a forest planner on the Nez Perce NF. I have experience working with LPP stands affected by Mtn Pine Beetle. I can assure you we didn’t respond to this natural disturbance event by logging the dead trees. This is why the aquatic resources on the Nez Perce NF are functioning properly. Understand that a reasonable response is to wait it out. Ask the public if they would rather see massive clearcuts or grey trees.

Comment #2 A USFS employee developed the most effective method to reduce or eliminate the danger of wildfire damage and/or human deaths in the WUI. Dr. Cohen’s methods are used throughout the world yet the USFS refuses to acknowledge they exist. Opposing Views Attachment #11 explains his methods in more detail. Please assure the DEIS discloses the WUI areas will be treated ti remove fine fuels.

Comment #3 Your scoping package at page 6 indicates you will take action to control noxious weed but it doesn’t say how this will be done. If you propose to apply herbicide please assure the NEPA document bases the herbicide toxicity and safety disclosures on best science supported by a variety of research conclusions. There are hundreds of research conclusions from research conducted by independent scientists that all show glyphosate is a highly-toxic carcinogen. The USDA approved glyphosate toxicity research comes from a single study at a single lab -- Syracuse Environmental Research Associates, Inc. (SERA). Of the hundreds of glyphosate toxicity studies, the one done by SERA is the only one to conclude glyphosate is non-toxic. If you don’t believe this then search on the 2 words “glyphosate” and “cancer.” Please see the Glyphosate 1 attachment.

Comment #4 It would be impossible to accurately predict the environmental effects of logging 406 square miles and constructing 600 miles of temporary road. This EIS should be programmatic. This means the individual timber sale decisions will be made in separate, site specific NEPA documents. The July 2017 amended Medicine Bow Landscape Vegetation Analysis Scoping Document does not say this. I am expecting the DEIS to include this important discussion.

Comment #5 When beetles kill a lodgepole pine tree, the needles fall off and decompose on the forest floor relatively quickly. When those needles die, the flammable oils break down. As a result, depending on the weather conditions, dead needles less likely to catch and sustain a fire than live needles. With an ignition source nearby live LPP trees are a greater fire hazard than dead LPP trees. Too many USFS line-officers won’t explain this to the public so they can use the insect activity as an excuse to accumulate volume. Please see Opposing Views Attachment #17 to learn more.

Despite what the USFS teaches you, you must know allowing skidders and tractors weighing 35,000 pounds with spinning wheels and tracks will tear up and destroy the countless natural resources in a fragile forest.

I am giving you and your IDT members the opportunity to become familiar with the natural resource research conclusions of independent scientists not associated with the USFS in the Opposing Views Attachments #1 and #4. They are numbered and presented in bold, red, underlined font. The research describes the many natural resources that cease to function properly when subjected to logging and roading.

These attachments will make you all uncomfortable because they contain a wealth of independent science conclusions that are inconsistent (many times in total conflict) with what the USFS wants you to do. ------Please alert me when the DEIS is posted online and you are accepting comments.

Sincerely,

Dick Artley (retired forest planner, forest NEPA and litigation coordinator and NEPA document legal compliance reviewer --- Nez Perce National Forest, Idaho) Grangeville, Idaho 83530 [email protected]

CC: selected specialists

The Truth about USFS Timber Sale Planning that Most Agency Specialists know and Embrace to Maintain their Promotion Potential

The bulleted items below describe a few of the NEPA process tricks that the agency teaches its employees. I’ll bet you thought you were correctly complying with NEPA didn’t you? Ask yourself what motivates the USFS to twist the process.

• The Purpose & Need statements are written to deceive the public into thinking logging and roading-up the forest are ecosystem friendly.

• The NEPA document text is populated with the following two undefined, sugar- coated terms: “restore” and “forest health.”

• The IDT specialists know they are expected to write untrue No Action effects in Chapter 3 that ALWAYS (emphasis added) describes the highly unlikely resource damage of maintaining the status quo and doing nothing. Even interested lay members of the public understand this makes no sense. This is clearly tragic, unprofessional public deception.

• The IDT specialists write untrue effects of implementing the Proposed Action in Chapter 3 that depict it in a positive way … in spite of the compelling independent science that shows logging activities destroy amenity resources so loved by the public. A minority of IDT members describe the true effects but justify the damage by telling the public it will be “short-term.”

• The IDT members know there are multiple ways to achieve most timber sale P&N goals that don’t involve logging or roading. They know that including the P&N goal to “supply volume for local community economic stability” to render these other “reasonable” alternatives not responsive to the P&N. Why else is there only 1 action alternative (logging) presented to the public in 99% of timber sale EAs and EISs? Indeed, the Responsible Official selects the alternative that will be implemented prior to scoping and then runs it through the NEPA process to make it appear legal.

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The system is rigged against the public. Ask yourself why USFS Objection Deciding Officers rule against the public in favor of the Responsible Official in the vast majority of cases regardless of the Issues. They use form responses for common objection items. Now ask yourself why the USFS looses in court most of the time when the Objection Deciding Officer’s decision is litigated. What does this tell you?

In the late 1990s there was a push to change the appeals process to allow a small unbiased team of natural resource experts not associated with the USFS to decide the final appeal ruling. Of course the USFS stopped it. They wanted complete control. If you were being tried in a court of law would you want the plaintiff’s attorney to decide the case? This is exactly what occurs when a USFS Objection Deciding Officer determines the final outcome of the objection.

Please consider really serving the public rather than obediently taking orders … and mindlessly doing what you are told. The USFS isn’t the military. You can still think for yourself outside the agency-approved box. You will be glad you did.

The public expects resource specialists to weigh the impacts of the logging actions against the amenity resource damage that logging will inflict without bias to favor the Proposed Action. Disclosing the real tradeoffs will serve future generations of kids more than any other action you will take as a USFS employee. I know this is frightening to specialists who know as IDT members they must pave the way for all timber sale proposals.

NEPA requires interdisciplinary input for a reason. It also requires Responsible Officials to seriously consider the effects of implementation before approving the Proposed Action. A professional resource specialist will have the courage to say “NO” when you know they expect you to cut legal corners and lie to assure them their precious volume. NEPA was never intended to be a hoop you must jump through to justify a decision that has already been made.

Attaining timber volume to assure corporate profit opportunities should never be a reason to justify other resource damage. When and if you point this out to the Responsible Official, he/she will surely remind you of the many P&N goals that will be achieved by logging and roading-up the sale area. Courageous other resource specialists know most EA and EIS P&N statements are untrue. You know 1) some P&N goals are not needed, and 2) that legitimate P&N goals are not satisfied by logging and road construction.

Have any of you ever wondered why most well-respected, independent scientists describe tragic short-term and long-term natural resource effects from logging and roading, and the USFS tells the public these same natural resources will benefit and be “restored” from “mechanical treatments” (a.k.a. logging). Have any of you ever wondered why the agency invented euphemisms and sugar-coated language when 2

describing logging in NEPA documents (i.e. active management, treatments, and mechanical treatment to name a few) ?

Now please consider the following questions. Be truthful with yourself and resist the safety and relief of falling back on agency dogma.

• Have you ever been an IDT member and felt the project would harm the resource(s) you are responsible for protecting? If so, did you suggest that the project’s design should be modified to remove the possibility that your resource will be harmed, or did you write unsubstantiated Chapter 3 effects disclosures for the Proposed Action discussing why the harm is acceptable because it’s only “short term?”

• Have you ever believed that your line-officer directly or indirectly pressured you to skew or withhold information from the public in your Chapter 3 effects disclosures? How did you react? Were you obedient or did you tell the truth?

• Did you ever “sanitize” your Chapter 3 effects disclosures to minimize the predicted adverse effects of timber sale implementation? Doesn’t the public pay you to tell the truth? How do you justify this in your own mind? How would you justify this to future generations of kids seeking undeveloped, wild forest land?

• How often have you felt your Ranger or Supervisor made his/her decision to implement the Proposed Action for a timber sale before asking the public for scoping comments? How did you feel knowing you were paid by the public to take the project through the NEPA process knowing the selected alternative had already been determined by the Responsible Official? What did you do?

• How often when writing the Chapter 3 effects disclosures have you felt (directly or indirectly) pressured to exaggerate the positive effects of the Proposed Action and amplify & inflate the adverse effects of No Action?

• NEPA requires the Responsible Official to seriously consider selecting the No Action alternative. When was the last time you heard of “No Action” being selected by any Responsible Official on a national forest anywhere in America? What does that tell you?

• How many times have you felt like the Responsible Official didn’t value or really consider your professional opinion when you were bold enough to express it truthfully?

• Have you ever wondered why the USFS uses medical terms like prognosis, prescription, treatment, forest health etc. when referring to most “unmanaged” (a.k.a. unlogged) stands? Of course they are attempting to convince the public

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the forest is sick? Why would they do that? Might they be suggesting there is something to cure the sickness? Why is their cure always logging?

• Have you ever wondered why a timber sale that will clearly inflict major natural resource damage is called a “restoration project?” Does this have anything to do with public deception?

• There are countless natural resources in the forest. Have you ever wondered why the Responsible Official’s focus is always on conifer tree species when discussing forest health? Have you had the courage to suggest amenity resource health should be at least as important as conifer tree species health and the amenity resource health will suffer then the area is logged and roaded?

• Would a forest be healthy of all conifer tree species were vigorous and fast growing? Then why is this a goal for most timber sales? Doesn’t a healthy, biodiverse forest have dead and dying trees? Might the Responsible Official’s need to create vigorous, fast growing, large diameter trees you see in some P&N statements have something to do with making the next timber sale attractive and profitable to the purchaser?

• Is it right for money to drive USFS projects? Timber sales are driven by the need to spend all NFTM dollars in the same FY the money was allocated. Line-officers who have unspent NFTM dollars at the end of the FY will have his/her budget cut next year and their promotion potential will be affected. Have you ever wondered if this requires them to find volume anywhere and develop the P&N with logging goals later?

• Why is success on your national forest measured by millions of board feet logged rather than the number of acres where amenity resources function properly?

• Do you think so-called temporary roads are really temporary on your forest, or are they long-term linear sediment sources? Shouldn’t an aquatics specialist demand that all planned temporary roads be returned to the natural angle of repose by returning the fill material into the cut (i.e. obliterate)? After use, a real temporary road would not have a running surface. Does this happen on your forest or do you scatter twigs/brush and seed on the outsloped running surface believing it will stop erosion?

• When you respond to public comments critical of a draft timber sale NEPA document doesn’t the Responsible Official expect you to explain (before you read the comment) why the comments are not-applicable, irrelevant, already decided by law or policy or outside the scope of the project?

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• Have you ever wondered why the agency stopped using the terms “logging” or “to log” in its documents that will be read by the public? When they tell the public they plan to “treat”, “restore” and “actively manage” instead of “log” the forest is the USFS trying to hide something from the public?

• National forests are infinitely more than merchantable trees. Why is the proper functioning of countless other resources less important than the need to create private industrial tree farm conditions (i.e. vigorous, shade-tolerant, fast growing, large diameter trees with high lumber value)?

• Independent scientists not affiliated with the USDA stress that the optimum habitat conditions for birds and mammals occurs in "unmanaged" (a.k.a. unlogged), undeveloped forests. Do you really think these same optimum habitat conditions will exist after the landscape is changed by logging? Isn't it arrogant to think USFS employees can improve on what took Mother Nature millions of years to perfect?

• Has a “park-like” stand lost its biodiversity? Have you ever wondered why creating a “park-like” stand without brush or small trees with fast-growing, “vigorous” conifer tree species with a high lumber value is sometimes a USFS goal? Have you ever had the courage to question this notion? Ask yourself what private-industrial tree farm managers are paid to create.

• All healthy populations of living things have dead and dying individuals. Why does the USFS conclude that stands with dead and dying trees are unhealthy stands? Does logging the dead and dying trees create a healthy forest when all resources are considered? Don’t some natural resources thrive only in so-called unhealthy stands? Have you ever discussed this with your supervisor? Why?

• Have you ever wondered why the USFS strives to eliminate climax tree species (grand-fir, hemlock, spruce etc.) so important to some wildlife species? Does the low lumber value of these trees have something to do with it? Do you believe eliminating climax tree species reduces fire intensity and rate of spread as the USFS so frequently claims? How could this be the case given the fact some climax tree species grow in cool, moist areas of the forest?

• Should dead and dying trees in a post-fire landscape be removed or left on site? Is a wildfire far removed from a WUI area “catastrophic” or is it an attempt by Nature to restore the forest? Isn’t there a reason fire comes from the sky during the hottest, least humid months of the year?

• There is a reason USFS employees have family meetings and not employee meetings. There is a reason USFS employees who might question or disagree

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with a proposed project are referred to as someone who’s not a “team player.” Why is group-think encouraged by the agency?

• Do you ever wonder why you believe the things you learned in college about the resource you are responsible for protecting don’t apply to proposed USFS timber sales?

• Have you ever watched foresters and silviculturists hoot with glee as they viewed the after effects of a timber sale and thought it looked “good”? Did the biologists who saw the same thing agree with them? Were they afraid to express their opinion? Why?

• The USFS justifies post-fire logging by telling the public the dead and dying trees must be “captured” (a.k.a. logged) before they rot and decay. Isn’t the forested ecosystem rejuvenated when the trees rot? How else would the organic material in the soil be supplemented? When your line-officer pursues a post-fire timber sale doesn’t this mean he/she places corporate profit ahead of real restoration?

• Have you ever felt pressured to conclude in your Chapter 3 effects disclosures that the timber sale will “restore” your resource when you really felt the planned logging and road construction would harm it? What did you do?

• Why does the USFS make decisions to manipulate the forests by severing and removing the trees? Is it to 1) enhance the opportunities for kids of the future to explore and enjoy an undeveloped forest without stumps & roads, or 2) to provide corporations with short-term profit opportunities? Are the 2 goals consistent?

• The USFS tells the public it can all happen (commodity output and naturally functioning natural resources) on the same acre. Can this be true? Why do they make this claim? Have you ever questioned this USFS “fact”? Were you punished?

• Many natural resources thrive when natural disturbance events occur (i.e. fire, insects and disease). Should the USFS spend tax dollars trying to stop or delay these events far from the WUI? Is it really that important to keep all merchantable trees from dying? What motivates the USFS to take extraordinary measures to save these trees, while simultaneously eliminating conditions that make it possible for other resources to thrive? Could it have something to do with the need to save the trees to please the corporations at a later date?

• Do you think corporations have too much influence in America? If you do, why do you help them trash the forest?

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• Of course the things you learned in college about the resource you are responsible for protecting apply to areas where the USFS plans to log. Have you ever suggested certain areas should not be logged to protect these resources? Did the Responsible Official act on your recommendation or were you ignored?

• Have you ever viewed the after-effects of a timber sale you worked on and thought it looked “good” and the natural resources in and downstream from the cutting units functioned better than before the sale was logged? If your answer is “no” then isn’t it appropriate to ask yourself if you sacrificed your resource to fit in as a “team player?” Were you proud? Will you do it again?

• Why does the USFS equate “to manage” with “to log”? Managed land is logged- over land. The agency has redefined English language words to manipulate and change the behavior of its employees. Look up the term “manage” in the dictionary. You won’t find logging or timber harvest mentioned.

• Why is the USFS solution to forest problems (real or perceived) to log-off merchantable trees? Why does the USFS conveniently “overlook” superior solutions to these problems that don’t produce volume?

• Is the USFS responsible for protecting and conserving the land and water that will be enjoyed today by 324 million Americans and that will be inherited by future generations, or is the agency responsible for maintaining sufficient volume under contract for the local mill? Can both occur simultaneously?

• Question What would your line-officer do if there were no unhealthy timber stands on the district and received a substantial NFTM timber budget the same FY? Would he/she give the money back, or log areas with no legitimate need to do so?

• Question: Why do you feel sheepish, uneasy, and perhaps a little guilty after reading these questions?

Have you ever fully acknowledged to yourself that the USFS uses euphemisms and invents new meanings for words to fool and deceive the public? I found each “sugar-coated” description below in USFS EAs and EISs. You probably used some yourself.

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The Forest Service’s “sugar- coated” terms used to The USFS is really deceive the public describing this To “mechanically treat” To log the forest To “actively manage” To log the forest Apply “sustainable forest To log the forest management” To “manage” To log the forest A “working forest” A logged forest To “restore” To log the forest To “rehabilitate” To log the forest To “treat” To log or apply toxic herbicides “visual diversity area” Logged hillside pockmarked by cutting units. “un-managed” land Unlogged land A “healthy” forest A logged forest

Decadent trees, over-mature Trees in a bio-diverse trees, slow growing trees and forest that serve trees that have reached their important functions but culmination of MAI. are removed because they have value to a mill.

“temporary wildlife opening” A clearcut “temporary meadow” A clearcut “birthing scene” A clearcut “minimum tree retention unit” A clearcut “patch cut” A clearcut “vista opportunity” Standing in a clearcut Clear-cut with reserves Still a clearcut

Timber Any tree larger than 10” growing on public land

“linear wildlife opening” Logging road 8

“wildlife travel corridor” Logging road

Catastrophic fire Any fire on public land

“prescription” Written guidelines for selecting and marking trees to be logged “diagnosis” Analysis findings of the forested condition that will be used to write the prescription

USFS line-officers would understand and manage the national forests according to the wisdom expressed below, if they didn’t feel obligated to serve up trees on the plate of the natural resource extraction corporations

"God has cared for these trees, saved them from drought, disease, avalanches, and a thousand tempests and floods. But he cannot save them from fools." John Muir

"Thank God, they cannot cut down the clouds!" Henry David Thoreau

“We cannot command Nature except by obeying her.” Francis Bacon

"It is imperative to maintain portions of the wilderness untouched so that a tree will rot where it falls, a waterfall will pour its curve without generating electricity, a trumpeter swan may float on uncontaminated water, and moderns may at least see what their ancestors knew in their nerves and blood." Bernand De Voto from Fortune, June 1947

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"We abuse land because we regard it as a commodity belonging to us. When we see land as a community to which we belong, we may begin to use it with love and respect."

Aldo Leopold from A Sand County Almanac

"If all the beasts were gone, man would die from a great loneliness of spirit. For whatever happens to the beasts soon happens to man." Chief Seattle (1786 - 1866) in a letter to U.S. President Franklin Pierce

"Government cannot close its eyes to the pollution of waters, to the erosion of soil, to the slashing of forests any more than it can close its eyes to the need for slum clearance and schools." Franklin D.Roosevelt

"It is horrifying that we have to fight our own government to save the environment."

Ansel Adams

"If a man walks in the woods for love of them half of each day, he is in danger of being regarded as a loafer. But if he spends his days as a speculator, shearing off those woods and making the earth bald before her time, he is deemed an industrious and enterprising citizen." Henry David Thoreau

"God is the experience of looking at a tree and saying, 'Ah!'" Joseph Campbell

"You will find something more in woods than in books. Trees and stones will teach you that which you can never learn from masters." Saint Bernard, Epistle French abbot (1090 - 1153)

"If trees could scream, would we be so cavalier about cutting them down?" Jack Handey

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"People in suburbia see trees differently than foresters do. They cherish every one. It is useless to speak of the probability that a certain tree will die when the tree is in someone's backyard. You are talking about a personal asset, a friend, a monument, not about board feet of lumber." Roger Swain

William C. Bryant

"A few minutes ago every tree was excited, bowing to the roaring storm, waving, swirling, tossing their branches in glorious enthusiasm like worship. But though to the outer ear these trees are now silent, their songs never cease. Every hidden cell is throbbing with music and life, every fiber thrilling like harp strings, while incense is ever flowing from the balsam bells and leaves. No wonder the hills and groves were God's first temples, and the more they are cut down and hewn into cathedrals and churches, the farther off and dimmer seems the Lord himself." John Muir

"The tree which moves some to tears of joy is in the eyes of others, only a green thing which stands in their way." William Blake

"Forests live out of the deaths of toppled giants across the decades, as well as the incessant dying of microscopic beings. Without death, the forest would die. Ultimately, it is only the removal of trees that can deplete the forest. Both fallen giants and fallen leaves collaborate with the bacteria of decay to produce the fertile soil from which new growth comes. By itself no single organism can long survive. The forest is its own memorial, the conclusion of its own conversation. You can lift a log, the corpse of a fallen tree, and find a whole community at the rotting face where it touches the moist ground." Mary Catherine Bateson

"Thou shalt not destroy the trees thereof by forcing an axe against them: for thou mayest eat of them, and thou shalt not cut them down (for the tree of the field is man's life). The Bible -- Deuteronomy 20:19

"Gradually, the trees were reduced from living spirits to little more than timber sources. Some of the ancient lore was passed on by oral tradition through a long line of country folk, albeit sometimes in a Christianised form to make it more acceptable to the 11

'authorities'. Much of it is missing, as is the case with the Beech. The only way we gain regain what was lost is to stop thinking of trees as merely timber and amenity. All the world would benefit if we are able to relate to trees fully once more: as our friends, our providers, our healers. But especially as creatures who have their own lives to lead and their own role to fulfill in the community of Earthly beings. Once we understand that, we will hopefully stop sabotaging their many contributions, and work side by side with these giant plants rather than merely exploiting them." Anna Fraser

"We must protect the forests for our children, grandchildren and children yet to be born. We must protect the forests for those who can't speak for themselves such as the birds, animals, fish and trees." Chief Edward Moody

"Our government is like a rich and foolish spendthrift who has inherited a magnificent estate in perfect order, and then has left his fields and meadows, forests and parks, to be sold and plundered and wasted." John Muir

“If you cut down a forest, it doesn’t matter how many sawmills you have if there are no more trees.” Susan George

"The National Forests are creatures of Democracy, not the Forest Service.”

John Freemuth

"Sooner or later, wittingly or unwittingly, we must pay for every intrusion on the natural environment." Barry Commoner biologist, environmentalist, and major advocate of environmental protection

"We won't have a society if we destroy the environment." Margaret Mead anthropologist, author, and environmentalist

"We have modified our environment so radically that we must now modify ourselves to exist in this new environment." 12

Norbert Wiener mathematician

"The difference between animals and humans is that animals change themselves for the environment, but humans change the environment for themselves."

Ayn Rand Russian born American writer & philosopher who advocated capitalism, individualism, and objectivism

"We shall never understand the natural environment until we see it as a living organism. Land can be healthy or sick, fertile or barren, rich or poor, lovingly nurtured or bled white. Our present attitudes and laws governing the ownership and use of land represent an abuse of the concept of private property. Today you can murder land for private profit. You can leave the corpse for all to see and nobody calls the cops."

Paul Brooks, environmentalist and author from The Pursuit of Wilderness (1971)

"I do not know of any environmental group in any country that does not view its government as an adversary." Gro Harlem Brundtland from Time magazine

"Thank God men cannot fly, and lay waste the sky as well as the earth."

Henry David Thoreau

"There is a sufficiency in the world for man's need but not for man's greed."

Mohandas K. Gandhi

"Because we don't think about future generations, they will never forget us."

Henrik Tikkanen

"I am the earth. You are the earth. The Earth is dying. You and I are murderers."

Ymber Delecto

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"So bleak is the picture, that the bulldozer and not the atomic bomb may turn out to be the most destructive invention of the 20th century." Philip Shabecoff from New York Times Magazine, June 4, 1978

"For 200 years we've been conquering Nature. Now we're beating it to death."

Tom McMillan, quoted in Francesca Lyman's book The Greenhouse Trap, 1990

"I would feel more optimistic about a bright future for man if he spent less time proving that he can outwit Nature and more time tasting her sweetness and respecting her seniority." Elwyn Brooks White from Essays of E.B. White, 1977

"A virgin forest is where the hand of man has never set foot." Author Unknown

"Every other civilized nation in the world has been compelled to care for its forests, and so must we if waste and destruction are not to go to the bitter end, leaving America as barren as Palestine or Spain." John Muir August 1897

"Humankind has not woven the web of life. We are but one thread within it. Whatever we do to the web, we do to ourselves. All things are bound together. All things connect." Chief Seattle, 1855

"Man is a blind, witless, low brow, anthropocentric clod who inflicts lesions upon the earth." Ian McHarg

"In its broadest ecological context, economic development is the development of more intensive ways of exploiting the natural environment." Richard Wilkinson 14

"If all mankind were to disappear, the world would regenerate back to the rich state of equilibrium that existed ten thousand years ago. If insects were to vanish, the environment would collapse into chaos." Edward O. Wilson

"To waste, to destroy our natural resources, to skin and exhaust the land instead of using it so as to increase its usefulness, will result in undermining in the days of our children, the very prosperity which we ought by right to hand down to them amplified and developed." Theodore Roosevelt from his seventh annual message, December 3, 1907

"Our modern industrial economy takes a mountain covered with trees, lakes, running streams and transforms it into a mountain of junk, garbage, slime pits, and debris."

Edward Abbey

"When a man wantonly destroys one of the works of man we call him a vandal. When he destroys one of the works of God we call him a sportsman." Joseph Wood Krutch

"To people who think of themselves as God's houseguests, American enterprise must seem arrogant beyond belief … or stupid. A nation of amnesiacs, proceeding as if there were no other day but today. Assuming the land could also forget what had been done to it."

Barbara Kingsolver in her book Animal Dreams

“Trees love to toss and sway; they make such happy noises.”

“Be truthful, nature only sides with the truth.”

Adolf Loos 15

“Trees are the earth’s endless effort to speak to the listening heavens.”

Rabindranath Tagore

"When a stupid man is doing something he is ashamed of, he always declares that it is his duty." George Bernard Shaw

“Our answer is to develop land-based performance measures that evaluate the "outcomes" rather than the "outputs" of our management -- to focus less on what we take from the land and more on what leave behind. To focus less on the volume of wood fiber removed and more on the quality of the water, the diversity of the species, the productive capacity of the land, itself.” Remarks of USFS Chief Dombeck, Ph.D. at a Society of American Foresters Breakfast September 21, 1998

“Nature is an infinite sphere of which the center is everywhere and the circumference nowhere” Baise Pascal

“The greatness of a nation and its moral progress can be judged by the way its animals are treated” Mahatma Gandhi

“All over the world the wildlife that I write about is in grave danger. It is being exterminated by what we call the progress of civilization.” Gerald Durrell

“Trees are the earth’s endless effort to speak to the listening heavens.”

Rabindranath Tagore

“Only when the last tree has died and the last river has been poisoned and the last fish been caught will we realize we cannot eat money.” Cree Indian Proverb 16

“A fool sees not the same tree that a wise man sees.” William Blake, Proverbs of Hell, 1790

"[Forests are] the 'lungs' of our land, purifying the air and giving fresh strength to our people." President Franklin D. Roosevelt, speech, January 29, 1935

"The forests of America, however slighted by man, must have been a great delight to God, because they were the best He ever planted." John Muir in John Gunther's, Inside U.S.A., 1947

"Our task must be to free ourselves … by widening our circle of compassion to embrace all living creatures and the whole of nature and its beauty." Albert Einstein

"They kill good trees to put out bad newspapers." James G. Watt

“The quicker we humans learn that saving open space and wildlife is critical to our welfare and quality of life, maybe we'll start thinking of doing something about it.”

Jim Fowler

“For in the true nature of things, if we rightly consider, every green tree is far more glorious than if it were made of gold and silver.” Martin Luther

“What we are doing to the forests of the world is but a mirror reflection of what we are doing to ourselves and to one another.” Chris Maser

“If I were a tree, I would have no reason to love a human.” Maggie Stiefvater

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“Here is your country. Cherish these natural wonders, cherish the natural resources, cherish the history and romance as a sacred heritage, for your children and your children’s children. Do not let selfish men or greedy interests skin your country of its beauty, its riches or its romance.” Theodore Roosevelt

“It was strangely like war. They attacked the forest as if it were an enemy to be pushed back from the beachheads, driven into the hills, broken into patches, and wiped out. Many operators thought they were not only making lumber but liberating the land from the trees.” Murray Morgan, in her book The Last Wilderness about the first logging of the U.S. in the Olympic Peninsula

“The trees are man's best friends; but man has treated them as his worst enemies. The history of our race may be said to be the history of warfare upon the tree world. But while man has seemed to be the victor, his victories have brought upon him inevitable disasters.” Nathaniel H. Egleston

“Destroying a forest for economic gain is like burning a Renaissance painting to cook a meal.” Edward O. Wilson

“In the next 24 hours, deforestation will release as much CO2 into the atmosphere as 8 million people flying from London to New York. Stopping the loggers is the fastest and cheapest solution to climate change." Daniel Howden

The Process of Cutting Down and Removing the Trees in the Forest by Humans for Money Hampers and Thwarts the Proper Functioning of the Countless other Natural Resources there. The excerpts below should Interest USFS Employees who aren’t Afraid to

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Explore Science and Educated Viewpoints that Contradict Agency Dogma.

1) "Human beings and the natural world are on a collision course. Human activities inflict harsh and often irreversible damage on the environment and on critical resources. If not checked, many of our current practices put at serious risk the future that we wish for human society and the plant and animal kingdoms, and may so alter the living world that it will be unable to sustain life in the manner that we know. Fundamental changes are urgent if we are to avoid the collision our present course will bring about."

Union of Concerned Scientists

2) "The primary goal of resource management (sustained yield) evolved from the utilitarian values of the Progressive Era. Intuitively, sustained yield is a logical and laudable goal: no more is taken than can be replenished. As it has come to be implemented, however, the concept of sustained yield has been modified to mean taking the maximum supply a system can withstand (i.e., the furthest point to which production can be pushed without impairment of the resource’s ability to reproduce). One of our colleagues calls this 'management at the edge of harm'."

Hanna Cortner and Margaret A. Moote in The Politics of Ecosystem Management

3) "The one process now going on that will take millions of years to correct is the loss of genetic and species diversity by the destruction of natural habitats. This is the folly our descendants are least likely to forgive us." E.O. Wilson in Biopholia Hypothesis

4) "The instrument, the knife, that carved out the new, rudimentary forest was the razor- sharp interest in the production of a single commodity. Everything that interfered with the efficient production of the key commodity was implacably eliminated. Everything that seemed unrelated to efficient production was ignored. Having come to see the forest as a commodity, scientific forestry set about refashioning it as a commodity machine. Utilitarian simplification in the forest was an effective way of maximizing wood production in the short and intermediate term. Ultimately, however, its emphasis on

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yield and paper profits, its relatively short time horizon, and, above all, the vast array of consequences it had resolutely bracketed came back to haunt it." James C. Scott in Seeing Like a State

5) "Two broad schools of thought exist regarding landscape planning. In one, future landscape patterns are described in specific desired products (e.g., wood fiber, habitat) and known ecosystem processes. The theme can be summarized as ‘we know what we want and we know how to get it’.

In the other approach, future patterns are based upon historic patterns to the degree feasible. This point of view reflects the fact that we cannot even name all the species in the landscape, much less rationally plan for their habitat needs and ecosystem functions. A premise of this approach is that native species have adapted to the disturbance events and resulting range of habitat patterns of the past thousands of years. The probability of their survival is reduced if their environment deviates substantially from the range of historic conditions." Cissel, Swanson, McKee and Burditt in Journal of Forestry v. 92, no. 8, p. 30-31, 1994

6) "Current standards represent the protection of environmental and cultural values as constraints on managing the timber resource. Current standards do not effectively integrate ecosystem and cultural values. Nor do they adequately address requirements for ecosystem sustainability, harmonious stewardship of all resources, and the needs of future generations.

Historical approaches to forest management have focused largely on products rather than on the biological systems from which these products derive. In Clayoquot Sound, as elsewhere in British Columbia, sustaining timber production has historically taken precedence over maintaining forest ecosystems.

The Panel believes that forests should be managed as ecosystems, rather than as potential products, and that forest practices should not put at risk the long-term health of forest ecosystems. 'Sustainable ecosystem management' is characterized by resource management practices that are scientifically based, ecologically sound, and socially responsible.

The Scientific Panel’s recommendations are among the first efforts taken to shift forestry from its historical focus on sustaining output levels for specific forest products, to a focus on sustaining forest ecosystems." Clayoquot Sound Scientific Panel Symposium, March 3-6, 2011

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7) "Nature designed a forest as an experiment in unpredictability. We are trying to design a regulated forest. Nature designed a forest of long-term trends. We are trying to design a forest of short-term absolutes. Nature designed a forest with diversity. We are designing a forest with simplistic uniformity. Nature designed a forest with interrelated processes. We are trying to design a forest based on isolated products."

Chris Maser in The Redesigned Forest

8) "One of the most fundamental lessons of the last several decades of ecological research is that the biological diversity of North American forests is far greater than previously thought. At the same time, much more is at risk through traditional forestry programs then ever imagined. Perhaps nowhere has this been more pronounced that in the debate over the fate of the remaining old forests of the Pacific North-West."

Bruce Marcot in Creating a Forestry for the 21st Century

9) "As the second half of the twentieth century got underway, the bold form of sustained yield was pursued enthusiastically by the federal resource agencies. After WWII, the budget floodgates of public capital opened, and the maximizers of sustained yield went on a binge of dam construction, rangeland 'improvement', recreational facilities development, road building, and clear-cutting. Single-resource agencies, cheered on by their single-resource clientele groups undertook Type A management activities with unprecedented capability.

"Labeled 'intensive management' in the Forest Service, the enthusiasm led to 'a conspiracy of optimism' as historian Paul Hirt described the period. What timber management meant, in the post-war years, was the conversion of complex biological systems, the old growth forests of the West, into simplified timber plantations."

Richard W. Behan in Plundered Promise

10) "If 20th century forestry was about simplifying systems, producing wood, and managing at the stand level, 21st century forestry will be defined by understanding and 21

managing complexity, providing a wide range of ecological goods and services, and managing across broad landscapes…managing for wholeness rather than for the efficiency of individual components." Kohm and Franklin in Creating A Forestry For the 21th Century

11) "Sustainable forestry will not result from lengthening rotations on tree farms and preserving a few small areas for display of other forest qualities.

The evolution to sustainable forestry requires, at a minimum, a recognition of the limitations of present knowledge and of the risk that human intervention will do irreversible harm before enough knowledge accumulates to identify the practices of sustainable forestry. Alice Rivlin in Defining Sustainable Forestry

12) "Decisions made when the sustained yield paradigm was established after the Second World War set British Columbia on a path that has been and will continue to be extremely costly and disruptive to reverse."

Cashore et al., in Change and Stability in BC Forest Policy from In Search of Sustainability

13) "We simply did not understand some very basic aspects of forest structure and function. Consequently, traditional forestry approaches, based on a very simple view of a forest, have proven very inadequate. Resource managers thought that they could grossly simplify forests without consequence. They have done so on a grand scale, and often react energetically against adoption of alternative models of how forest ecosystems work.

There is no question that recognizing the potential ecological value of a dead tree makes life much more difficult (or, put another way, more interesting) for the silviculturalist. Perhaps as important, it challenges the basic value set for foresters, many of whom share a strongly utilitarian view of the forest." Jerry Franklin in Conservation Ecology

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14) "Sustained yield is not the same thing as sustainability. You could produce a sustained yield of timber (for several rotations anyway) without practicing sustainable forestry. Managing for a consistent and sustained supply of one commodity does not ensure that all other commodities and values will be maintained. Nor is the concept of sustained yield particularly appropriate for forests as ecosystems. Even if one includes all known non-timber forest products and all aspects of ‘wildcrafting’, most components of forest biodiversity are not harvestable resources. Nevertheless, natural resources have continued to be managed (or mismanaged) under the rubric of sustained yield in one form or another, and the histories of forestry, fisheries, and wildlife management show similar patterns [of resource depletion]." Pojar et al. in Silvicultural Options on the Central Coast draft BC MoF, 1999

15) "When systems are pushed outside the bounds of natural variability, there is a substantial risk that biological diversity and ecological function will be jeopardized and therefore, ecological systems will not be naturally maintained." Ayn Shlisky in Journal of Forestry

16) "Forestry has been largely concerned with silviculture, defined as "that branch of forestry which deals with the establishment, development, care, and reproduction of stands of timber" (Toumey 1947). The aim of silviculture, according to Toumey, is the "continuous production of wood". But forests comprise much more than wood and other products for human consumption, much more even then the "public service" functions of climate regulation, water supply, pest control, gene banks, or recreational opportunities. What future generations can afford to lose is not the only consideration. Forests are valuable and must be sustained for their own sake. Until we acquire such an attitude, the sustainability concept may just be a smoke screen, behind which we continue to chip away at our biotic heritage." Reed Noss in Defining Sustainable Forestry

17) "The agricultural paradigm of forestry adopted in this century (simplification and uniformity in structure, pattern, and product) and the regulated landscape (fully occupied by an ordered age sequence of managed stands) no longer suffices. The simplistic notion that four regeneration harvest practices, designed with the knowledge and objectives of the 19th century, can meet the objectives of the 21st century must be given up." 23

Kohm and Franklin in Creating a Forestry for the 21st Century

18) "Sustained yield and sustainable development are unquestionably in conflict. Attitudes, policies, and management strategies that evolved to serve the sustained yield ideal are, in many respects, outmoded. Sustainable development demands that timber primacy be replaced by a concern for a forests' contribution to human welfare in the broadest sense.

The emphasis must shift from maintaining timber supplies over the long run to maintaining a multitude of resource values that are dependent upon site productivity, ecosystem, ecosystem health, integrity, and diversity." David Haley and Martin Luckert in Managing Natural Resources in BC

19) "The major change in forestry thinking wrought by Ecosystem Management has been the abandonment of the concept of a stable flow of wood from the land as a universally dominant management objective. As an environmental paradigm replaces utilitarian, conservation, and preservation paradigms in land managers’ and the public’s view of the landscape, the management of whole systems for a variety of purposes rather than commodity flows or single resources (including "wilderness") will become increasingly overt and explicit. Ecosystem Management will differ from multiple-use management in focusing on inputs, interactions, and processes, as well as uses and outputs." John C. Gordon, Yale University

20) "There are currently many plans for sustainable use or sustainable development that are founded upon scientific information and consensus. Such ideas reflect ignorance of the history of resource exploitation and misunderstanding of the possibility of achieving scientific consensus concerning resources and the environment. Although there is considerable variation in detail, there is remarkable consistency in the history of resource exploitation: resources are inevitably overexploited, often to the point of collapse or extinction." Carl Walters, Donald Ludwig, and Ray Hilbor in Uncertainty, Resource Exploitation, and Conservation: Lessons from History published in Science 260(2):17, April 2, 1993

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21) "In my own field, forestry, group A is quite content to grow trees like cabbages, with cellulose as the basic forest commodity. It feels no inhibition against violence … its ideology is agronomic. Group B, on the other hand, sees forestry as fundamentally different from agronomy because it employs natural species, and manages a natural environment rather than creating an artificial one. Group B prefers natural reproduction on principle. It worries on biotic as well as economic grounds about the loss of species like chestnut, and the threatened loss of the white pines. It worries about a whole series of secondary forest functions: wildlife, recreation, watersheds, wilderness areas. To my mind, Group B feels the stirrings of an ecological conscience." Aldo Leopold in A Sand County Almanac

22) "Preservation of future stewardship options is rarely possible when current rates of resource exploitation are high. Preserving options assumes an acceptable "decision space" will be available to address the environmental problems confronting future human generations. However, many forest and range ecosystems have experienced intensive resource management and utilization by Euro-Americans with adverse effects on their productive potential. The most significant changes in these systems have occurred over the last 200 years.

For example, in forested systems most of the old-growth has been converted to younger stands, extensive road systems have been built with outdated technologies based on unsustainable levels of resource use. If current practices result in species becoming threatened or endangered, water quality standards being exceeded, or public values and trust violated, then dramatic readjustments to current stewardship activities are clearly needed.

Preserving options is also a way of explicitly acknowledging our incomplete knowledge of complex ecosystems – that is, our ignorance of how they function and their interactions with natural and human influenced disturbance regimes and our responsibilities to future human generations. This philosophy is perhaps best encapsulated by focusing more on what we leave behind in exploited ecosystems than on what is taken from them." Committee of Scientists Third draft Preliminary report, July 98

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23) “The proliferation of timber roads and rapid liquidation of old growth eventually made a mockery of sustained yield and multiple use policies on Northwest national forests, and this, in turn, spelled disaster for the Forest Service’s public image."

Paul Hirt in Institutional Failure in the U.S. Forest Service

24) "In the past, Registered Professional Foresters emerging from forestry schools across Canada were narrowly trained to maximize fibre production on a given area of land. Safeguarding the health and integrity of ecosystems did not constitute an important dimension of their education or of their work. In the 1990s, significant and long-needed changes are taking place in the forestry curricula in many Canadian schools. However, the new approach is still framed within the sustained yield forest management paradigm, and on prioritizing fibre production over ecosystem health and integrity. Only fundamental reform of the forestry profession can create the New Forester to practice the New Forestry." Fred Gale in The Wealth of Forests

25) "The concept that all forests must be silviculturally manipulated (logged) and eventually replaced in order to provide desired goods and services, including the continued health of forest landscapes, is an old and honored tradition among many forestry professionals. The "fully regulated" forest landscape with its "balanced" distribution of forest age classes, or developmental states, has been a goal and icon of forest management for over a century. Another traditional view is that forests must be actively replaced, because without human intervention their ability to provide goods and services will decline and fire, storm, insects or disease will eventually destroy them.

Proposals for widespread logging as the mechanism to create and provide for all forest values are therefore not surprising. These approaches continue to be advanced by advocates of timber harvesting under such rubrics as "Structure-Based Management" and "High Quality Forestry." Franklin et el. in Simplified Forest Management ... National Wildlife Federation Report

The Take-home Message

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Things can and should change in the USFS. In their own way all national forest employees can contribute to this change if they wish to serve the kids born many decades from now. Will these kids feel it’s a wise to plunder the national forests for short-term corporate profit now? USFS non-timber natural resource specialists have the collective power to start the change.

How do you Feel after Reading this Far?

• 1) you are probably angry that a member of the public would have the audacity to challenge your professionalism and land values/ethics, or • 2) you don’t care, or perhaps • 3) you are secretly intrigued because you have had doubts at times yourself about what you do.

I invite you all to send me science authored by independent scientists who aren’t affiliated with the USFS that shows 1 or more of the 25 statements above is untrue.

Here’s what you can do. It’s simple:

• Assure your timber sale NEPA document complies with the environmental laws of the United States: ESA, NFMA and NEPA.

• Assure the needs described in the Purpose and Need are really needed to maintain and enhance the proper functioning of all the natural resources in the area, and not a cooked-up, fabricated excuses to log. Assure your Chapter 3 environmental effects are honest and based on best science.

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Photo of “Short-Term” damage -- Olympic National Forest – Washington -- 2008 (note the mudslide on this “restoration” timber sale)

Thanks again for reading this far. Perhaps you might change your ways. Please understand that the happiness and well being of future generations of kids is more important than short-term corporate profit opportunities.

Do you have the fortotude and curiosity to respond to me? I won’t tell your supervisor. My goal is not to get USFS employees in trouble. I’m sure you have wondered about some of the things you have read. My goal is to stimulate change … 1 person at a time. Please attempt to conquer you fear. There are 324 million Americans that depend on you to do the right thing.

Dick Artley (USFS retired) Grangeville, Idaho [email protected]

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Glyphosate Dangers

This document contains links to Monsanto and glyphosate safety literature. Of course we cannot believe everything posted on the web, but you will get 765,000 hits when you search for websites that contain the words “glyphosate” and “cancer.” ------Non-native invasive plant spread in the national forests is one of the largest threats to the proper functioning forest ecosystem. I commend you for recognizing this and spending taxpayer’s money to deal with it. There are many methods to address this threat. They include different types of herbicides, hand pulling and biological control.

Please allow me to point out something you and your staff should already know. You propose to apply a potentially lethal chemical to your national forest. I suggest you read the information authored by independent scientists below. Then ask your USFS invasive plant eradication expert who assisted you with this project why they suggested an herbicide containing the chemical glyphosate be applied to public land.

In the next 50 pages I will present irrefutable research-based evidence that casual exposure to the chemical glyphosate is one of the causes of birth defects, miscarriages, premature births, cancer - non-Hodgkin’s lymphoma and hairy cell leukemia, DNA damage, autism, irreparable kidney and liver damage, infertility, learning disabilities, ADHD and other neurological disorders (especially in children), mitochondrial damage, cell asphyxia, endocrine disruption, bipolar disorder, skin tumors, thyroid damage, decrease in the sperm count and chromosomal damage. Regardless of what your agency says, no human being would take action that independent research scientists (not affiliated with the USFS) show sometimes causes these horrific physical conditions.

Here’s a very recent (January 27, 2017) article published in Your Newswire. Link to entire article: http://yournewswire.com/france-bans-sale-of-monsanto-herbicide- roundup/

France Bans Sale Of Monsanto Herbicide Roundup

Excerpt: 1

“The week-killer will no longer be available in garden centres in France, following French Ecology Minister Segolene Royal’s announcement on national television,“I have asked garden centres to stop putting Monsanto’s Roundup on sale“ “

Here’s another recent (January 24, 2017) article published in Truthout. Link to entire article: http://www.truth-out.org/news/item/39197-monsanto-epa-seek-to- keep-talks-secret-on-glyphosate-cancer-review

MONSANTO, EPA SEEK TO KEEP TALKS SECRET ON GLYPHOSATE CANCER REVIEW

Excerpts:

“Monsanto Co. and officials within the Environmental Protection Agency are fighting legal efforts aimed at exploring Monsanto's influence over regulatory assessments of the key chemical in the company's Roundup herbicide, new federal court filings show.

The revelations are contained in a series of filings made within the last few days in the U.S. District Court for the Northern District of California as part of litigation brought by more than 50 people suing Monsanto. The plaintiffs claim they or their loved ones developed non-Hodgkin lymphoma (NHL) after exposure to Roundup herbicide, and that Monsanto has spent decades covering up cancer risks linked to the chemical.”

“The EPA has spent the last few years assessing the health and environmental safety aspects of glyphosate as global controversy over the chemical has mounted. The World Health Organization's International Agency for Research on Cancer (IARC) declared in March 2015 that glyphosate is a probable human carcinogen, with a positive association found between glyphosate and NHL. Monsanto has been fighting to refute that classification.”

Please do not ignore or reject the information below thinking it’s your duty as a loyal USFS employee to do so. Remember, you are a human being. As you will see I have done extensive research on the chemical glyphosate. Why? My granddaughter died of cancer in 2013. It was tragic to watch her die. Cancer caused by glyphosate exposure is preventable. You can accomplish your land management goals using alternatives to herbicides that contain glyphosate: mechanical methods, biological methods and other herbicides.

Please explore the Monsanto website(s) available at the link below that deny any relationship between glyphosate and cancer. Roundup generates $15.9 billion dollars

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for Monsanto from worldwide sales each year. Might this explain their denial? Please see: https://www.bloomberg.com/news/articles/2015-03-20/who-classifies-monsanto-s- glyphosate-as-probably-carcinogenic-

Here are the results of my research:

Why Glyphosate Should Be Banned – A Review of its Hazards to Health and the Environment Published by, Permaculture Research Institute, November 1, 2012

Note: the USDA has known this for 4 years and still looks the other way to please Monsanto.

Excerpts:

“The use of glyphosate-based herbicides, especially Monsanto’s Roundup formulation, has increased dramatically since the introduction of genetically modified (GM) glyphosate-tolerant crops, resulting in the contamination of our food, environment and water supplies.

Glyphosate-based herbicides are now the most commonly used herbicides in the world. It is still promoted as ‘safe’, despite damning evidence of serious harm to health and the environment.”

“Evidence of harm to health • Monsanto and the European Commission (EC) have known about birth defects since the 1980s. Industry studies found statistically significant skeletal and/or visceral abnormalities as well as reduced viability and increase in spontaneous abortions in rats and rabbits exposed to high doses of glyphosate. Lower doses were later shown to cause dilated hearts. The EC dismissed all the findings.

• Independent studies have since found caudal vertebrae loss in rats treated with sub- lethal doses of the herbicide; as well as craniofacial abnormalities, increased embryonic mortality and endocrine disruption, abnormal onset of puberty, and abnormal sexual behaviour and sperm count in male offspring of mothers exposed during gestation.

• GM soybean-fed female rats gave birth to excessive numbers of severely stunted pups, with over half of the litter dead by three weeks, and the surviving pups were sterile.

• Non-mammalian animals exposed to glyphosate resulted in increased gonad size, increased mortality, craniofacial abnormalities correlating with abnormal retinoic acid signalling, and reduced egg viability.

• In vitro exposure to glyphosate resulted in endocrine disruption and death of cells of the testis, placenta, and umbilical cord.

• A long term in vivo study on rats found females exposed to Roundup and/or Roundup Ready GM maize were two to three times as likely to die as controls and much more

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likely to develop large mammary tumours, while males presented large tumours four times controls and up to 600 days earlier.

• Clinical data from Argentina are consistent with lab findings of increases in birth defects and cancers in regions with large areas cultivating glyphosate-tolerant soybean.

• Endocrine disruption has been observed in both in vivo and in vitro studies in the laboratory, including abnormal levels of testosterone, aromatase enzyme, testosterone and oestrogen receptors, leutinising hormone, follicle-stimulating hormone. Endocrine disruption can lead to cancers and reproductive problems.

• Epidemiological studies have found links to cancer including non-Hodgkin lymphoma and increased plasma cell proliferation. Cancer rates have risen in in glyphosate-use zones in Argentina. Lab studies found significant increases in interstitial cell tumour incidence in rats as well as skin tumour-promoting activity. Numerous lab studies including those performed by industry showed glyphosate damages DNA of cells in culture as well as in humans living in glyphosate-sprayed regions of Argentina. Non-mammalian studies found defects in cell cycle checkpoints and DNA damage repair machinery. DNA damage is a major prelude to cancers. AMPA, the glyphosate metabolite, also has genotoxic effects.

• Neurotoxicity effects include Parkinsonism have emerged following acute exposure. Exposure to glyphosate resulted in oxidative stress in lab animals and death of neuronal cells, correlating with Parkinsonian pathology. Acute exposure in fish resulted in acetylcholine esterase (AChE) inhibition. An epidemiological study linked glyphosate - exposure to Attention-Deficit-Hyperactive disorder in children, a disorder associated with AChE inhibition. The original neurotoxicity studies carried out by industry were ruled invalid by the US Environment Protection Agency and urgently need re-examining by independent scientists.

• Internal organ toxicity has been documented in animal feeding studies with glyphosate- tolerant soybean. Rats suffered kidney abnormalities including renal leakage and ionic disturbances, and liver pathology including irregular hepatocyte nuclei, and increased metabolic rates.

• Acute toxicity of glyphosate is officially declared low by government agencies; however agricultural workers have reported many symptoms including skin irritation, skin lesions, eye irritation, allergies, respiratory problems and vomiting. Ingestion of large volumes causes systemic toxicity and death.”

Link to full report: http://permaculturenews.org/2012/11/01/why-glyphosate-should-be- banned-a-review-of-its-hazards-to-health-and-the-environment/

Monsanto’s Roundup linked to fatty liver disease Published by: Nation of Change, January 11, 2017

Excerpts:

Glyphosate – the controversial active ingredient in Monsanto’s top-selling weedkiller Roundup and other herbicides – can cause non-alcoholic fatty liver disease in rats at very low, real-world doses, according to a peer-reviewed study published in Nature.”

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“The groundbreaking research is the first to show a “causative link between an environmentally relevant level of Roundup consumption over the long-term and a serious disease,” stated lead author Dr. Michael Antoniou of King’s College London, who described the findings as “very worrying.” “

Link: http://www.nationofchange.org/2017/01/11/monsantos-roundup-linked-fatty-liver-disease/

Monsanto spends an incredible amount of money each year to suppress real science and manipulate the media. This corporation even invents its own science that the USFS chooses to embrace as I will show later.

Monsanto undermines EPA's scientific review Published by: Pesticide Action Network, December 8, 2016

Excerpts:

“After halting the process in October, the Environmental Protection Agency (EPA) recently put its review of glyphosate back on the calendar for December 13-16. Scientists will gather on behalf of the agency to review the carcinogenic properties of the key ingredient in Monsanto’s flagship herbicide RoundUp.”

“EPA originally postponed the meeting after Monsanto publicly attempted to discredit participating scientists chosen by the agency. While the Scientific Advisory Panel (SAP) will convene next week, it’s notably missing Peter Infante — an expert epidemiologist Monsanto publicly accused of bias.”

“Caving to industry pressure A few days before the SAP meeting was supposed to start in October, Monsanto sent a letter to EPA claiming that Infante was “biased” because he had historically defended plaintiffs in chemical exposure cases against Monsanto and affiliated agrichemical corporations — and challenged the legitimacy of industry-funded studies.

Given that Infante is no longer participating in the review process, it seems Monsanto’s tactics to undercut independent, non-industry science were effective.”

Link: http://www.panna.org/blog/monsanto-pushing-silence- science?utm_source=blog&utm_campaign=gt-12-09&utm_medium=groundtruth

Ask yourself why the poison called glyphosate is banned for use in 3rd word countries and still allowed in the United States if Monsanto does not control the regulatory agencies in this country. Now ask yourself why Congress included Section 735 in the 2013 spending bill (HR 933) that was signed by President Obama. Section 735 is known by many as the "Monsanto Protection Act." See: http://www.ibtimes.com/monsanto-protection-act-5-terrifying-things-know-about-hr-933- provision-1156079

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As I will show, the USDA has been snuggling with Dow, Syngenta, Monsanto, Bayer, and DuPont for decades. It’s not surprising the USFS receives untrue information from the USDA about the chemicals these corporations manufacture. Please see Section #1 below.

My father and mother both died of cancer. Their pain was unimaginable. This is why I have taken time to investigate the chemical glyphosate … that’s sold over the counter as Roundup to misinformed consumers.

My comments are structured using the following sections:

Section 1) Monsanto exerts unacceptable influence over the USDA

Section 2) The USFS depends on a single (emphasis added) research conclusion that glyphosate is safe by a lab with clear ties to Monsanto (Syracuse Environmental Research Associates--SERA) knowing the research conducted by thousands of independent scientists reveals glyphosate exposure is lethal.

Section 3) Glyphosate is especially toxic to children

Section 4) Herbicides that contain glyphosate are prohibited in 26 countries and the state of California classifies glyphosate as a “”

Section 5) California classifies glyphosate as a“ ------Section 1

The USDA has been in bed with Monsanto for decades

It’s well known that in the United States today corporate executives and lobbyists sometimes control the behavior of 1) some government agency employees and 2) the information made available to these employees.

Clearly, Monsanto controls the USDA’s herbicide science and conclusions. Here are papers& articles that should be read by all Americans:

Six Reasons Why Obama Appointing Monsanto's Buddy, Former Iowa Governor Vilsack, for USDA Head Would be a Terrible Idea 6

Published by Organic Consumers Association, November 12, 2008

Excerpt:

“Vilsack has a glowing reputation as being a schill for agribusiness biotech giants like Monsanto. Sustainable ag advocated across the country were spreading the word of Vilsack's history as he was attempting to appeal to voters in his presidential bid.”

Link: https://www.organicconsumers.org/news/six-reasons-why-obama-appointing- monsantos-buddy-former-iowa-governor-vilsack-usda-head-would

Monsanto Receives Full Deregulation From Vilsack's USDA For Roundup Ready Alfalfa Published by Alabama Confidential, January 31, 2011

Excerpt:

“Monsanto shill supreme, USDA Head Tom Vilsack pushed hard for his favorite corporate demon, the dreaded Monsanto, to further gain total control of US agriculture with this latest power bestowal by granting full deregulation for Monsanto's genetically modified Alfalfa:”

“Vanity Fair covered this issue in an investigative piece from May 2008 aptly entitled "Monsanto's Harvest of Fear" that is a compelling read and an in-depth probe into the frightening power that Monsanto has and wants.

And thanks to this latest ruling from the USDA, in conjunction with the false Food and Safety Bill that passed in the lame duck session of Congress, they are well on their way to getting it.” Link: http://alabamacorruption.blogspot.com/2011/01/monsanto-recieves-full- deregulation.html

Tom "Monsanto" Vilsack Must Go. Published by Daily Kos, April 25, 2011

Excerpt:

“He should go to Monsanto, that is, where we know he'll end up in a cushy job making bushels of money following his adventure as Secretary of Agriculture. Why waste our time? Why not just do it now Tom? You're already working for them:”

“Who needs the federal agency responsible for ensuring food safety for Americans? In our brave new world we rely on the "invisible hand" of the market place to regulate itself! So it's only natural that Vilsack would approve a program allowing companies like Monsanto to review itself. I'm sure Monsanto will do the environmental assessments and find that "Oh My Gosh!", GMO's are perfectly safe!” 7

Link: http://www.dailykos.com/story/2011/04/25/969976/-Tom-Monsanto-Vilsack-Must- Go

Ag Secretary Tom Vilsack: Too much Monsanto in the Mix? Published by OpEdNews, December 17, 2008

Excerpt:

“Iowans also remember the rides on Monsanto's corporate jet that Vilsack - the Biotech "Governor of the Year" - enjoyed during his time in office. He repayed Monsanto by working with the Republican floor manager in the House, promising to do everything he could to get a seed bill to pass. This bill took away county power to regulate GMOs within county borders.”

Link: http://www.opednews.com/articles/Ag-Secretary-Announced-To-by-Jill-Hamilton- and-081216-596.html

How did Barack Obama become Monsanto’s man in Washington? Published by Infowars, April 29, 2013

Excerpts:

“After his victory in the 2008 election, Obama filled key posts with Monsanto people, in federal agencies that wield tremendous force in food issues, the USDA and the FDA:”

“At the USDA, as the director of the National Institute of Food and Agriculture, Roger Beachy, former director of the Monsanto Danforth Center.”

“As commissioner of the USDA, Iowa governor, Tom Vilsack. Vilsack had set up a national group, the Governors’ Biotechnology Partnership, and had been given a Governor of the Year Award by the Biotechnology Industry Organization, whose members include Monsanto.”

“As the new counsel for the USDA, Ramona Romero, who had been corporate counsel for another biotech giant, DuPont.”

“Obama’s signing of the Monsanto Protection Act, making that corporation senior in power to the US court system, wasn’t an accident. It was taken in keen awareness of his duty to his Globalist betters.”

Link: http://www.infowars.com/how-did-barack-obama-become-monsantos-man-in- washington/

Monsanto Has Tom Vilsack Under Its Thumb Broadcast by Ring of Fire Radio, LLC, March 25, 2013 8

Excerpt:

“The Agricultural Department sent a budget to the White House last week, with orders from the meat industry and agricultural giant Monsanto on how Secretary Tom Vilsack should do his job. Monsanto, a company known for its controversial and potentially dangerous genetically engineered crop seeds, has been under fire for years for putting profit over consumer need and safety.”

Link: https://trofire.com/2013/03/25/monsanto-has-tom-vilsack-under-its-thumb/

USDA Forces Whole Foods to Accept Monsanto Published by Reader Supported News, February 3, 2016

Excerpts:

“In a cleverly worded, but profoundly misleading email sent to its customers last week, Whole Foods Market, while proclaiming their support for organics and "seed purity," gave the green light to USDA bureaucrats to approve the "conditional deregulation" of Monsanto's genetically engineered, herbicide-resistant alfalfa.

Beyond the regulatory euphemism of "conditional deregulation," this means that WFM and their colleagues are willing to go along with the massive planting of a chemical and energy-intensive GE perennial crop, alfalfa; guaranteed to spread its mutant genes and seeds across the nation; guaranteed to contaminate the alfalfa fed to organic animals; guaranteed to lead to massive poisoning of farm workers and destruction of the essential soil food web by the toxic herbicide, Roundup; and guaranteed to produce Roundup- resistant superweeds that will require even more deadly herbicides such as 2,4 D to be sprayed on millions of acres of alfalfa across the U.S.” Link: http://readersupportednews.org/opinion2/265-34/34968-usda-forces-whole-foods- to-accept-monsanto

GMO Science Deniers: Monsanto and the USDA The Huffington Post, May 20, 2015

Excerpt:

“Perhaps no group of science deniers has been more ridiculed than those who deny the science of evolution. What you may not know is that Monsanto and our United States Department of Agriculture (USDA) are among them. That’s right: for decades, Monsanto and its enablers inside the USDA have denied the central tenets of evolutionary biology, namely natural selection and adaptation. And this denial of basic science by the company and our government threatens the future viability of American agriculture.”

“Now Monsanto and Dow Chemical have received government approval to market new genetically engineered corn, soy and cotton, that are “stacked” with engineered DNA 9

that make them resistant to Roundup as well as 2,4-D (one of the chief elements of “Agent Orange”). Monsanto has also gained approval from the USDA for the same three crops that can tolerate Dicamba. 2,4-D and Dicamba are older, more toxic herbicides than Roundup, and these companies are reverting to them because they have brought us to the point of peak herbicides. They simply don’t have any new ones, similar to the current crisis in antibiotics.”

Link: http://www.huffingtonpost.com/andrew-kimbrell/gmo-science-deniers-monsanto- and-the-usda_b_6904606.html

There is not enough room to print quote excerpts from them all. Here are the links to the rest for those who are interested in reading about Monsanto controlling the USDA … and of course the USFS.

Is the USDA a wholly owned subsidiary of Monsanto? Link: http://www.cornucopia.org/is-the-usda-a-wholly-owned-subsidiary-of-monsanto/

Obama's Highly Corrupt USDA: END Monsanto. Link: http://www.thomhartmann.com/users/telliottmbamsc/blog/2013/10/obamas-highly-corrupt- usda-end-monsanto

A Government of Monsanto, by Monsanto, and for Monsanto Link: http://farmwars.info/?p=5860

USDA to Give Monsanto’s New GMO Crops Special ‘Speed Approval’ Link: http://naturalsociety.com/usda-to-give-monsantos-new-gmo-crops-special-speedy- approval/

Monsanto’s GMO Policy Infecting All Levels of Government Link: http://www.nationofchange.org/monsanto-s-gmo-policy-infecting-all-levels-government- 1373204831

Another Monsanto man in a key USDA post? Obama’s ag policy’s giving me whiplash Link: http://grist.org/article/2009-09-24-usda-obama-monsanto-organic/

GMO Science Deniers: Monsanto and the USDA Link: http://www.wanttoknow.info/a-gmo-science-deniers-monsanto-the-usda

USDA Forces 'Whole Foods' To Accept Monsanto Link: http://humansarefree.com/2012/02/usda-forces-whole-foods-to-accept.html

In Defiance of Sanity, USDA Approves Dow's Agent Orange GMO Link: http://www.sustainablebusiness.com/index.cfm/go/news.display/id/25907

Is the USDA Covering Up Potential Dangers That Affect Your Health?

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Link: http://www.liveinthenow.com/article/is-the-usda-covering-up-dangers-that-affect-your- health

USDA and Monsanto “Biotech” Industry Collusion Link: http://www.truthwiki.org/usda-and-monsanto-biotech-industry-collusion/

Corruption at the USDA Link: https://newhomeeconomics.wordpress.com/2010/03/09/corruption-at-the-usda/

USDA Admits Exterminating Birds, Crops, and Bees Link: http://worldtruth.tv/usda-admits-exterminating-birds-crops-and-bees/

USDA: Stop Killing Bees and Butterflies (CCD) While Saving Monsanto (Round-Up) Link: https://www.change.org/p/usda-stop-killing-bees-and-butterflies-ccd-while-saving- monsanto-round-up

U.S.D.A. infiltrated by Monsanto. Link: https://legacy.minds.com/blog/view/460310689387388940/usda-infiltrated-by-monsanto

STOP the Corrupt FDA and USDA Madness Once and For All! Link: https://www.change.org/p/athena-telos-stop-the-corrupt-fda-and-usda-madness-once-and- for-all

Are you aware that the USDA is attempting to corrupt organic standards? Link:http://www.carbonproduct.net/Health_and_Fitness/Are_you_aware_that_the_USDA_is_att empting_to_corrupt_orangic_standards/_17096

NEW SCANDAL FOR USDA & MONSANTO: Whistle Blowers at USDA say MONSANTO Influences Agency Suppression of Critical Science. Link: http://mauicauses.org/new-scandal-for-usda-monsanto-whistle-blowers-at-usda-say- monsanto-influences-agency-suppression-of-critical-science/

USDA moves to let Monsanto perform its own environmental impact studies on GMOs Link: http://axisoflogic.com/artman/publish/Article_62860.shtml

Monsanto’s GMO Crops Ravage US, USDA Ignores Dangers Link: http://www.alipac.us/f19/monsanto%92s-gmo-crops-ravage-us-usda-ignores-dangers- 247146-print/

THE BITTER TRUTH ABOUT THE USDA AND MONSANTO SUGAR BEETS Link: http://geneticallyengineeredfoodnews.com/monsanto-sugar-beets

USDA Approves Toxic Herbicide Amidst Great Public Outcry Link: http://healthimpactnews.com/2014/usda-approves-toxic-herbicide-amidst-great-public- outcry/

USDA Gives Green Light to 2,4-D Resistant GM Crops Link: http://sustainablepulse.com/2014/01/03/usda-gives-green-light-pesticide-promoting-gm- crops/#.VlIUtJbTm1s 11

USDA approves the second generation of GMOs resistant to more toxic herbicide Link: http://www.seattleorganicrestaurants.com/vegan-whole-food/usda-approves-second- generation-of-GMOs-resistant-to-toxic-herbicide-isoxaflutole-IFT.php

USDA refuses to test foods for glyphosate contamination, says pesticides are safe to eat. Link: http://www.naturalnews.com/048237_glyphosate_contamination_USDA.html

USDA Secretary Vilsack's proposal for product labeling: companies will voluntarily, use barcodes to tell consumers if their products contain GMOs. This would require you to scan the product, then be directed to the company’s website where you’d have to wade through the advertising and search the fine print. Link: https://www.organicconsumers.org/essays/%E2%80%98qr%E2%80%99-barcodes-latest- plot-keep-you-dark-about-gmos

Herbicide Use To Increase Dramatically Link: http://www.enn.com/agriculture/article/47711

USDA Approval of Second-Generation of GMOs Link: http://undergroundhealthreporter.com/usda-approval-of-second-generation-of- gmos/#axzz3sFaNPdRd

You are probably wondering what to do. Should you do the ethical, caring thing by not applying glyphosate or are you worried about your job? There are alternatives to glyphosate: hand pulling, biological eradication methods and other herbicides. Please use them. What kind of person takes a chance on killing someone because their employer says its OK? ------Section 2

As is the case here, USFS EAs and EISs that propose to apply glyphosate cite research conclusions from the Human Health and Ecological Risk Assessment prepared by Syracuse Environmental Research Associates’ (SERA).

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As I will show below, an examination of the SERA Risk Assessment denies or does not address the causal relationship between glyphosate exposure and human health problems disclosed by hundreds of independent scientists worldwide. The USFS ignores this science. Section #1 above explains why. Its not surprising the agency embraces the SERA conclusion.

Please open your mind and find out the corporation or agency that sanctioned and funded the so-called SERA research. Here’s a hint: it wasn’t the USFS … although considerable effort was made to make it appear the project was driven by the agency.

The safety conclusions of most USFS EAs and EISs that analyze and approve application of herbicides that contain glyphosate are based in the SERA report below.

Report Name: Glyphosate -Human Health and Ecological Risk Assessment Final Report, 2011 Prepared by: Syracuse Environmental Research Associates, Inc. Prepared for: USDA Forest Service, Contract Number: AG-3187-C-06-0010 Link to Report: http://www.fs.fed.us/foresthealth/pesticide/pdfs/Glyphosate_SERA_TR-052-22- 03b.pdf

My examples of SERA deception shown below use the following format: I have selected 9 tragic physical conditions caused by casual glyphosate exposure. First, I present a few links to the many examples of independent science conclusions that discuss how glyphosate causes these conditions. Then I quote the SERA report’s discussion denying the “best science” conclusions.

On page xviii the SERA Report makes ridiculous, untrue claims.

Executive summary

“This risk assessment on glyphosate is dominated by three considerations: the extensive literature available on glyphosate, the availability of numerous glyphosate formulations, and the use of surfactants either as components in glyphosate formulations or as adjuvants added to glyphosate formulations prior to application.”

Comment: After reading the information below, intelligent, unbiased people would conclude “the extensive literature available on glyphosate” reveals glyphosate exposure causes tragic, catastrophic physical conditions in mammals including humans. I challenge you to find science literature besides the SERA Report that concludes glyphosate is safe that’s not authored by 1) USFS employees, 2) the corporation that manufactures the chemical glyphosate, or 3) scientists with ties to Monsanto.

Human Health 13

“The preponderance of the available data, however, clearly indicates that the mammalian toxicity of glyphosate is low, and very few specific hazards can be identified.”

After reading the information below, intelligent, unbiased people would conclude claims that “the mammalian toxicity of glyphosate is low, and very few specific hazards can be identified” is a lie intended to increase the sales of Roundup and Monsanto profits. This in itself would cause anyone to reject the rest of the SERA conclusions.

The statements quoted from the SERA Report below intended to disprove independent research conclusions linking glyphosate to tragic health effects are highlighted in brown font.

In most cases, the SERA report denies glyphosates connection with health problems. In a few cases, a word search of the SERA report indicates the tragic physical conditions caused by glyphosate that are disclosed by multiple independent scientists below isn’t even addressed. ***************************************** #1 Birth Defects

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Roundup: Birth Defects Caused By World’s Top-Selling Weedkiller, Scientists Say The Huffington Post, August 24, 2011

Excerpts:

“Our examination of the evidence leads us to the conclusion that the current approval of glyphosate and Roundup is deeply flawed and unreliable,” wrote the report’s authors. “What is more, we have learned from experts familiar with pesticide assessments and approvals that the case of glyphosate is not unusual.

“They say that the approvals of numerous pesticides rest on data and risk assessments that are just as scientifically flawed, if not more so,” the authors added. “This is all the more reason why the Commission must urgently review glyphosate and other pesticides according to the most rigorous and up-to-date standards.”

Monsanto spokeswoman Janice Person said in a statement that the Earth Open Source report presents no new findings.”

“The study, published in the journal Chemical Research in Toxicology in 2010, found that glyphosate causes malformations in frog and chicken embryos at doses far lower than those used in agricultural spraying. It also found that malformations caused in frog and chicken embryos by Roundup and its active ingredient glyphosate were similar to human birth defects found in genetically modified soy-producing regions.”

Link: http://www.huffingtonpost.com/2011/06/24/roundup-scientists-birth- defects_n_883578.html

Lab Study Establishes Glyphosate Link to Birth Defects Institute of Science in Society, April 10, 2010

Excerpt:

“In regions where glyphosate-based herbicides are used, specific neural defects and craniofacial malformations were reported. This prompted Prof. Andrés Carrasco, director of the Laboratory of Molecular Embryology at the University of Buenos Aires Medical School into action. He and his colleagues carried out a laboratory study on the effects of glyphosate on the development of frog embryos. They found the same kinds of abnormalities in frog embryos incubated with a 5 000 fold diluted solution of the Roundup herbicide [2]. The findings were so serious that Carrasco decided to release the results before publication [3] (Glyphosate Herbicide Could Cause Birth Defects Glyphosate Herbicide Could Cause Birth Defects, SiS 43), and in May 2009, the Environmental Lawyers Association of Argentina initiated a lawsuit to ban the herbicide.”

Link: http://www.i-sis.org.uk/glyphosateCausesBirthDefects.php

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The inside story on Monsanto and the glyphosate birth defect data The Ecologist, June 13, 2011

Excerpts:

“The report reveals that industry’s own studies (including one commissioned by Monsanto itself) showed as long ago as the 1980s that Roundup’s active ingredient glyphosate causes birth defects in laboratory animals. Industry submitted these studies to the European Commission in support of its application for glyphosate’s approval for use in Europe. As the 'rapporteur' member state for glyphosate, liaising between industry and the Commission, Germany took an active role in minimising the problems with glyphosate and must shoulder a chunk of the responsibility for allowing it onto the market.”

“Monsanto also repeats the usual industry claim that the studies that show problems with glyphosate are 'flawed'. But as our report proves, studies that show glyphosate causes birth defects include industry’s own, Monsanto’s among them. Is Monsanto saying its own studies are flawed? If so, we have all the more reason to worry, as these are the studies on which the current approval of glyphosate rests.”

Link:http://www.theecologist.org/blogs_and_comments/commentators/other_com ments/938661/the_inside_story_on_monsanto_and_the_glyphosate_birth_defect _data.html

Monsanto's Roundup Herbicide Threatens Public Health Rachel's Environment and Health News, issue 751, Sept. 5, 2002. Reprinted by Organic Consumers Association, September 25, 2001

Excerpt:

“Two new studies indicate that Monsanto's herbicide, Roundup, is a hormone- disruptor and is associated with birth defects in humans. Farm families that applied pesticides to their crops in Minnesota were studied to see if their elevated exposure to pesticides caused birth defects in their children. The study found that two kinds of pesticides -- fungicides and the herbicide Roundup -- were linked to statistically significant increases in birth defects. Roundup was linked to a 3-fold increase in neurodevelopmental (attention deficit) disorders. [EHP Supplement 3, Vol. 110 (June 2002), pgs. 441-449.]

Link: http://www.organicconsumers.org/Monsanto/roundup92502.cfm

I invite you to search the WEB using “glyphosate” and “birth defects.” You will get several hundred thousand hits.

Why does the USFS ignore hundreds sources of science information and make life threatening decisions based on the conclusions of a single (emphasis added) SERA report? Why do you go along with their scheme to please Monsanto?

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Here is the SERA Report’s denial of the fact that glyphosate exposure causes birth defects:

The 2011 SERA glyphosate safety report at page 19 states: “There is no indication that glyphosate causes birth defects.” ***************************************** #2 Miscarriages

Is Glyphosate Responsible for your Health Problems? from Health Impact News, December 6, 2015

Excerpts:

“But, what about that other modern advance made in the 1970s? Has Roundup stood the test of time, or is it also another failed experiment? The short answer is that Roundup/glyphosate can easily be ranked together with DDT, because of its chemical similarity and its toxicity. [9]”

“A U.S. government study measured the amount of glyphosate in air and rain samples in the agricultural area of the Mississippi delta between 1995 and 2007. Results found Roundup and its toxic metabolite called AMPA in over 75% of the air and rain samples tested in 2007. (AMPA is the toxic residue that is left after glyphosate degrades into other chemical forms.) Glyphosate in the air is absorbed directly into the blood by way of the lungs. Even though the daily exposure is low, we now know that extremely low exposure, measured in parts per trillion, can disrupt the human endocrine system and stimulate cancer growth. The air and rain samples were taken in locations that were 3 miles away from the fields where Roundup was used. [16]”

“The endocrine disrupting properties of glyphosate can lead to reproductive problems: infertility, miscarriage, birth defects, and sexual development. Fetuses, infants and children are especially susceptible because they are continually experiencing growth and hormonal changes. For optimal growth and development, it is crucial that their hormonal system is functioning properly…. The endocrine disrupting properties also lead to neurological disorders (learning disabilities (LD), attention deficit hyperactive disorder (ADHD), autism, dementia, Alzheimer’s, schizophrenia and bipolar disorder). Those most susceptible are children and the elderly. [25]”

Link: http://healthimpactnews.com/2014/is-glyphosate-responsible-for-your- health-problems/

Glyphosate Weedkiller in Our Food and Water? from Infowars, June 17, 2013

Excerpts:

“In 2011, Earth Open Source said that official approval of glyphosate had been rash, problematic and deeply flawed. A comprehensive review of existing data 18

released in June 2011 by Earth Open Source suggested that industry regulators in Europe had known for years that glyphosate causes birth defects in the embryos of laboratory animals. Questions were raised about the role of the powerful agro-industry in rigging data pertaining to product safety and its undue influence on regulatory bodies (2).”

“With some hugely powerful players involved here, many of whom have successfully infiltrated important government and official bodies (9), much of the science and the ensuing debate surrounding glyphosate is being manipulated and hijacked by vested interests for commercial gain.”

Link: http://www.infowars.com/glyphosate-weedkiller-in-our-food-and-water/

Glyphosate, pathways to modern diseases II: Celiac sprue and gluten intolerance. From Interdisiplinary Toxicology , 2013 Dec;6(4):159-84. doi: 10.2478/intox- 2013-0026

Excerpts:

“Deficiencies in iron, cobalt, molybdenum, copper and other rare metals associated with celiac disease can be attributed to glyphosate's strong ability to chelate these elements. Deficiencies in tryptophan, tyrosine, methionine and selenomethionine associated with celiac disease match glyphosate's known depletion of these amino acids. Celiac disease patients have an increased risk to non-Hodgkin's lymphoma, which has also been implicated in glyphosate exposure. Reproductive issues associated with celiac disease, such as infertility, miscarriages, and birth defects, can also be explained by glyphosate. Glyphosate residues in wheat and other crops are likely increasing recently due to the growing practice of crop desiccation just prior to the harvest. We argue that the practice of "ripening" sugar cane with glyphosate may explain the recent surge in kidney failure among agricultural workers in Central America. We conclude with a plea to governments to reconsider policies regarding the safety of glyphosate residues in foods.”

Link: http://www.ncbi.nlm.nih.gov/pubmed/24678255

I invite you to search the WEB using “glyphosate” and “miscarriage.” You will get several hundred thousand hits.

Here is the SERA Report’s denial of the fact that glyphosate exposure causes miscarriages:

The 2011 SERA glyphosate safety report at page 57 states:

“One study analyzed self-reported spontaneous miscarriages of 3984 pregnancies among 1898 couples who self-reported exposures to glyphosate formulations within a period beginning 2 months before pregnancy and ending

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the 29 month of conception (Savitz et al., 1997). Risk of miscarriage was unrelated to self-reported exposure to glyphosate formulations.” ***************************************** #3 Cancer

Roundup and Glyphosate Toxicity Have Been Grossly Underestimated Published by Mercola.com

Excerpt:

“The true toxicity of glyphosate—the active ingredient in Monsanto’s broad-spectrum herbicide Roundup—is becoming increasingly clear as study after study is published demonstrating its devastating effects. In June, groundbreaking research was published detailing a newfound mechanism of harm for Roundup.

This was immediately followed by tests showing that people in 18 countries across Europe have glyphosate in their bodies,1 while yet another study revealed that the chemical has estrogenic properties and drives breast cancer proliferation in the parts-per-trillion range.2

This finding might help explain why rats fed Monsanto’s maize developed massive breast tumors in the first-ever lifetime feeding study published last year. Other recently published studies demonstrate glyphosate’s toxicity to cell lines, aquatic life, food animals, and humans.”

Link: http://articles.mercola.com/sites/articles/archive/2013/07/30/glyphosate- toxicity.aspx#!

RoundUp--Lymphoma Connection From a June 22, 1999 Press Release by Sadhbh O' Neill, author of Genetic Concern.

Excerpts:

“A recent study by eminent oncologists Dr. Lennart Hardell and Dr. Mikael Eriksson of Sweden [1], has revealed clear links between one of the world's biggest selling herbicide, glyphosate, to non-Hodgkin's lymphoma, a form of cancer [2].

In the study published in the 15 March 1999 Journal of American Cancer Society, the researchers also maintain that exposure to glyphosate 'yielded increased risks for NHL.' They stress that with the rapidly increasing use of glyphosate since the time the study was carried out, 'glyphosate deserves further epidemiologic studies.' “

Link: http://www.naturescountrystore.com/roundup/page8.html

"RoundUp Ready" nears end of the line... From GroundTruth, July 7, 2014 20

Excerpts:

“With these dramatic increases in use, the frequency and level of human exposures to these herbicides have also gone up. As usage of glyphosate increases — for instance, as a wheat "dessicant" used at harvest-time to ensure that all of the crop is conveniently dry enough to harvest — glyphosate will continue to show up in everyday food items such as bread, and also in our surface water.”

“Striking increases in the incidence of non-Hodgkin lymphoma cancer have occurred over the past 30 years. A 2014 systematic review and meta-analysis of epidemology studies broke down the relationship between non-Hodgkin lymphoma and occupational exposure to agricultural pesticides by group and by active ingredient.

Among the findings — a handful of those studies identified a positive association between glyphosate and B cell lymphoma (a type of non-Hodgkin lymphoma).”

Link: http://www.panna.org/blog/roundup-ready-nears-end-line

Study: Glyphosate Doubles Risk of Lymphoma From AgMag BLOG, May 23, 2014

Excerpt:

“Scientists at the International Agency for Research on Cancer have found what appears to be a strong link between pesticide exposure and a blood cancer called non-Hodgkin lymphoma.

Analyzing 44 individual research projects published since 1980, the scientists, writing in the International Journal of Environmental Research and Public Health, said that people exposed to the weed killer glyphosate, marked by Monsanto under the brand name Roundup, had double the risk of developing non-Hodgkin’s lymphoma.”

Link: http://www.ewg.org/agmag/2014/05/study-glyphosate-doubles-risk-lymphoma

Cytotoxic and DNA-damaging properties of glyphosate and Roundup in human- derived buccal epithelial cells. From Arch Toxicol. 2012 May;86(5):805-13. doi: 10.1007/s00204-012-0804-8. Epub 2012 Feb 14.

Excerpt:

“Glyphosate (G) is the largest selling herbicide worldwide; the most common formulations (Roundup, R) contain polyoxyethyleneamine as main surfactant. Recent findings indicate that G exposure may cause DNA damage and cancer in humans. Aim of this investigation was to study the cytotoxic and genotoxic properties of G and R (UltraMax) in a buccal epithelial cell line (TR146), as workers are exposed via inhalation to the herbicide. R induced acute cytotoxic effects at concentrations > 40 mg/l after 20 min, which were due to membrane damage and impairment of mitochondrial functions. With 21

G, increased release of extracellular lactate dehydrogenase indicative for membrane damage was observed at doses > 80 mg/l. Both G and R induced DNA migration in single-cell gel electrophoresis assays at doses > 20 mg/l.”

Link: http://www.ncbi.nlm.nih.gov/pubmed/22331240

Roundup is tied to infertility and cancer; herbicide’s maker calls it safe Published in the Washington Post, April 29, 2013 By Carey Gillam

Excerpts:

“Roundup, may be linked to a range of health problems and diseases, including Parkinson’s, infertility and cancers, according to a new study.”

“Jerry Steiner, Monsanto’s executive vice president of sustainability, reiterated that when questioned about the new study. “We are very confident in the long track record that glyphosate has. It has been very, very extensively studied,” he said.

Link: https://www.washingtonpost.com/national/health-science/roundup-is-tied-to-infertility-and- cancer-herbicides-maker-calls-it-safe/2013/04/29/ac86ced6-ae71-11e2-98ef- d1072ed3cc27_story.html

I invite you to search the WEB using “glyphosate” and “cancer.” You will get several hundred thousand hits.

Here is the SERA Report’s denial of the fact that glyphosate exposure causes cancer:

The SERA report at page 61 cites 23-year old U.S. EPA/OPP literature that concludes there is “evidence of non-carcinogenicity for humans.” The SERA report then goes on to say thus, “no quantitative risk assessment for cancer is conducted.” ***************************************** #4 DNA Damage

Glyphosate Toxic to Mouth Cells & Damages DNA, Roundup Much Worse From an Institute of Science Publication, March 3, 2012

Excerpts:

“New research finds that glyphosate causes cell and DNA damage to epithelial cells derived from the inside of the mouth and throat [1]. It raises concerns over the safety of inhaling glyphosate, one of the most common ways in which people are exposed to the herbicide.

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Siegfried Knasmueller and his colleagues the Medical University of Vienna, Austria, found that Monsanto’s formulated version of glyphosate called Roundup Ultra Max caused cellular damage and DNA damage including chromosomal abnormalities and ultimately killed the cells at higher concentrations. Importantly, DNA damage occurred at concentrations below those required to induce cell damage, suggesting that the DNA damage was caused directly by glyphosate instead of being an indirect result of cell toxicity.”

Link: http://www.i-sis.org.uk/Glyphosate_Toxic_to_Mouth_Cells.php

Evaluation of DNA damage in an Ecuadorian population exposed to glyphosate from Genetics and Molecular Biology, 30, 2, 456-460 (2007)

Excerpts:

“We analyzed the consequences of aerial spraying with glyphosate added to a surfactant solution in the northern part of Ecuador. A total of 24 exposed and 21 unexposed control individuals were investigated using the comet assay. The results showed a higher degree of DNA damage in the exposed group (comet length = 35.5 μm) compared to the control group (comet length = 25.94 μm). These results suggest that in the formulation used during aerial spraying glyphosate had a genotoxic effect on the exposed individuals.”

Link: http://www.scielo.br/pdf/gmb/v30n2/a26v30n2.pdf

Monsanto’s Roundup is Causing DNA Damage from Natural Society, March 30, 2012

Excerpts:

“There is a reason that masks are worn while applying herbicides and warning signs are erected upon recently sprayed land plots — herbicide exposure is known to cause serious health complications. New research has recently been released showing that glyphosate, the main active ingredient found in Monsanto’s Roundup Ultra Max, is causing both DNA and cellular damage to cells found in the mouth and throat. Seeing as the inhalation of herbicides and ingredients like glyphosate is very common, this research alone is enough to raise concern over the safety of such substances which are used on a major scale.”

Link: http://naturalsociety.com/monsantos-roundup-is-causing-dna-damage/

Roundup: The "Safe" Garden Product that Can Destroy Your DNA from Mercola.com, March 13, 2012

Excerpts:

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“Instead, new research is showing that glyphosate, the active ingredient in Monsanto's Roundup herbicide, is contaminating everything from food and air to groundwater and even human beings.”

“Other independent scientific research has also found that glyphosate has the potential to cause grave health damage, including a 2009 study that tested formulations of Roundup that were highly diluted (up to 100,000 times or more) on human cells, and even then the cells died within 24 hours!”

“This can wreak havoc with your health as 80 percent of your immune system resides in your gut (GALT – Gut Associated Lymph Tissue) and is dependent on a healthy ratio of good and bad bacteria! Separate research has also uncovered the following effects from glyphosate: DNA damage, Neurotoxicity, Cancer, Endocrine disruption, Developmental toxicity and Reproductive toxicity.”

Link: http://articles.mercola.com/sites/articles/archive/2012/03/13/active-ingredient- glyphosate-in-roundup-herbicides-found-in-peoples-urine.aspx

Carcinogenic Glyphosate Linked to DNA Damage as Residues are found in Bread from Beyond Pesticides, July 22, 2015

Excerpts:

“The new report, Glyphosate: Unsafe on Any Plate, found high levels of glyphosate contamination in popular American food brands, such as Cheerios, Doritos, Oreos, Goldfish and Ritz Crackers, and Stacy’s Pita Chips. According to the report, the levels that found in these products are above the levels associated with organ damage (above 0.1 parts per billion(ppb)). Among 29 different foods tested, the highest levels detected were found in General Mills’ Original Cheerios, at 1,125.3 ppb. Stacy’s Simply Naked Pita Chips were the next highest, at 812.53 ppb. The testing and analysis was performed by Anresco Laboratories, which is an FDA registered laboratory.”

“Given its widespread use on residential and agricultural sites, its toxicity is of increasing concern. Roundup formulations can induce a dose-dependent formation of DNA adducts (altered forms of DNA linked to chemical exposure, playing a key role in chemical carcinogenesis) in the kidneys and liver of mice. Human cell endocrine disruption on the androgen receptor, inhibition of transcriptional activities on estrogen receptors on HepG2, DNA damage and cytotoxic effects occurring at concentrations well below “acceptable” residues have all been observed.”

Link: http://beyondpesticides.org/dailynewsblog/2015/07/carcinogenic-glyphosate-linked- to-dna-damage-as-residues-are-found-in-bread/

I invite you to search the WEB using “glyphosate” and “DNA” and “damage.” You will get several hundred thousand hits.

Here is the SERA Report’s denial of the fact that glyphosate exposure causes DNA damage:

The SERA report at page 64 states: 24

More serious limitations in the Paz-y-Mino et al. (2007) study involve the failure to demonstrate either temporal or spatial associations between exposure and effect. Paz-y- Mino et al. (2007) simply tested two groups of individuals after a spray and noted a difference. If the individuals at both sites had been tested before and after spraying, a temporal association could have been detected. Similarly, Paz-y-Mino et al. (2007) note that the exposed group consisted of individuals who lived at the spray site as well as individuals who lived as many as 3 miles away from the spray site. If Paz-y-Mino et al. (2007) had assessed responses based on proximity to the spray and noted some positive correlation in the responses, confidence in their assertion that the glyphosate spray caused the observed effect would be enhanced. In the absence of these types of analyses, the assertion that the differences (i.e., chromosomal damage) between the two populations are due to glyphosate exposure is weak. ***************************************** #5 Cell Death

The Hidden Dangers of Roundup From Natural News, February 05, 2009

Excerpts:

“The researchers also reported that G acted very quickly at concentrations 500 to 1000 times lower than present agricultural levels to induce programmed cell death. G alone was found to induce mitochondrial toxicity without cell membrane damage. Furthermore, the researchers tested very weak concentrations (.005%) of Roundup and reported cell death, lack of adhesion, shrinking and fragmentation in the cells undergoing apoptosis. The embryonic cells were the most sensitive indicating another major reason to eat only organic foods while pregnant.”

Link: http://www.naturalnews.com/025534_Roundup_research_toxic.html

Endocrine disruption and cytotoxicity of glyphosate and roundup in human JAr cells in vitro from Integr Pharm Toxicol Gentocicol, 2015 doi: 10.15761/IPTG.1000104

Excerpts:

“Endocrine disruption effects were secondary to cytotoxicity. Roundup was more cytotoxic than the same concentration of glyphosate alone, indicating that the other constituents of the herbicide are not inert. There is a compelling need to conduct in vivo studies to characterise the toxicity of glyphosate in a Roundup formulation, to facilitate re- evaluation of existing public health guidelines.”

Link: http://www.gmoevidence.com/wp-content/uploads/2015/03/IPTG-1-104.pdf

Roundup Weed Killer Dangers 25

from Garden Guides.com, January 2013

Excerpts:

“Monsanto's Roundup weed killer was originally marketed as being "biodegradable" and "environmentally friendly." However, in response to complaints from the New York Attorney General's office, the company agreed to stop using those terms in marketing and advertising. Roundup herbicide uses the active ingredient glyphosate, sometimes called "G." Glyphosate has been implicated in a number of potential dangers.”

“Excessive exposure to the active ingredient of Roundup, glyphosate, can cause a range of symptoms. Some of the 23 symptoms of glyphosate poisoning include reduced urination, cough, diarrhea, drowsiness, difficulty swallowing and breathing, nausea and vomiting, sore throat, blood in vomit or urine, stomach inflammation, and reduced blood pressure. Continued exposure can result in destruction of red blood cells, respiratory failure, and permanent kidney damage. Poisoning by Roundup requires a visit to a doctor or other professional chemical decontamination specialist. If you suspect acute glyphosate poisoning, contact your local poison control center or emergency room.”

Link: http://www.gardenguides.com/127538-roundup-weed-killer-dangers.html

Monsanto's Roundup is Causing DNA and Cellular Damage from Health and Wellness, March 30, 2012

Excerpts:

“There is a reason that masks are worn while applying herbicides, and warning signs are erected upon recently sprayed land plots; herbicide exposure is known to cause serious health complications.

New research has recently been released showing that glyphosate, the main active ingredient found in Monsanto's Roundup Ultra Max, is causing both DNA and cellular damage to cells found in the mouth and throat.”

Link: http://www.sott.net/article/243580-Monsantos-Roundup-is-Causing-DNA-and- Cellular-Damage

I invite you to search the WEB using “glyphosate” and “cell damage.” You will get several hundred thousand hits.

Here is the SERA Report’s denial of the fact that glyphosate exposure causes sell death:

The SERA report at page 62 states:

“Rank et al. (1993) also note that these exposure levels are near to those that cause cell death. The study does not provide information regarding the volume of the test solution in each plate. Assuming that Rank et al. (1993) used standard methods, the volume of the test solution in this type of assay is approximately 2-3 mL (U.S. EPA/OPPTS 1998a). Based on the upper range of 3 mL (0.003 L), the estimated concentrations in the test 26

solutions are about 120- 240 mg/L [0.360 mg to 0.72 mg/plate ÷ 0.003 L/plate]. These concentrations would be plausible in the gastrointestinal tract following acute oral exposure to a nontoxic dose of glyphosate (Table 10) but are from about 140 to 280-fold greater than peak plausible concentrations in plasma (≈0.86 mg/L).” ***************************************** #6 Autism

MIT Researcher: Glyphosate Herbicide will Cause Half of All Children to Have Autism by 2025 Posted on December 23, 2014 at: Alliance for Natural Health

Excerpt:

“At a [recent] conference, in a special panel discussion about GMOs, she took the audience by surprise when she declared, “At today’s rate, by 2025, one in two children will be autistic.” She noted that the side effects of autism closely mimic those of glyphosate toxicity, and presented data showing a remarkably consistent correlation between the use of Roundup on crops (and the creation of Roundup-ready GMO crop seeds) with rising rates of autism. Children with autism have biomarkers indicative of excessive glyphosate, including zinc and iron deficiency, low serum sulfate, seizures, and mitochondrial disorder.”

Here are other links explaining how research shows the mother’s exposure to glyphosate likely causes her to have autistic babies.

Links: http://healthimpactnews.com/2014/mit-researcher-glyphosate-herbicide-will-cause- half-of-all-children-to-have-autism-by-2025/

http://circleofdocs.com/community/topic/4106-mit-researcher-glyphosate-herbicide-will- cause-half-of-all-children-to-have-autism-by-2025/

http://circleofdocs.com/community/topic/4106-mit-researcher-glyphosate-herbicide-will- cause-half-of-all-children-to-have-autism-by-2025/

http://www.livingforlonger.com/mit-researcher-glyphosate-herbicide-will-cause-half-of-all- children-to-have-autism-by-2025/

http://sensoryswim.com/autism-roundup

http://www.infowars.com/half-of-all-children-will-be-autistic-by-2025-warns-senior- research-scientist-at-mit/

http://robinwestenra.blogspot.com/2015/02/warning-half-of-all-children-will-be.html

http://www.medicaldaily.com/autism-rates-increase-2025-glyphosate-herbicide-may-be- responsible-future-half-316388

http://www.vibrationsofhealth.com/gmos-will-cause-half-of-all-children-to-be-autistic-by- 2025/2/

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There is not enough room to quote excerpts from them all. Here are the rest for those who are interested in the autism-glyphosate links. http://www.healthnutnews.com/mit-researcher-glyphosate-herbicide-will-cause-half-children-autism-2025/ http://www.getholistichealth.com/41171/mit-researcher-glyphosate-herbicide-will-cause-half-of-all- children-to-have-autism-by-2025/ http://beforeitsnews.com/alternative/2015/03/mit-researcher-glyphosate-herbicide-will-cause-half-of-all- children-to-have-autism-by-2025-3130842.html http://gmoinside.org/mit-researcher-glyphosate-herbicide-will-cause-half-of-all-children-to-have-austim-by- 2025-health-impact-news/ http://www.uncensorednewsnetwork.com/current-events/mit-researcher-glyphosate-herbicide-will-cause- half-of-all-children-to-have-autism-by-2025 http://help.howproblemsolution.com/1131497/mit-researcher-herbicides-will-cause-half-of-all-children-to- have-autism-by-2025 http://agentorangezone.blogspot.com/2015/05/mit-researcher-glyphosate-herbicide.html http://www.globalresearch.ca/monsantos-roundup-glyphosate-overuse-scientist-warns-half-of-all-children- will-be-autistic-by-2025/5423676 http://www.theepochtimes.com/n3/1179553-glyphosate-causing-autism-mit-researcher-claims-herbicide- will-cause-half-of-all-children-to-be-autistic/ http://www.naturalnews.com/048099_autism_glyphosate_Monsanto.html https://www.organicconsumers.org/news/warning-half-all-children-will-have-autism-2025 http://www.momsacrossamerica.com/the_autism_and_glyphosate_roundup_link_a_mom_s_argument http://tapnewswire.com/2014/12/half-of-all-children-will-be-autistic-by-2025-monsantos-glyphosate/ http://www.lawnsite.com/showthread.php?t=434553 http://www.thetruthseeker.co.uk/?p=109006 http://journal-neo.org/2015/01/26/mit-states-that-half-of-all-children-may-be-autistic-by-2025/ http://www.americasfreedomfighters.com/2014/12/28/half-of-all-children-will-be-autistic-by-2025-warns- senior-research-scientist-at-mit/ http://the-trumpet-online.com/half-children-will-autistic-2025-warns-senior-research-scientist-mit/ https://www.youtube.com/watch?v=O9KWalwD_Nk http://edgytruth.com/2015/02/25/half-of-all-children-could-be-autistic-by-2025-due-to-monsanto/ http://www.investigatorsreport.com/health-news/autism/item/2583-half-of-all-children-will-be-autistic-by- 2025,-warns-senior-research-scientist-at-mit.html http://ehsmanager.blogspot.com/2015/01/glyphosate-causing-autism-mit.html http://theunhivedmind.com/wordpress3/half-of-all-children-will-be-autistic-by-2025-warns-senior-research- scientist-at-mit/ http://investmentwatchblog.com/half-of-all-children-will-be-autistic-by-2025-warns-senior-research- scientist-at-mit-number-of-adverse-reactions-from-vaccines-can-be-correlated-with-autism/ http://truthfrequencyradio.com/half-of-all-children-will-be-autistic-by-2025-warns-senior-research-scientist- at-mit/ http://www.naturallifeenergy.com/senior-research-scientist-mit-warns-children-autistic-2025/ https://zedie.wordpress.com/2014/12/28/half-of-all-children-will-be-autistic-by-2025-warns-senior- research-scientist-at-mit-the-alliance-for-natural-health-usa/ https://usahitman.com/mshcmba/ http://www.liveleak.com/view?i=d36_1422305199 http://soundofheart.org/galacticfreepress/content/mit-states-half-all-children-may-be-autistic-2025-due- monsanto http://www.thelibertybeacon.com/2014/12/26/half-of-all-children-will-be-autistic-by-2025-warns-senior- research-scientist-at-mit/ http://www.blacklistednews.com/Half_of_All_Children_Will_Be_Autistic_by_2025,_Warns_Senior_Resear ch_Scientist_at_MIT/40301/0/38/38/Y/M.html http://medicsindex.ning.com/forum/topics/medical-news-half-of-all-children-could-be-autistic-by-2025-due 28

I invite you to search the WEB using “glyphosate” and “autism.” You will get several hundred thousand hits.

Here is the SERA Report’s denial of the fact that pregnant women are exposed to glyphosate they have autistic children at a statistically significant higher rate than normal:

Incredibly, the SERA report does not contain the word “autism.” ***************************************** #7 Neurological disorders such as: learning disabilities, attention deficit hyperactive disorder (ADHD), autism, dementia, Alzheimer's, schizophrenia and bipolar disorder. Those most susceptible are children and the elderly.”

GMO's & Neurological Disease: ADHD, Autism, Alzheimer's, Schizophrenia, Bipolar From Health and Wellness, October 8, 2013

Excerpt:

“The endocrine disrupting properties of glyphosate can lead to neurological disorders (learning disabilities (LD), attention deficit hyperactive disorder (ADHD), autism, dementia, Alzheimer's, schizophrenia and bipolar disorder). Those most susceptible are children and the elderly.”

Link: http://www.sott.net/article/267227-GMOs-Neurological-Disease-ADHD-Autism- Alzheimers-Schizophrenia-Bipolar

Roundup herbicide linked to Parkinson’s-related brain damage from Health, April 21, 2012

Excerpt:

“This month a new and alarming study has been published in the journal Neurotoxicology and Teratology which supports the emerging connection between glyphosate, Roundup's active ingredient, and the emergence of neurodegenerative conditions including Parkinson's disease and Parkinsonian disorders.

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The new study, entitled "Glyphosate induced cell death through apoptotic and authophagic mechanisms," was arranged to investigate potential brain-damaging effects of herbicides which authors of the study stated "have been recognized as the main environmental factor associated with neurodegenerative disorders, such as Parkinson’s disease."

Link: http://www.digitaljournal.com/article/323391

Neurotoxins? from the Detox Project sponsored by the World Health Organization, 2015

Excerpt:

“Some studies suggest that both glyphosate and Roundup are possibly neurotoxins (toxic to the nervous system). Neurological diseases in humans include Parkinson’s disease, Alzheimer’s disease, and some forms of depression. Neurodevelopmental toxicity to the growing foetus or to babies can result in autism and attention deficit hyperactivity disorder (ADHD).”

Link: http://detoxproject.org/glyphosate/neurological-disease/

I invite you to search the WEB using “glyphosate” and “neurological disorders.” You will get several hundred thousand hits.

Here is the SERA Report’s denial of the fact that glyphosate exposure causes neurological disorders:

The 2011 SERA glyphosate safety report states:

“In the Reregistration Eligibility Decision (RED) document for glyphosate (U.S. EPA/OPP1993a), the U.S. EPA notes that standard toxicity studies of glyphosate do not suggest that this pesticide is neurotoxic and that specific toxicity tests for neurotoxicity are not necessary:

The acute and 90-day neurotoxicity screening battery in the rat (guidelines 81-8-SS, 82- 7) is not being required since there was no evidence of neurotoxicity seen in any of the existing studies at very high doses and this chemical lacks a leaving group; therefore, it would not seem likely to inhibit esterases (the presumptive neurotoxic mechanism of concern for all organophosphates). U.S. EPA/OPP 1993a, p. 18” (page 41 on the SERA report)

“Thus, effects reported in Schiffman et al. (1995) cannot be classified clearly as a glyphosate-induced neurological effect.” (page 43)

“As noted above, extreme and sometimes fatal over-exposures to glyphosate are not generally associated with neurologic effects.” (page 45) ***************************************** 30

#8 Irreparable kidney and liver damage

Unique Gene Expression Study Shows Roundup Causes Massive Kidney and Liver Damage at Low Doses From Sustainable Pulse, Aug 26, 2015 at:

Excerpts:

“A new ground-breaking peer-reviewed study has been published in Environmental Health Journal that shows the levels of glyphosate-based herbicides which the general public are commonly exposed to in drinking water, altered the gene function of over 4000 genes in the livers and kidneys of rats.”

“Dr. Antoniou stated; “The findings of our study are very worrying as they confirm that a very low level of consumption of Roundup weedkiller over the long term can result in liver and kidney damage. Our results also suggest that regulators should re-consider the safety evaluation of glyphosate-based herbicides.” “

Link: http://sustainablepulse.com/2015/08/26/unique-roundup-study-shows-massive- kidney-and-liver-gene-function-alterations/#.Vd8p0Zbn_IX

More evidence of Roundup's link to kidney, liver damage From Environmental Health News, September 1, 2015

Excerpts:

“Long-term exposure to tiny amounts of Roundup—thousands of times lower than what is permitted in U.S. drinking water—may lead to serious problems in the liver and kidneys, according to a new study.

The study looked at the function of genes in these organs and bolsters a controversial 2012 study that found rats exposed to small amounts of the herbicide Roundup in their drinking water had liver and kidney damage.

It is the first to examine the impacts of chronic, low exposure of Roundup on genes in livers and kidneys and suggests another potential health impact for people and animals from the widely used weed killer.”

Link: http://www.environmentalhealthnews.org/ehs/news/2015/aug/monsanto-roundup- glyphosate-pesticide-kidney-liver-toxic-gmo

MONSANTO'S HERBICIDE LINKED TO FATAL KIDNEY DISEASE EPIDEMIC: COULD IT TOPPLE THE COMPANY? from Truthout, July 10, 2014

Excerpts: 31

“For years, scientists have been trying to unravel the mystery of a chronic kidney disease epidemic that has hit Central America, India and Sri Lanka. The disease occurs in poor peasant farmers who do hard physical work in hot climes. In each instance, the farmers have been exposed to herbicides and to heavy metals. The disease is known as CKDu, for Chronic Kidney Disease of unknown etiology. The "u" differentiates this illness from other chronic kidney diseases where the cause is known. Very few Western medical practitioners are even aware of CKDu, despite the terrible toll it has taken on poor farmers from El Salvador to South Asia.”

“Dr. Catharina Wesseling, the regional director for the Program on Work and Health (SALTRA) in Central America, which pioneered the initial studies of the region's unsolved outbreak, put it this way, "Nephrologists and public health professionals from wealthy countries are mostly either unfamiliar with the problem or skeptical whether it even exists." “

“We know that political changes in Sri Lanka in the late 1970s led to the introduction of agrochemicals, especially in rice farming. The researchers looked for likely suspects. Everything pointed to glyphosate. This herbicide is used in abundance in Sri Lanka. Earlier studies had shown that once glyphosate binds with metals, the glyphosate-metal complex can last for decades in the soil.”

Link: http://www.truth-out.org/news/item/24876-monsantos-herbicide-linked-to-fatal- kidney-disease-epidemic-will-ckdu-topple-monsanto

Other sites also discuss glyphosate and kidney failures: http://www.truth-out.org/news/item/32585-more-evidence-of-roundup-s-link-to-kidney-liver- damage http://www.democraticunderground.com/10027132287 http://www.chemwatch.net/185836/more-evidence-of-roundups-link-to-kidney-liver-damage http://gmwatch.org/news/latest-news/16377-more-evidence-of-roundup-s-link-to-kidney-liver- damage http://www.infowars.com/evidence-mounts-on-roundups-link-to-liver-and-kidney-damage/ http://www.sej.org/headlines/more-evidence-roundups-link-kidney-liver-damage http://www.globalhealingcenter.com/natural-health/evidence-mounts-on-roundups-link-to-liver- and-kidney-damage/ http://wakeup-world.com/2015/10/15/evidence-mounts-on-roundups-link-to-liver-and-kidney- damage/ https://protestationdotorg.wordpress.com/2015/09/01/more-evidence-of-roundups-link-to-kidney- liver-damage/ https://authenticallymale.wordpress.com/2015/09/02/more-evidence-of-roundups-link-to-kidney- liver-damage/ https://clinicpress.com/blog/more-evidence-of-roundups-link-to-kidney-liver-damage- environmental-health-news/ http://cureliver.info/liver/more-evidence-of-roundups-link-to-kidney-liver-damage-environmental- health-news http://www.thesleuthjournal.com/evidence-mounts-on-roundups-link-to-liver-and-kidney-damage/ http://todayeco.com/pages/59185402-more-evidence-of-roundups-link-to-kidney-liver-damage http://article.wn.com/view/2015/08/28/More_evidence_of_Roundups_link_to_kidney_liver_damag e/ https://www.pinterest.com/pin/206602701633503702/

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http://gmwatch.eu/news/latest-news/16377-more-evidence-of-roundup-s-link-to-kidney-liver- damage http://www.grbnews.net/more-evidence-of-roundups-link-to-kidney-liver-damage-scientists-report- worrisome-changes-to-liver-and-kidney-genes-in-rats-adding-to-evidence-that-a-popular- herbicide-may-be-toxic.html http://www.collective-evolution.com/2014/07/15/new-study-links-gmos-to-cancer-liverkidney- damage-severe-hormonal-disruption/ http://have-anticipated.beforeitsnews.com/christian-news/2015/08/roundup-link-to-kidney-liver- disease-dupont-shit-hit-the-fan-latvia-greece-win-opt-out-from-monsanto-gm-crop-2516448.html

I invite you to search the WEB using “glyphosate” and “liver damage.” You will get several hundred thousand hits.

Here is the SERA Report’s denial of the fact that glyphosate exposure causes kidney and liver damage:

The 2011 SERA glyphosate safety report states:

“Signs of kidney toxicity, which might be expected based on observations from human suicide attempts (Appendix 2, Table 6), have not been reported consistently and are not severe (e.g., MRIDs 00130406 and 00150564; NTP 1992).” (pages 38 and 39)

As discussed by U.S. EPA/OPP (1993b), the multi-generation study in rats by Reyna (1985) failed to note any adverse kidney effects at a dose of 500 mg/kg bw/day, which is about 17 times greater than the presumed LOAEL of 30 mg/kg bw/day in study by Schroeder and Hogan (1981).

Consequently, U.S. EPA/OPP (1993b) concurred with the assessment by Schroeder and Hogan (1981) and considers the finding of kidney tubule dilation a spurious effect.” (page 104)

By the end of the 65-day exposure period, there was no apparent inhibition of liver esterase (Li and Kole 2004, Table II).” (page 142) ***************************************** #9 Parkinson's-Related Brain Damage

Monsanto’s Roundup, Glyphosate Linked to Parkinson’s and Similar Diseases From Natural Society, October 30, 2012

Excerpt:

“We already know the links between herbicides and sterility in men, birth defects, mental illness, obesity and possibly cancer—but now we have something new to add to the nasty effects of pesticides list — Parkinson’s disease and similar neurodegenerative conditions.

33

New research, published in the journal Neurotoxicology and Teratology, indicates a connection between a component in Monsanto’s Roundup and Parkinson’s disease. Glyphosate is said to induce cell death, with frightening repercussions.”

Link: http://naturalsociety.com/monsantos-roundup-glyphosate-parkinsons- neurodegenerative/

Roundup, An Herbicide, Could Be Linked To Parkinson’s, Cancer And Other Health Issues, Study Shows From Huffington Post, January 25, 2013

Excerpt:

“Those residues enhance the damaging effects of other food-borne chemical residues and toxins in the environment to disrupt normal body functions and induce disease, according to the report, authored by Stephanie Seneff, a research scientist at the Massachusetts Institute of Technology, and Anthony Samsel, a retired science consultant from Arthur D. Little, Inc. Samsel is a former private environmental government contractor as well as a member of the Union of Concerned Scientists.

“Negative impact on the body is insidious and manifests slowly over time as inflammation damages cellular systems throughout the body,” the study says.

We “have hit upon something very important that needs to be taken seriously and further investigated,” “Seneff said.

Link: http://www.huffingtonpost.com/2013/04/25/roundup-herbicide-health-issues- disease_n_3156575.html

Pesticides and herbicides like glyphosate now strongly linked to Parkinson's disease and other neurological disorders From Natural News, March 8, 2016

Excerpt:

“(NaturalNews) The genes of the human race have never been under such intense pressure from their surrounding environment. Pesticide and herbicide chemicals that confuse, distort and destroy the natural chemistry of life and microbiology, are being sprayed directly on the foods that people eat. The ill effects are being measured all the way down to the genetic level. In the presence of pesticides and herbicides like glyphosate, healthy genes that were meant to be expressed are being turned off, and genes that were intended to lie dormant are being turned on. The human race is experiencing a shift like never before, and the epigenetic changes are occurring silently, without human understanding.”

Link: http://www.naturalnews.com/053226_herbicides_gene_expression_Parkinsons.html

Roundup herbicide linked to Parkinson’s-related brain damage From the National Parkinson Foundation, April 21, 2012 34

Excerpts:

“Monsanto's controversial herbicide, Roundup, has now been linked to Parkinsonism related disorders according to research reported in the Neurotoxicology & Teratology journal.

This month a new and alarming study has been published in the journal Neurotoxicology and Teratology which supports the emerging connection between glyphosate, Roundup's active ingredient, and the emergence of neurodegenerative conditions including Parkinson's disease and Parkinsonian disorders. The new study, entitled "Glyphosate induced cell death through apoptotic and authophagic mechanisms," was arranged to investigate potential brain-damaging effects of herbicides which authors of the study stated "have been recognized as the main environmental factor associated with neurodegenerative disorders, such as Parkinson’s disease." With the current wide use of Roundup herbicide in the U.S.A., it is considered to be a contaminant in air, groundwater, rain and food, making it virtually impossible to avoid. Researchers in the new study found that glyphosate inhibited the viability of differentiated test cells (PC12, adrenal medula derived), in both dose-and-time dependent manners. They also discovered "glyphosate induced cell death via authophagy pathways in addition to activating apoptotic pathways." “

Link: http://forum.parkinson.org/index.php?/topic/12649-roundup-herbicide-linked-to- parkinson%e2%80%99s-related-brain-damage/

Monsanto's Roundup Weedkiller Linked to Alzheimer's, Parkinson's and ALS From Alternet, July 19, 2016

Excerpt:

“According to the most recent review, Glyphosate pathways to modern disease V: Amino acid analogue of glycine in diverse proteins, conducted by independent scientists Anthony Samsel, Ph.D. and Stephanie Seneff, Ph.D., a scientist at Massachusetts Institute of Technology (MIT), glyphosate acts as a glycine analogue that incorporates into peptides during protein synthesis. In this process, it alters a number of proteins that depend on conserved glycine for proper function. According to the authors, glyphosate substitution for glycine correlates with several diseases, including diabetes, obesity, asthma, Alzheimer’s disease, amyotrophic lateral sclerosis (ALS), and Parkinson’s disease, among others.”

Link: http://www.alternet.org/food/monsantos-roundup-weedkiller-changes-dna-function- causing-chronic-disease

Monsanto's Roundup, Glyphosate Linked to Parkinson's and Similar Diseases From Reader Supported News, October 13, 2012

Excerpt:

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“We already know the links between herbicides and sterility in men, birth defects, mental illness, obesity and possibly cancer - but now we have something new to add to the nasty effects of pesticides list - Parkinson's disease and similar neurodegenerative conditions.

New research, published in the journal Neurotoxicology and Teratology, indicates a connection between a component in Monsanto's Roundup and Parkinson's disease. Glyphosate is said to induce cell death, with frightening repercussions.”

Link: http://readersupportednews.org/news-section2/312-16/14279-monsantos-roundup- glyphosate-linked-to-parkinsons-and-similar-diseases

I invite you to search the WEB using “glyphosate” and “Parkinsons.” You will get several hundred thousand hits.

Here is the SERA Report’s denial of the fact that glyphosate exposure causes Parkinson’s-related brain damage:

The 2011 SERA glyphosate safety report states:

“At this point, there is no evidence to conclude that glyphosate can produce or exacerbate Parkinsonism; indeed, the Barbosa et al. (2001) observation stands in contrast to the abundant case literature which suggests that glyphosate is not a neurotoxicant in humans. The possible connection between the onset of Parkinsonism and the exposure to glyphosate cannot be established from the single case reported by Barbosa et al. (2001), as the apparent concurrence of the two effects could be coincidental. A coincidental association is suggested by the fact no other cases of glyphosate-related Parkinsonism have been reported in the literature in the nearly 10- year period since the Barbosa et al. (2001) publication. Thus, as with the report by Ptok (2009) on speech disorder, the report by Barbosa et al. (2001) is essentially anecdotal and does not demonstrate a causal relationship between glyphosate and the development of Parkinsonism.” (pg 45)

This would be enough to discredit and invalidate the 2011 SERA “Glyphosate -Human Health and Ecological Risk Assessment Final Report” in the minds of reasonably intelligent, thinking, kind USFS people who would not kill other human beings just because the USDA says it’s OK.

You can believe one dubious glyphosate safety study (SERA), or you can be responsible and act according to hundreds of independent scientists’ research conclusions. The SERA safety report is the only source among hundreds of other safety research conclusions available that shows glyphosate exposure is safe. ------36

Section 3

Children are especially susceptible to glyphosate poisoning

Here is information that won’t please you.

Concerns Over Glyphosate Use Published in The Sun (Malaysia), Friday August 20, 1999

Excerpt:

“The establishment of the World Health Organization’s (WHO's) Acceptable Daily Intake (ADI) is based on limited studies using limited parameters which do not account for vulnerable groups such as children, the elderly, the sick and other groups that might have increased susceptibility to glyphosate exposure.”

Link: http://www.poptel.org.uk/panap/archives/glywb.htm

Photo images of glyphosate and children Link: http://www.bing.com/images/search?q=glyphosate+children&qpvt=glyphosate+children&qpvt=gl yphosate+children&FORM=IGRE

Are Your Children Roundup-Ready? Published by the Cornucopia Institute, October 1, 2015

Excerpt:

“Feeding herbicide-tolerant GE corn and soy to children gives them a dose of glyphosate with every bite. Glyphosate is often portrayed by the manufacturers as safe for human exposure while being deadly to weeds. However, scientific research indicates that the herbicide is not as harmless as it has been portrayed. Rather, evidence shows that glyphosate may be the most important factor in the development of multiple chronic diseases and conditions now prevalent in Westernized societies.”

Link: http://www.cornucopia.org/2015/10/are-your-children-roundup-ready/

Alleged Glyphosate Poisoning Kills 2 Children, 33 More in Hospital Published by Natural Society, August 2, 2014

Excerpt:

37

“Two children (ages 3-yrs, and 6 mos.) from the same family suddenly died last week, one en route to the hospital, another just after being released due to a poisoning outbreak of glyphosate in the Huber Duré settlement. Their bodies have been sent to the capital of Paraguay, Asunción, for detailed autopsies which could confirm that glyphosate was the cause of death.”

The reported poisoning outbreak in Huber Duré is not the first case. Over the past few years, there have been many reports of poisoning, increased abortions, and the death of farm animals in the areas where heavy pesticide spraying is conducted. Following these cases, local residents protested, but authorities took no action to address their concerns.”

Link: http://naturalsociety.com/alleged-glyphosate-poisoning-kills-2-children-33-hospital/

Glyphosate toxicity – impacts on the environment and non-target species Published by the Pemaculture College Australia

Excerpt:

“Studies on human cells showed toxicity and hormone disruption at sub agricultural levels with effects within 24 hours caused by concentrations as low as 0.5 parts per million. And DNA damage at 5 parts per million. The impact of glyphosate-based herbicides residues in food, feed or in the environment now has thus to be considered real. PMID: 19539684

The exposure of children to glyphosate should be avoided as recent animal studies have shown that commercial formulation of glyphosate is a potent endocrine (hormone) disruptor, causing disturbances in reproductive development when the exposure was during the puberty period (5)”

Link: http://permaculture.com.au/glyphosate-toxicity-impacts-on-the-environment-and-non-target- species/ ------Section 4

Herbicides that contain glyphosate are banned in Denmark, England, Italy, El Salvador, Sri Lanka, France, Holland, Austria, Bulgaria, Germany, Greece, Hungary, Ireland, Japan, Chile, South Africa, Luxembourg, Madeira, Cameroon, New Zealand, Peru, South Australia, Russia, France, Switzerland, Columbia, and Costa Rica.

38

If Monsanto didn’t control the regulatory agencies in America we would be among the countries listed above.

Please open the link below to learn about more countries that protect their citizens and America doesn’t. http://www.bing.com/search?q=Roundup+Banned+in+What+Countries&first=1&FORM= PERE

Who would believe Cameroon, Sri Lanka and Russia would protect their citizens when America ignores the tragic effects of glyphosate.

Monsanto Has Been Removed And Banned By: Austria, Bulgaria, Germany, Greece, Hungary, Ireland, Japan, Luxembourg, Madeira, New Zealand, Peru, South Australia, Russia, France, and Switzerland! Published by Political Vel Craft, March 23, 2013

Excerpts:

“Now we know without a doubt that smoking and lung and throat cancer are kissing cousins. Because GMOs have been around for 15 years or so, with no long-term studies other than Monsanto’s being done, we only have Monsanto’s word that GMOs are safe.”

“We know that when Obama campaigned in 2008, he promised he would label GMOs. When elected, not only did he renege on that promise but immediately appointed former Monsanto VP and attorney Michael Taylor, aka “Monsanto Mike”, as the Head of Food Safety at the Fraud and Drug Administration and Tom Vilsack, another biotech hooker, as the Secretary of Agriculture.”

Link: https://politicalvelcraft.org/2013/03/23/monsanto-has-been-removed-and-banned-by-austria- bulgaria-germany-greece-hungary-ireland-japan-luxembourg-madeira-new-zealand-peru-south- australia-russia-france-and-switzerland/

El Salvador bans glyphosate Published by Natural News, October 22, 2013

Excerpts:

“While the U.S. Environmental Protection Agency (EPA) was busy doubling (and in some cases quadrupling) the amount of allowable glyphosate residue on certain foods, the nation of El Salvador actually heeded the grim data surrounding the herbicide's disastrous effect on our environment and everything in it and decided to outright ban the chemical.”

“A wealth of independent (read: not funded by Monsanto or Big Agra interests) research been published over the last year to further affirm the havoc wreaked by the now ubiquitous chemical, most notably, award-winning scientist Gilles-Eric Seralini's genetically modified corn toxicity study published in the journal Food and Chemical Toxicity last fall. Seralini and his team found that feeding rats Monsanto's glyphosate-resistant GMO corn resulted in massive bodily system 39

failures, including chronic hormone and reproductive disruption, severe liver and kidney damage and the formation of large tumors which may have been, according to the study, a result of endocrine disruption linked to Roundup.

Other recent research continued to confirm the link between glyphosate and Colony Collapse Disorder, the mass wipeout of America's honeybee population. This is especially troubling, considering the fact that bees are responsible for pollinating every third bite of food on our forks in this country.”

Link: http://www.naturalnews.com/042608_El_Salvador_glyphosate_ban_Monsanto.html#

Sri Lanka bans leading Monsanto herbicide citing deadly disease fears Published by The International Consortium of Investigative Journalists, March 14, 2014

Excerpts:

“An investigation carried out by medical specialists and scientists has revealed that kidney disease was mainly caused by glyphosate,” Special Projects Minister S.M Chandrasena told reporters in Sri Lanka. “President Mahinda Rajapaksa has ordered the immediate removal of glyphosate from the local market soon after he was told of the contents of the report.” “

Link: https://www.icij.org/blog/2014/03/sri-lanka-bans-leading-monsanto-herbicide-citing-deadly- disease-fears

France Bans the World’s Leading Herbicide From Garden Stores Published by Takepart, June 15, 2015

Excerpts:

“On Sunday, Ségolène Royal, the environment and energy minister, announced a plan to ban Roundup from all garden=store shelves in the country.

“The reason? The world’s most popular weed killer contains glyphosate—a chemical the World Health Organization in March determined to be “probably carcinogenic to humans.” “

“ “France must be on the offensive with regards to the banning of pesticides,” Royal said Sunday on French 3TV.”

Link: http://www.takepart.com/article/2015/06/15/france-bans-herbicide

On the Offensive' Against Monsanto, France Removes Roundup from Store Shelves Published by Common Dreams, June 15, 2015

Excerpts:

40

“It's the newest development in the growing international movement against Monsanto in general and Roundup in particular. French Ecology Minister Segolene Royal announced on Sunday that she had instructed garden centers to stop putting the herbicide on the shelves of their self-service aisles, stating, "France must be on the offensive with regards to the banning of pesticides." “

Colombian officials made similar statements in May, when they put a halt to U.S.-backed toxic fumigation of coca fields in the country, noting that a previous ruling by the Colombian Supreme Court called for an end to the aerial spraying program if health concerns over glyphosate were discovered.”

Link: http://www.commondreams.org/news/2015/06/15/offensive-against-monsanto-france- removes-roundup-store-shelves

Dutch Ban Roundup, France and Brazil to Follow Published by The Healthy Home Economist,

Excerpts:

“The dominoes are starting to fall.

The evidence damning glyphosate, the active ingredient in Roundup, the world’s number one herbicide for weed control, has become too enormous to ignore.

While it won’t kill you immediately as demonstrated by foolish Monsanto reps who have been known to drink Roundup in product demonstrations to convince unwitting farmers to use it, the long term effects to health are nothing short of devastating.”

Link: http://www.thehealthyhomeeconomist.com/roundup-banned-netherlands-france-brazil-likely- soon-follow/

5 Countries That are Throwing Monsanto Out on its Ass Published by Ultraculture

Excerpt:

“The world may have had enough of Monsanto, if the events of this month are anything to go by. We’ve just seen no less than five countries—South Africa, France, Chile, Brazil and Sri Lanka— either outright banning the sale of toxic weedkillers or GMO strains produced by the country, or demanding the company hold to truth in advertising standards.”

Link: http://ultraculture.org/blog/2014/04/01/5-countries-throwing-monsanto-ass/

The Netherlands Says “No” to Monsanto, Bans RoundUp Herbicide Published by Inhabitat, September 29, 2014

Excerpt:

41

“The Netherlands is the latest country—after Russia, and Mexico—to say no to Monsanto. The Dutch Parliament recently decided that the sale of glyphosate-based herbicides to private parties will be prohibited as of late 2015. This means that people who spray RoundUp on their gardens and lawns will have to find another form of pest control: glyphosate is the main ingredient in RoundUp, and it has been directly linked to all manner of severe health issues, from bird defects and nervous system damage to kidney failure and various forms of cancer.”

Link: http://inhabitat.com/the-netherlands-says-no-to-monsanto-bans-roundup-herbicide/

3 More European Countries Begin Banning Glyphosate and Monsanto’s Roundup Published by ANTI MEDIA, June 24, 2015

Excerpt:

“The chemical giant Monsanto has been garnering lots of necessary backlash for their glyphosate products lately. There’s worldwide concern because Monsanto’s glyphosate-containing herbicides are known to cause cancer in animals and have been labeled likely carcinogenic to humans. Monsanto representatives are feeling the pressure — and even asked the World Health Organization to retract their study which hinted at glyphosate being a human carcinogen.”

Link: http://theantimedia.org/more-european-countries-banning-glyphosate-monsantos-roundup/

GLyphosate (Round UP) is Banned in DENMARK and will be banned in Brazil and France Published by Lanka Newspapers,

Excerpts:

“Monsanto`s Secret Formula : Dangerous Chemicals in Glyphosate Herbicide Slip Past EU Regulators Due to Data Confidentiality

The only Europeans to ban glyphosate (the main active ingredient in Monsanto`s herbicide roundUp) and its dangerous additions (surfactants) thus far are the Dutch, with Brazil and France to follow. Yet Germany, keeping their evidence of these toxic chemicals secret, pressures EU regulators to allow these unhealthy compounds to be sprayed liberally over the continent.”

“A major qualitative difference between the effect of glyphosate and glyphosate formulations on aquatic and terrestrial organisms concerns the surfactant used in Roundup. The surfactant is much more toxic than glyphosate to aquatic organisms. Unlike glyphosate, the surfactant is more toxic in alkaline water than in acidic water. Thus, the relative potency of the surfactant with respect to glyphosate is pH dependent. There is relatively little information regarding the toxicity of Roundup Pro to aquatic species. Nonetheless, the acute lethal potencies of Roundup and Roundup Pro are similar.”

Link: http://www.lankanewspapers.com/news/2014/9/89870_space.html

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------Section 5

California classifies glyphosate as a “”

California Classifies Glyphosate As Cancer-Causing, FDA Tests Crops For Residue Published by CBS SF Bay Area, July 7, 2017

Excerpts:

“SAN FRANCISCO (CBS SF) — California added a controversial chemical found in the world’s most popular weedkiller to the list of chemicals known to the state to cause cancer, and the FDA is now testing U.S. crops for residues from that same chemical.

Glyphosate, a key ingredient in hundreds of products including Monsanto’s best-selling herbicide Roundup, was added to the state’s Prop 65 list on Friday. The list was created by The Safe Drinking Water and Toxic Enforcement Act of 1986 and includes hundreds of chemicals known to the state to cause cancer or reproductive toxicity.”

Link: http://sanfrancisco.cbslocal.com/2017/07/07/california-glyphosate-monsanto-cancer- causing-fda-crops/

Glyphosate causes cancer, rules California -- All California retailers are required to add cancer warning labels to all products containing glyphosate from July 7, 2017 Published by Pgurus, July 15, 2017

Excerpts:

“In a major setback to the multinational seed and chemical company, Monsanto, the US State of California declared glyphosate, the main ingredient in its weed killer Roundup, as a toxic cancer- causing chemical, effective July 7, 2017. This decision by the California Office of Environmental Health Hazard Assessment (OEHHA) is a triumph of environmentalists, farmers who have long fought losing battles with the giant corporations, consumer rights activists and health activists.

Declaring glyphosate as a known, cancer-causing carcinogen, the California Office of Environmental Health Hazard Assessment said it would be added to the state’s warning list under 43

the “The Safe Drinking Water and Toxic Enforcement Act of 1986,” also known as Proposition 65. This law protects California drinking water from toxic, cancer-causing substances and those known to cause birth defects.”

Link: https://www.pgurus.com/glyphosate-causes-cancer-california/

Monsanto Is Suing California for Trying to Inform People That Roundup Causes Cancer Published by Alternet, March 2, 2016

Excerpts:

“Once again, Monsanto is trying to take away our right to know, this time about carcinogenic chemicals used in household products and places all around us. In January, Monsanto filed a lawsuit against the state of California for its intent to list glyphosate, the main chemical used in Monsanto’s flagship Roundup herbicide, under California's Proposition 65, a law that mandates notification and labeling of all chemicals known to cause cancer, birth defects or other reproductive harm, and prohibits their discharge into drinking waters of the state.

Enacted by California voters via ballot initiative in 1986, Prop 65 prohibits any business from knowingly or intentionally exposing any individual to a chemical known to the state to cause cancer or reproductive toxicity without first giving a clear and reasonable warning, and the discharge of such chemical into a source of drinking water is prohibited. The State relies on the findings of the International Agency for Research on Cancer (IARC) of the World Health Organization (WHO) — the world’s leading authority on cancer — as the basis for listing chemicals that are known or probable carcinogens under Prop 65. In 2015, IARC concluded, by a unanimous decision, that glyphosate is “probably carcinogenic.” “

Link: http://www.alternet.org/environment/monsanto-suing-california-trying-inform-people- roundup-causes-cancer ------Indeed, this is not a trivial issue.

With the knowledge contained in the last 46 pages, most people wouldn’t think of applying herbicides that contain glyphosate (Roundup etc.) because they would not be at peace with themselves knowing they may have planted the cancer seed in a forest visitor … maybe a child.

Ask yourself how a Federal District Court judge would rule when the plaintiff introduces the information above and the USFS’s OGC attorney tries to refute it with information from the SERA report.

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Opposing Views Attachment #1

This document contains quotes authored by Ph.D. scientists who are world-class experts in forest ecology. Their statements describe how logging activities harm recreation opportunities and many natural resources in the forest ------Timber Harvest Opposing View #1 - The following document contains pertinent color pictures showing logging damage, thus the article text is not shown here. Please use the link below to access the article.

Al-jabber, Jabber M. “Habitat Fragmentation:: Effects and Implications” Clearcuts and forest fragmentation, Willamette NF, Oregon. From: Cascadia Wildland Project, Spring 2003 http://faculty.ksu.edu.sa/a/Documents/Habitat%20Fragmentation%20Effects%20and%20Implication.pdf ------Timber Harvest Opposing View #2 - “Timber harvest operations have been shown to have many effects on adjacent watercourses and on the aquatic ecosystems they support. This may occur from introductions or loss of woody debris, loss of riparian vegetation, accelerated stream bank and bed erosion, the alteration of natural channel form and process, and the reduction of stream habitat diversity. However, the existing literature indicates one of the most insidious effects of logging is the elevation of sediment loads and increased sedimentation within the drainage basin.

Sediment generation from various forestry practices has been studied extensively in the past. Forestry practices which generate suspended sediments include all operations 1

that disturb soil surfaces such as site preparations, clear-cutting, log skidding, yarding, slash burns, heavy equipment operation and road construction and maintenance.”

Anderson, P.G. 1996. “Sediment generation from forestry operations and associated effects on aquatic ecosystems” Proceedings of the Forest-Fish Conference: Land Management Practices Affecting Aquatic Ecosystems, May 1-4, 1996, Calgary, Alberta. http://www.alliance-pipeline.com/contentfiles/45____Sediment_generation.pdf ------Timber Harvest Opposing View #3 - “Timber harvest will remove dead and dying material from the site and inhibit the recruitment of downed woody material as time progresses. Timber harvest and associated reduced structural complexity and reduced age and size class diversity are all known to reduce population abundance and diversity of ants and a number of birds. For instance, ants are documented to require downed woody material in a variety of sizes and in all stages of decomposition (Torgersen and Bull, 1995). This is an attribute that is negatively correlated with harvest of the dead and dying trees and positively correlated with natural succession, especially after disturbance. Ants and birds are known to predate on insect species which cause mortality to trees, serving as a potentially important population control in the case of epidemics or before they occur (Campbell, Torgersen and Srivastava, 1983). Structural and functional characteristics associated with unlogged forests are also important for canopy arthropods, which play an important role in regulating pest outbreaks (Schowalter, 1989).

Structural complexity, functional diversity, diversity of ecological process and diversity of structure in roadless areas are all expected to be less susceptible to the outbreak of pests and regulate insect activity in surrounding homogenized forests (Schowalter and Means, 1989; Franklin, Perry, Schowalter, Harmon, McKee and Spies, 1989).

A large body of scientific evidence also indicates that increased edge effect and increased sunlight into stands, resulting from reduced canopy cover associated with timber harvest, can directly promote the population abundance, productivity and persistence of insects which cause mortality to trees of (Roland, 1993; Rothman and Roland, 1998; Kouki, McCullough and Marshall, 1997; Bellinger, Ravlin and McManus, 1989).”

“Applying Ecological Principles to Management of the U.S. National Forests” Issues in Ecology Number 6 Spring 2000 http://www.esa.org/science_resources/issues/FileEnglish/issue6.pdf

2

------Timber Harvest Opposing View #4 - “The biggest ecological con job in years is being waged by the U.S. Republican party and their timber industry cronies. They are blaming the recent Western wildfires on environmentalists, and assuring the public that commercial logging will reduce the risk of catastrophic wildfires.”

Barry, Glen, Ph.D. “Commercial Logging Caused Wildfires” Published by the Portland Independent Media Center, August 2002. http://portland.indymedia.org/en/2002/08/17464.shtml ------Timber Harvest Opposing View #5 - “According to a 1998 poll by a firm that has worked for several Republican House members and two presidents, 69 percent of Americans oppose commercial logging on federally owned land. The Forests Service's own poll showed that 59 percent of Americans who expressed an opinion oppose timber sales and other commodity production in national forests.”

“Many Americans are surprised to learn that logging is even allowed on public lands. Alas, it has been since the Organic Act of 1897 first authorized logging in America's new forest reserves. That legislation called for watershed protection and a steady supply of timber - what the Forest Service calls ‘multiple use.’ "

“But the agency has been unable to balance those goals. More often than not, the integrity of the forest ecosystem has been sacrificed to maximize timber and other commodities. And at taxpayer expense, notes Bernie Zaleha, chair of the End Commercial Logging on Federal Lands (ECL) campaign. The Forest Service lost $2 billion on its logging program from 1992 to 1997, according to the General Accounting Office. It spends more on building roads and preparing sales than it gets back in timber receipts.”

Barry, John Byrne. “Stop the Logging, Start the Restoration” from The Planet newsletter 3

June 1999, Volume 6, Number 5 http://vault.sierraclub.org/planet/199905/ecl1.asp ------Timber Harvest Opposing View #6 - “Federal auditors have found that the Forest Service frequently fails to assess, prevent or correct environmental damage from logging on the national forests.

After inspecting 12 timber projects in the field from 1995 to 1998, the Agriculture Department's inspector general found that all were deficient and that ’immediate corrective action is needed.’

A new report on the audits found that the environmental studies required before logging was approved were poorly done, the rules to protect streams and wildlife habitat from undue damage during logging were not followed, and the steps planned to repair some of the harm after logging were not carried out.

The inspector general, Roger C. Viadero, reported on Jan. 15 to Mike Dombeck, chief of the Forest Service, that the review had found '’numerous serious deficiencies.'’ Agency officials generally agreed with the report's conclusions and recommendations.”

Cushman, John H. Jr. “Audit Faults Forest Service on Logging Damage in U.S. Forests” New York Times, February 5, 1999 http://query.nytimes.com/gst/fullpage.html?res=9B00E2DF163BF936A35751C0A96F958260&sec=&spon =&pagewanted=print http://www.ncpa.org/sub/dpd/index.php?Article_ID=12468 ------Timber Harvest Opposing View #7 – “Logging on national forest land creates more economic harm than good, according to a recent study by the National Forest Protection Alliance and the Forest Conservation Council.

4

The 75-page report, three years in the making, notes there are dramatic economic and social losses when forests are logged under the U.S. Forest Service's timber-sale program.

The report, "The Economic Case Against Logging National Forests," states that national forest lands are far more valuable to rural communities when trees are left standing, and that the federal logging program creates billions of dollars in unaccounted costs for communities, businesses, and individuals. This expense comes in addition to timber industry subsidies, which cost American taxpayers approximately $1.2 billion a year.”

“Talberth said both reports lend support to current efforts in Congress to end the federal timber-sale program. Introduced by Rep. Cynthia McKinney (D-Georgia) in April 1999, the National Forest Protection and Restoration Act (H.R. 1396) would put an end the federal timber-sale program.”

Higgins, Margot, “National forest logging is bad business, study says” Posted on CNN.com-Nature, March 16, 2000 http://www.colorado.edu/AmStudies/lewis/west/costlogging.pdf ------Timber Harvest Opposing View #8 - “I recently read a letter from a line officer who chided local managers for being behind schedule relative to meeting the region’s ‘timber targets.’ My expectation is that line officers will demand similar accountability for meeting watershed restoration, fish and wildlife habitat, riparian, recreation, cultural resource, and wilderness management goals.”

“We need to do a better job talking about, and managing for, the values that are so important to so many people. Values such as wilderness and roadless areas, clean water, protection of rare species, old growth forests, naturalness -- these are the reasons most Americans cherish their public lands.”

"Fifty years ago, Aldo Leopold wrote his seminal work, A Sand County Almanac. In it, Leopold spoke of his personal land ethic and the need for land managers to extend their own ecological conscience to resource decisions. The Forest Service natural resource agenda is an expression of our agency's land ethic. If we are to redeem our role as conservation leaders, it is not enough to be loyal to the Forest Service organization. First and foremost, we must be loyal to our land ethic. In fifty years, we will not be remembered for the resources we developed; we will be thanked for those we maintained and restored for future generations." 5

Dombeck, Mike Ph.D. a message on "Conservation Leadership” sent to all USFS employees on July 1, 1998 http://www.wvhighlands.org/VoicePast/VoiceAug98/Dombeck.Aug98.html ------Timber Harvest Opposing View #9 - “For much of the past century the Forest Service, entrusted as the institutional steward of our National Forests, focused its management on an industrial-scale logging program. The result of the massive logging and road construction program was to damage watersheds, destroy wildlife habitat and imperil plant and animal species.”

“The continued logging of our National Forests also wastes American tax dollars and diminishes the possibilities of future economic benefits. The Forest Service lost $2 billion dollars on the commercial logging program between 1992-1997. Annually, timber produces roughly $4 billion while recreation, fish and wildlife, clean water, and unroaded areas provide a combined total of $224 billion to the American economy. Forests purify our drinking water - 60 million Americans get their drinking water from National Forests. When the dramatic values of ecological goods and services are taken into account, it is clear that protecting National Forests creates more economic benefits than continued logging.”

Ehrlich, Anne Ph.D., David Foster Ph.D. and Peter Raven Ph.D. 2002 “Scientists Seek Logging Ban on U.S.-Owned Land” New York Times, April 15, 2002 http://www.nativeforest.org/campaigns/public_lands/stb_5_30_02.htm ------Timber Harvest Opposing View #10 - “The Bush administration has announced plans to greatly increase logging on federal lands in order to reduce the risk of wildfires. The Forest Service is using the fear of wildfires to allow logging companies to remove medium-and large-diameter trees that they can sell, rather than just the small trees and brush that can make fires more severe. There is little evidence to show that such logging will prevent catastrophic fires; on the contrary, logging roads and industrial logging cause wildfires. Bush is a well known supporter of the timber industry and has accepted huge sums of money from wealthy timber company leaders. He is promoting 6

misinformation about forest fires in order to benefit timber industry campaign contributors.”

“Bush Fire Policy: Clearing Forests So They Do Not Burn” FOREST CONSERVATION NEWS TODAY, August 27, 2002 http://forests.org/archived_site/today/recent/2002/tiporefl.htm ------Timber Harvest Opposing View #11 - "The proposition that forest values are protected with more, rather than less logging, and that forest reserves are not only unnecessary, but undesirable, has great appeal to many with a vested interest in maximizing timber harvest. These ideas are particularly attractive to institutions and individuals whose incomes depend upon a forest land base. (page 2)"

"On the other hand, approaches that involve reserving of a portion of the land base, or harvest practices that leave commercially valuable trees uncut to achieve ecological goals, are often considered much less desirable as they reduce traditional sources of timber income. (page 2)"

Franklin, Jerry Ph.D., David Perry Ph.D., Reed Noss Ph.D., David Montgomery Ph.D. and Christopher Frissell Ph.D. 2000. "Simplified Forest Management to Achieve Watershed and Forest Health: A Critique." http://www.coastrange.org/documents/forestreport.pdf ------Timber Harvest Opposing View #12 - “Consequently, we specifically criticize the “simplified structure-based management” approaches derived from simple structural models and traditional silvicultural systems such as clearcutting. In our view, the assumptions underpinning simplified structure-based management (SSBM) are not supported by the published scientific literature on structural development of natural forests, disturbance ecology, landscape ecology and conservation biology, or by the relationships between ecosystem structures and processes. In this report, we review scientific findings associated with each of these areas with particular attention to the over-simplified structural models associated with SSBM and the importance and viability of forest reserves to achieve various ecological goals. (page 2)

7

“We do not believe, however, that scientific literature or forestry experience supports the notions that intensively managed forests can duplicate the role of natural forests, or that sufficient knowledge and ability exist to create even an approximation of a natural old-growth forest stand.” (page 3)

Franklin, Jerry F. Ph.D. and James K. Agee Ph.D. 2007. “Forging a Science-Based National Forest Fire Policy.” Issues in Science and Technology. A National Wildlife Federation publication sponsored by the Bullitt Foundation http://www.coastrange.org/documents/forestreport.pdf ------Timber Harvest Opposing View #13 - “But the majority of the protesters were angry about Bush’s plans to implement rules that would thin our national forests to reduce fire risk. Cascadia Forest Alliance volunteer Carrie Taylor said Bush’s plan to log mature and old forests “will only increase fire risks while providing taxpayer subsidized logs to the timber industry.”

“According to the Cascadia Forest Alliance, under the Bush proposal, ‘environmental laws and citizen involvement will be undermined or suspended so that federal land management agencies can increase logging and roadbuilding on public lands, one of the timber industry's highest priorities.’”

Giuliano, Jackie Alan, Ph.D. “Fire Suppression Bush Style: Cut Down the Trees!” Environmental News Service, 2008. www.ens-newswire.com/ens/aug2002/2002-08-23g.asp ------Timber Harvest Opposing View #14 - "Most of the trees that need to be removed to reduce accumulated fuels are small in diameter and have little or no commercial value."

"Mechanically removing fuels (through commercial timber harvesting and other means) can also have adverse effects on wildlife habitat and water quality in many areas. Officials told GAO that, because of these effects, a large-scale expansion of commercial timber harvesting alone for removing materials would not be feasible. However, because the Forest Service relies on the timber program for funding many of its 8

activities, including reducing fuels, it has often used this program to address the wildfire problem. The difficulty with such an approach, however, is that the lands with commercially valuable timber are often not those with the greatest wildfire hazards."

Government Accounting Office “Western National Forests: A Cohesive Strategy is Needed to Address Catastrophic Wildfire Threats” GAO/RCED-99-65 http://www.gao.gov/archive/1999/rc99065.pdf ------Timber Harvest Opposing View #15 - “The recent concern over the poor health of western pine ecosystems has been attributed at least partly to inappropriate silvicultural practices, both before and since the national forests were established. (4) Because of the timber industry's needs, logging in mixed conifer stands has emphasized cutting the large pines and leaving the true firs and Douglas-fir to dominate the remaining stands. (5) However, true firs and Douglas-fir are more susceptible to the damage (including insect and disease attacks as well as direct damage) that has occurred during the decade-long drought in the interior West, and thus may contribute to the risk of catastrophic wildfires. Salvage sales are one tool that can be used to improve forest health, (6) but critics object to granting the agency the discretion to use timber sales to correct problems partially created by past timber sales.”

“A more general concern in some quarters is over Forest Service "bias" toward timber outputs, at the expense of ecosystem conditions and other resource values. While timber harvests are important, other important values are not measured, and managers are not rewarded for achieving these other values. (7) Some have attributed this "bias" to inappropriate incentives, particularly related to the agency's numerous trust funds and special accounts. (8) The Forest Service has several trust funds and special accounts that are either funded by timber revenues or provide funds for timber management (or both). (9)”

“One trust fund often cited by critics is the Knutson-Vandenberg (K-V) Fund. This account receives an unlimited portion of timber sale receipts, to be used for reforestation, timber stand improvements, and other resource mitigation and enhancement activities in timber sale areas. Forest Service managers can, therefore, fund their programs from timber sales; in the words of one critic, wildlife managers have an incentive to support timber sales that damage wildlife habitat, because they can use the revenues to mitigate that damage and to keep themselves and their staffs employed. (10)”

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Gorte, Ross W. Ph.D. “Forest Service Timber Sale Practices and Procedures: Analysis of Alternative Systems.” A Congressional Research Service (CRS) report, October 30, 1995. http://www.ncseonline.org/NLE/CRS/abstract.cfm?NLEid=215 ------Timber Harvest Opposing View #16 - “In April 1999, the General Accounting Office issued a report that raised serious questions about the use of timber sales as a tool of fire management. It noted that "most of the trees that need to be removed to reduce accumulated fuels are small in diameter" -- the very trees that have ‘little or no commercial value.’ “

“As it offers timber for sale to loggers, the Forest Service tends to ‘focus on areas with high-value commercial timber rather than on areas with high fire hazards,’ the report said. Its sales include ‘more large, commercially valuable trees’ than are necessary to reduce the so-called accumulated fuels (in other words, the trees that are most likely to burn in a forest fire).”

“The truth is that timber sales are causing catastrophic wildfires on national forests, not alleviating them. The Sierra Nevada Ecosystem Project Report, issued in 1996 by the federal government, found that ‘timber harvest, through its effects on forest structure, local microclimate and fuel accumulation, has increased fire severity more than any other recent human activity.’ The reason goes back to the same conflict that the G.A.O. found: loggers want the big trees, not the little ones that act as fuel in forest fires.”

“After a ‘thinning’ timber sale, a forest has far fewer of the large trees, which are naturally fire-resistant because of their thick bark; indeed, many of these trees are centuries old and have already survived many fires. Without them, there is less shade. The forest is drier and hotter, making the remaining, smaller trees more susceptible to burning. After logging, forests also have accumulations of flammable debris known as "slash piles" -- unsalable branches and limbs left by logging crews.”

Hanson, Chad Ph.D., “Commercial Logging Doesn't Prevent Catastrophic Fires, It Causes Them.” Published in the New York Times, May 19, 2000 http://yeoldeconsciousnessshoppe.com/art6.html ------10

Timber Harvest Opposing View #17 - "But all of these benefits are harmed by one activity—commercial logging on national forests through the Forest Service’s timber sale program, in which private timber companies pay the Forest Service to be allowed to cut down trees on public land.”

“In other words, the timber sales program functions as a particularly destructive form of government subsidy to private logging companies. This subsidy is so large that if the government ended the Forest Service timber sales program, a portion of the money saved could be used employ every timber worker that is currently involved in cutting down national forests to instead work on ecological restoration, repairing the damage that has been done to our forests, and there would still be millions of dollars remaining in taxpayers savings.”

Hanson, Chad, Ph.D. “National Forest Protection” Environment Now (see picture on last page) http://www.environmentnow.org/forest.html ------Timber Harvest Opposing View #18 - “Recent editorials by timber industry spokespersons are a wildly misleading attempt to promote increased logging of western U.S. forests under the guise of reducing wildland fires …”

Hanson, Chad Ph.D., “Logging Industry Misleads on Climate and Forest Fires.” Guest Commentary in New West, July 11, 2008 http://www.newwest.net/topic/article/logging_industry_misleads_on_climate_and_forest_fires/C41/L41/ ------Timber Harvest Opposing View #19 - "Logging reduces the organic parent material (duff and woody residues) available for soil-formation processes."

Harvey, A. E., M. J. Larsen, and M. F. Jurgensen “Distribution of Ectomycorrhizae in a Mature Douglas-fir/larch Forest Soil in Western Montana” Forest Science, Volume 22, Number 4, 1 December 1976 , pp. 393-398(6) http://www.ingentaconnect.com/content/saf/fs/1976/00000022/00000004/art00007;jsessionid=l2sdf2hphia 2.alexandra

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------Timber Harvest Opposing View #20 - "For too long, we foresters took the public for granted, assuming unwavering support for those who grow the nation’s wood fiber. Few noticed when the public’s mood changed, and those who did were often ridiculed by disbelieving colleagues. Now we come to a day of reckoning: the public believes forests are too important to be entrusted to foresters. To restore lost confidence, foresters must first come out of hiding. We have a lot of explaining to do because, where forests are concerned, the public will no longer support what it cannot see and understand. Regaining the public’s trust will take time. We must be prepared to answer hard questions about what we are doing and how our actions are impacting the environment. We must also help the public think through its forest management options. When we lay out these options, we must speak of much more than trees. Only then will our critics know we love forests as much as they do."

Houston, Alan Ph.D., "Why Forestry is in Trouble with the Public." Evergreen magazine, October 1997. http://evergreenmagazine.com/web/Why_forestry_is_in_trouble_with_the_public-v2.html ------Timber Harvest Opposing View #21 - "SEC. 3. FINDINGS.

Congress finds the following:

Commercial logging has many indirect costs which are very significant, but not easily measured, such as flooding damage and relief of flooding damage through Federal funds, damage to the salmon fishing industry; and harm to the recreation and tourism industries."

H. R. 1494 text. April 4, 2001 http://www.gpo.gov/fdsys/pkg/BILLS-107hr1494ih/content-detail.html

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------Timber Harvest Opposing View #22 - "Human tampering with nature has not been without costs. Human manipulation of existing ecosystems has also sometimes had unfortunate consequences."

Hudak, Mike Ph.D. “From Prairie Dogs to Oysters: How Biodiversity Sustains Us” from his book review of The Work of Nature: How the Diversity of Life Sustains Us by Yvonne Baskin, 1997 Newsletter of Earth Day Southern Tier, February/March 1999, p. 2 http://www.mikehudak.com/Articles/FromPrairieDogs9902.html ------Timber Harvest Opposing View #23 - “In general, rate of spread and flame length were positively correlated with the proportion of area logged (hereafter, area logged) for the sample watersheds. Correlation coefficients of area logged with rate of spread were > 0.57 for five of the six river basins (table 5). Rate of spread for the Pend Oreille and Wenatchee River basins was strongly associated (r-0.89) with area logged. Correlation of area logged with flame length were > 0.42 for four of six river basins (table 5). The Deschutes and Methow River basins showed the strongest relations. All harvest techniques were associated with increasing rate of spread and flame length, but strength of the associations differed greatly among river basins and harvesting methods.” (pg.9)

“As a by-product of clearcutting, thinning, and other tree-removal activities, activity fuels create both short- and long-term fire hazards to ecosystems. The potential rate of spread and intensity of fires associated with recently cut logging residues is high, especially the first year or two as the material decays. High fire-behavior hazards associated with the residues can extend, however, for many years depending on the tree. Even though these hazards diminish, their influence on fire behavior can linger for up to 30 years in the dry forest ecosystems of eastern Washington and Oregon.”

Huff, Mark H. Ph.D.; Ottmar, Roger D.; Alvarado, Ernesto Ph.D. Vihnanek, Robert E.; Lehmkuhl, John F.; Hessburg, Paul F. Ph.D. Everett, Richard L. Ph.D. 1995. “Historical and current forest landscapes in eastern Oregon and Washington. Part II: Linking 13

vegetation characteristics to potential fire behavior and related smoke production” Gen. Tech. Rep. PNW-GTR-355. USDA Forest Service, Pacific Northwest Research Station. https://ir.library.oregonstate.edu/xmlui/bitstream/handle/1957/4706/PB96155213.pdf;jsessionid=C8DDB6 11DB29D3716BBF313AADBA2E70?sequence=1 ------Timber Harvest Opposing View #24 - "The Quincy Library Group's (QLG's) fuelbreak strategy represents a giant step backwards from the progressive development of rational fire policies established by the 1995 Federal Wildland Fire Management Policy and Program Review."

"The fact that the QLG admits that its Plan is inconsistent with these new policies (indeed, is almost gleefully defiant of them) says a lot about the credibility of the QLG's self-purported fire management expertise."

"In spite of (or more likely because of) the intensive 'fuels reduction' activities associated with commercial logging, the Fountain Fire was truly catastrophic in its effects."

"Even 'kinder, gentler' commercial logging still inflicts environmental impacts such as eroded topsoil, degraded water quality, destroyed wildlife habitat, and extirpated species that are every bit as much symptoms of forest health problems as large-scale, severe wildfires."

"And after spending millions of dollars creating the SNEP Report, it seems wise to use its information, not ignore it or opportunistically select out statements clearly worded as assumptions, values, or goals which run contrary to factual research findings. The QLG Plan has much more to do with timber extraction than with genuine fire protection, and in that respect, it constitutes more of a forest health threat than a real solution."

"The QLG Bill resembles similar 'panic legislation' that was passed during the early 1970s in which, following some large-scale wildfires in California, Congress allowed the Forest Service to access emergency firefighting funds to conduct 'presuppression' timber sales. Many fuelbreaks were cut in the Sierras during this period, and while costs rapidly rose into tens of millions of dollars, most of these fuelbreaks failed to perform adequately during wildfire suppression incidents. Congress quickly had to take away this funding source from the Forest Service. What has become of these old fuelbreaks? Almost without exception, the agency failed to monitor or maintain them, and in a modern-day version of 'cut and run' logging, many of these old fuelbreaks have converted to chaparral brush and 'dog-hair' thickets … a much more flammable vegetation type than the original forest cover. The QLG Bill appears to be 'deja vu' 14

without evidence of Congress or the QLG being aware of this history of previous fuelbreak programs."

Ingalsbee, Timothy Ph.D. "Logging for Firefighting: A Critical Analysis of the Quincy Library Group Fire Protection Plan." Unpublished research paper. 1997. http://www.fire-ecology.org/research/logging-for-firefighting_2.htm ------Timber Harvest Opposing View #25 - “The notion that commercial logging can prevent wildfires has its believers and loud proponents, but this belief does not match up with the scientific evidence or history of federal management practices. In fact, it is widely recognized that past commercial logging, road-building, livestock grazing and aggressive firefighting are the sources for "forest health" problems such as increased insect infestations, disease outbreaks, and severe wildfires.”

“How can the sources of these problems also be their solution? This internal contradiction needs more than propaganda to be resolved. It is time for the timber industry and their supporters to heed the facts, not fantasies, and develop forest management policies based on science, not politics.”

Ingalsbee, Timothy Ph.D. 2000. “Commercial Logging for Wildfire Prevention: Facts Vs Fantasies” http://www.fire-ecology.org/citizen/logging_and_wildfires.htm ------Timber Harvest Opposing View #26 - "Since the 'New Perspectives' program of the early 1990s, the agency has tried to dodge public opposition to commercial logging by using various euphemisms, such as this gem from the Siskiyou National Forest: Clearcuts are called 'minimum green tree retention units.' Accordingly, Forest Service managers have believed that if they simply refer to logging as 'thinning,' or add the phrases 'fuels reduction' or 'forest restoration' to the title of their timber sale plans, then the public will accept these projects at face value, and business-as-usual commercial logging can proceed. In the face of multiple scandals and widespread public skepticism of the Forest Service's credibility, it seems that only Congress is buying the agency's labeling scheme." 15

Ingalsbee, Timothy Ph.D. “Logging without Limits isn't a Solution to Wildfires” published in the Portland Oregonian, August 6, 2002 http://www.klamathforestalliance.org/Documents/loggingwithoutlimits.html ------Timber Harvest Opposing View #27 - “Thus, the use of commercial logging for fire hazard reduction poses yet another paradox: Logging removes the trees that normally survive fires, leaves behind the trees that are most often killed by fire, increases flammable fuel loads, and worsens fire weather conditions.” (pg. 5)

Ingalsbee, Timothy Ph.D. “The wildland fires of 2002 illuminate fundamental questions about our relationship to fire.” The Oregon Quarterly, Winter 2002 http://www.fire-ecology.org/research/wildfire_paradox.pdf ------Timber Harvest Opposing View #28 - "In the face of growing public scrutiny and criticism of the agency's logging policies and practices, the Forest Service and their enablers in Congress have learned to mask timber sales as so-called 'fuels reduction' and 'forest restoration' projects. Yet, the net effect of these logging projects is to actually increase fire risks and fuel hazards."

"Decades of encouraging private logging companies to take the biggest, oldest, most fire-resistant trees from public lands, while leaving behind a volatile fuel load of small trees, brush, weeds, stumps and slash has vastly increased the flammability of forestlands."

"In addition to post-fire salvage logging, the Forest Service and timber industry advocates in Congress have been pushing pre-fire timber sales, often falsely billed as hazardous fuels reduction or 'thinning' projects, to lower the risk or hazard of future wildfires. In too many cases, these so-called thinning projects are logging thick- diameter fire-resistant overstory trees instead of or in addition to cutting thin-sized fire- susceptible understory trees. The resulting logging slash and the increased solar and wind exposure can paradoxically increase the fuel hazards and fire risks."

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Ingalsbee, Timothy Ph.D. "Fanning the Flames! The U.S. Forest Service: A Fire-Dependent Bureaucracy." Missoula Independent. Vol. 14 No. 24, June 2003 http://www.fire-ecology.org/research/USFS_fire_dependent.html ------Timber Harvest Opposing View #29 - “More than any other recent human activity, the legacy of commercial timber extraction has made public forests more flammable and less resilient to fire. Firstly, clearcut and high-grade logging have historically taken the largest, most fire-resilient, most commercially-valuable trees, and left behind dead needles and limbs (logging debris called "slash"), along with smaller trees and brush that are less commercially valuable but more flammable than mature and old-growth trees. The net effect is to increase the amount of available hazardous fuel.”

“Secondly, the removal of large overstory trees also changes the microclimate of logged sites, making them hotter, drier, and windier, which increases the intensity and rate of spread of wildfires. Third, the creation of densely-stocked even-aged plantations of young conifers made sites even more flammable since this produced a solid mass of highly combustible conifer needles within easy reach of surface flames. These changes in the fuel load, fuel profile, and microclimate make logged sites more prone to high- intensity and high-severity wildfires.”

Ingalsbee, Timothy Ph.D. 2005. “A Reporter's Guide to Wildland Fire.” Published by the Firefighters United for Safety, Ethics, and Ecology (FUSE), January 2005 http://www.commondreams.org/news2005/0111-14.htm ------Timber Harvest Opposing View #30 - “Linear developments may result in habitat avoidance for grizzly bears. Logging-truck traffic in the Kimsquit Valley in British Columbia resulted in a 78% reduction in use of the “Zone of Hauling Activity” by radio collared bears compared to non-hauling periods (16). For 14 hours/day, 3%-23% of each bear's home range was unavailable to them because of disturbance.”

“The impacts of land-use activities on wolverines are likely similar to those on grizzly bears. Wolverines seem to have been most affected by activities that fragment and 17

supplant habitat, such as human settlement, extensive logging, oil and gas development, mining, recreational developments, and the accompanying access. Wolverine populations that are now at the edge of extirpation have been relegated to the last available habitat that has not been developed, extensively modified, or accessed by humans.”

Jalkotzy, M.G., P.I. Ross, and M.D. Nasserden. 1997. “The Effects of Linear Developments on Wildlife: A Review of Selected Scientific Literature.” Prepared for Canadian Association of Petroleum Producers. Arc Wildlife Services Ltd., Calgary. 115pp. http://www.arlis.org/docs/vol1/A/65937142.pdf ------Timber Harvest Opposing View #31 - “History, not science, refutes the claim that logging helps to prevent forest fires.

The forests of the West are far more vulnerable to fire due to a century of industrial logging and fire suppression. Logging has removed most of the older, fire-resistant trees from the forests.

Fire suppression has encouraged many smaller and more flammable trees, brush and dense plantations to fill the holes. Logging has set the forests of the West up to burn big and hot.

More logging will not fix this.”

Keene, Roy “Logging does not prevent wildfires” Guest Viewpoint, the Eugene Register Guard January 11, 2009 http://www.thefreelibrary.com/Logging+does+not+prevent+wildfires.-a0192070397 ------Timber Harvest Opposing View #32 - “Fear of wildfire is heavily used to sell these forest “restoration” schemes. Logging has not been proven, in practice, to reduce fire frequency or intensity. Historically, the largest, most destructive blazes, like the Tillamook conflagration, were caused from logging or fueled by slash. Unlogged

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forests, cool and shaded, are typically more fire resistant than cut over, dried-up stands choked with slash and weeds.

Large-scale logging (by any name) has devalued our forests, degraded our waters, damaged soils, and endangered a wide variety of plants and animals. How will the current round of politically and environmentally propelled ‘restorative’ logging proposals differ, in practice, from past logging regimes?”

Keene, Roy Restorative Logging? “More rarity than reality” Guest Viewpoint, the Eugene Register Guard March 10, 2011 http://eugeneweekly.com/2011/03/03/views3.html ------Timber Harvest Opposing View #33 - "Timber harvesting operations affect hydrologic processes by reducing canopy interception and evapotranspiration. Many studies have documented changes in soil properties following tractor yarding (Stone, 1977; Cafferata, l983), and low-ground-pressure skidding (Sidle and Drlica, 1981). More recently, researchers have evaluated cable yarding (Miller and Sirois, 1986; Purser and Cundy, 1992). In general, these studies report decreased hydraulic conductivity and increased bulk density in forest soils after harvest."

Keppeler, Elizabeth T. Robert R. Ziemer Ph.D., and Peter H. Cafferata "Effects of Human-Induced Changes on Hydrologic Systems." An American Water Resources Association publication, June 1994 http://www.fs.fed.us/psw/publications/ziemer/Ziemer94a.PDF ------Timber Harvest Opposing View #34 - "Among these four species of amphibians, the spotted salamander is most likely to be affected adversely by the logging as this species of salamander relies on dense forests with full canopies (Harding, 1997)."

"Looking at the study on a larger scale, the potential for changes caused by logging is great. Absence of trees could influence water temperature by altering available sunlight, conductivity by changing the amount of organic matter that collects in the

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vernal ponds, or pH if the logging process deposits foreign residues to the area. Also heavy equipment used to harvest the timber has the potential to alter the terrain."

"Modifications to the landscape could change how water flows and collects at the surface and change the size, shape, and location of the vernal ponds. Loss or alteration to small temporary water sources less than four hectares can be extremely detrimental to amphibians water (Semlitsch, 2000). Without vernal ponds amphibians would have difficulty inhabiting forested areas because they rely on the ponds as breeding grounds. If logging disturbs the ponds, amphibian populations could diminish in the areas that surround these vernal pools."

Klein, Al 2004. Logging Effects on Amphibian Larvae Populations in Ottawa National Forest. http://www.nd.edu/~underc/east/education/documents/AKlein2004Pre- loggingsurveyofamphibianlarvaeinvernalpools.pdf ------Timber Harvest Opposing View #35 - “The Congressional Research Service (CRS) recently addressed the effect of logging on wildfires in an August 2000 report and found that the current wave of forest fires is not related to a decline in timber harvest on Federal lands. From a quantitative perspective, the CRS study indicates a very weak relationship between acres logged and the extent and severity of forest fires. To the contrary, in the most recent period (1980 through 1999) the data indicate that fewer acres burned in areas where logging activity was limited.”

“Qualitative analysis by CRS supports the same conclusion. The CRS stated: "[T]imber harvesting removes the relatively large diameter wood that can be converted into wood products, but leaves behind the small material, especially twigs and needles. The concentration of these fine fuels on the forest floor increases the rate of spread of wildfires." Similarly, the National Research Council found that logging and clearcutting can cause rapid regeneration of shrubs and trees that can create highly flammable fuel conditions within a few years of cutting.”

Laverty, Lyle, USDA Forest Service and Tim Hartzell U.S. Department of the Interior “A Report to the President in Response to the Wildfires of 2000”, September 8, 2000. https://www.frames.gov/rcs/6000/6269.html

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------Timber Harvest Opposing View #36 - “I will turn first to forest thinning aimed at reducing fire risks. There is surprisingly little scientific information about how thinning actually affects overall fire risk in national forests.”

“How can it be that thinning could increase fire risks? First, thinning lets in sunlight and wind, both of which dry out the forest interior and increase flammability. Second, the most flammable material - brush, limbs, twigs, needles, and saplings - is difficult to remove and often left behind. Third, opening up forests promotes brushy, flammable undergrowth. Fourth, logging equipment compacts soil so that water runs off instead of filtering in to keep soils moist and trees healthy. Fifth, thinning introduces diseases and pests, wounds the trees left behind, and generally disrupts natural processes, including some that regulate forest health, all the more so if road construction is involved.”

Lawrence, Nathaniel, NRDC senior attorney “Gridlock on the National Forests” Testimony before the U.S. House of Representatives Subcommittee on Forests and Forest Health (Committee on Resources) December 4, 2001. http://www.nrdc.org/land/forests/tnl1201.asp ------Timber Harvest Opposing View #37 - “Those who would argue that this form of logging has any positive effects on an ecosystem are clearly misinformed. This type of logging has side effects related to wildfires, first and foremost being that the lumber companies aren't interested in hauling out all the smaller trees, branches, leaves, pine needles, sawdust, and other debris generated by cutting all these trees. All this debris is left on site, quickly dries out, and is far more flammable sitting dead on the ground than it was living in the trees. Smaller, non-commercially viable trees are left behind (dead) as well - creating even more highly flammable fuel on the ground.

Leitner, Brian. “Logging Companies are Responsible for the California Wildfires.” the Democratic Underground, October 30, 2003. http://www.democraticunderground.com/articles/03/10/30_logging.html

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------Timber Harvest Opposing View #38 - "We concluded that commercial timber sales do not meet the criteria for forest restoration." (Pg. 11)

Long, Richard D., U.S. Department of Agriculture Office of Inspector General "Western Region Audit Report: Forest Service National Fire Plan Implementation" Report No. 08601-26-SF, November 2001. http://www.usda.gov/oig/webdocs/08601-26-SF.pdf ------Timber Harvest Opposing View #39 - “In hopes of ending conflicts over "multiple use," an independent scientific committee has proposed that "ecological sustainability" should become the principal goal in managing the U.S. national forests and grasslands, which since 1960 have been under a congressional mandate to serve industry, recreation, and conservation all at once.”

Mann, Charles C. Ph.D. and Mark L. Plummer Ph.D. “Call for 'Sustainability' in Forests Sparks a Fire” Science 26 March 1999: Vol. 283. no. 5410, pp. 1996 – 1998 http://www.sciencemag.org/content/283/5410/1996.summary ------Timber Harvest Opposing View #40 - "Logging removes a mass that harbor a myriad of organisms, from bacteria and actinomycetes to higher fungi. The smaller organisms, not visible to the unaided eye, are still important components of the system."

Maser, C. Ph.D., and J. M. Trappe Ph.D. “The Seen and Unseen World of the Fallen Tree”, 1984 USDA Forest Service, GTR-PNW-164 http://www.fs.fed.us/pnw/publications/pnw_gtr164/ 22

------Timber Harvest Opposing View #41 - "Logging removes mature and maturing trees which conserve essential elements, whereas the area containing new very young planted trees following logging are susceptible to erosion and essential element loss." (pg.5)

"Logging removes tree parts that would have created and maintained diversity in forest communities." (pg. 44)

Maser, C. Ph.D., R. F. Tarrant, J. M. Trappe Ph.D., and J. F. Franklin Ph.D. 1988 “The Forest to the Sea: A Story of Fallen Trees” USDA Forest Service, GTR-PNW-GTR-229 http://www.fs.fed.us/pnw/publications/pnw_gtr229/ ------Timber Harvest Opposing View #42 - "In addition to the direct effects of habitat loss and fragmentation, logging typically reduces ecosystem health by:

a) damaging aquatic habitats through siltation, reduction in stream complexity and increased water temperatures.”

McIntosh, B.A., J.R. Sedell, J.E. Smith, R.C. Wissmar S.E. Clarke, G.H. Reeves, and L.A. Brown “Management history of eastside ecosystems: changes in fish habitat over 50 years, 1935-1992.” 1994 GTR-321 93-181 http://www.fs.fed.us/pnw/publications/pnw_gtr321/ ------

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Timber Harvest Opposing View #43 - “Logging practices can indirectly result in changes in the biological components of a stream, and can have direct and indirect on the physical environment in streams.

The primary environmental changes of concern are the effects of siltation, logging debris, gravel scouring, destruction of developing embryos and alevins, blockage of streamflow, decrease in surface and intragravel dissolved oxygen, increase in maximum and diel water temperatures, changes in pool/riffle ratios and cover, redistribution of fishes, reduction in fish numbers, and reduction in total biomass.”

Moring, John R. Ph.D. 1975. “The Alsea Watershed Study: Effects of Logging on the Aquatic Resources of Three Headwater Streams of the Alsea River, Oregon – Part III.” Fishery Report Number 9 Oregon Department of Fish and Wildlife. http://www.for.gov.bc.ca/hfd/library/ffip/Moring_JR1975b.pdf ------Timber Harvest Opposing View #44 - "Biodiversity in managed ecosystems is poor. Less biodiverse communities and ecosystems are more susceptible to adverse weather (such as drought) and exotic invaders, and have greatly reduced rates of biomass production and nutrient cycling."

"All of these studies show that ecosystem functioning is decreased as the number of species in a community decreases. Declines in functioning can be particularly acute when the number of species is low, such as in most managed ecosystems including croplands or timber plantations."

"Recent evidence demonstrates that both the magnitude and stability of ecosystem functioning are likely to be significantly altered by declines in local diversity, especially when diversity reaches the low levels typical of managed ecosystems."

Naeem, Shahid Ph.D., F.S. Chapin III Ph.D., Robert Costanza Ph.D., Paul R. Ehrlich Ph.D., Frank B. Golley Ph.D., David U. Hooper Ph.D. J.H. Lawton Ph.D., Robert V. O’Neill Ph.D., Harold A. Mooney Ph.D. Osvaldo E. Sala Ph.D., Amy J. Symstad Ph.D., and David Tilman Ph.D. "Biodiversity and Ecosystem Functioning: Maintaining Natural Life Support Processes." Issues in Ecology No. 4. Fall 1999. http://cfpub.epa.gov/watertrain/pdf/issue4.pdf

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------Timber Harvest Opposing View #45 - "As a result of the Forest Service's well- documented mismanagement over many years of the timber sale program, taxpayers also have been stuck with the tab for hundreds of millions of dollars worth of subsidies to a profitable timber industry."

Nappier, Sharon. Lost in the Forest: How the Forest Service's Misdirection, Mismanagement, and Mischief Squanders Your Tax Dollars. Taxpayers for Common Sense, 2002. http://www.ourforests.org/fact/lostintheforest.pdf ------Timber Harvest Opposing View #46 - "Agroforestry does reduce biodiversity. In forests used for logging, whole-landscape management is crucial. Here, emphasis is placed on areas of intensive use interspersed with areas for conservation and catchment purposes. Management strategies for sustainable forestry are being developed, but there is a need for further interaction among foresters, ecologists, community representatives, social scientists, and economists."

Noble, Ian R. and Rodolfo Dirzo Ph.D. "Forests as Human-Dominated Ecosystems." Science Vol. 277. No. 5325, pp. 522 - 525. 25 July 1997. http://www.sciencemag.org/content/277/5325/522.abstract?maxtoshow=&HITS=10&hits=10&RESULTFO RMAT=&fulltext=logging&searchid=1136659907310_5043&FIRSTINDEX=0&journalcode=sci ------Timber Harvest Opposing View #47 - "The U.S. Forest Service has been sitting on a public opinion survey it commissioned, not knowing what to do with the results. The problem is that most people surveyed want more wilderness and less logging on the Green Mountain National Forest (GMNF), while the federal agency seems to want to build more roads and cut more trees."

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"The survey conducted by Dr. Robert Manning of the School of Natural Resources at the University of Vermont, polled 1,500 Vermont households in the spring of 1995. A survey with similar results was completed last fall for the White Mountain National Forest in New Hampshire. 'It is clear that New England residents value the national forest for many reasons, but non-material values, such as aesthetics and ecological protection, are more important than material values, such as economic development,' said Dr. Manning."

"The responses to several survey questions indicate a strong public desire for more areas of wild, untouched nature on the GMNF and less roadbuilding and logging. Very few people supported clearcutting and other types of industrial logging, especially if natural beauty or wildlife habitat were harmed."

"For example:

• 82 percent wanted to ban clearcutting, • 82 percent said logging should not hurt scenic beauty, • 80 percent of the respondents wanted to protect remaining undisturbed forest; and • 72 percent urged prohibition of logging if bear or other wildlife habitat would be harmed."

"Only 36 percent felt that management of the GMNF should emphasize timber and lumber products; and only 15 percent felt that jobs are more important than protection of endangered species."

"'The results of this survey and a similar one on the White Mountain National Forest in Vermont should serve as loud wake-up calls to the U.S. Forest Service,' said Northup. 'Forest Service officials have two choices: either begin a major overhaul of the agency's management programs or ignore the wishes of the people they are supposed to serve'."

Northup, Jim. 1999. "Public Wants More Wilderness, Less Logging on Green Mountain NF". Press Release by Forest Watch, a Vermont-based environmental organization. http://www.forestwatch.org/content.php?id=10 ------Timber Harvest Opposing View #48 - “Still, forestry experts warned in the 2000 plan that logging should be used carefully and rarely; in fact, the original draft states plainly

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that the "removal of large merchantable trees from forests does not reduce fire risk and may, in fact, increase such risk."

“Now, critics charge that the Bush administration is ignoring that warning. Neil Lawrence, a policy analyst with the Natural Resource Defense Council, claims that Washington has taken a far more aggressive approach to incorporating commercial logging in its wildfire prevention plans. As a result, Lawrence and other critics say, the National Fire Plan is becoming a feeding ground for logging companies. Moreover, critics claim the administration's strategy, far from protecting the lives and homes of those most at risk, could actually increase the likelihood of wildfires.”

Okoand Ilan Kayatsky, Dan. “Fight Fire with Logging?” Mother Jones, August 1, 2002 http://motherjones.com/politics/2002/08/fight-fire-logging ------Timber Harvest Opposing View #49 - “In response to catastrophic wildfires, wide- reaching forest management policies have been enacted in recent years, most notably the Healthy Forests Restoration Act of 2003. A key premise underlying these policies is that fire suppression has resulted in denser forests than were present historically in some western forest types. Therefore, although reducing the threat of wildfire is the primary goal, forest managers commonly view fuel treatments as a means to restore historic forest structure in those forest types that are outside of their historic range of variation. This study evaluates where both wildfire mitigation and restoration of historic forest structure are potentially needed in the ponderosa pine–dominated montane forest zone of Boulder County, Colorado. Two spatial models were overlain: a model of potential fireline intensity and a model of historic fire frequency. The overlay was then aggregated by land management classes.

Contrary to current assumptions, results of this study indicate that both wildfire mitigation and restoration of historic forest structure are needed in only a small part of the study area, primarily at low elevations.

Furthermore, little of this land is located on Forest Service land where most of the current thinning projects are taking place. We question the validity of thinning as a means both to reduce the threat of wildfire and to restore historic forest structure in the absence of site-specific data collection on past and present landscape conditions.”

Platt, Rutherford V. Ph.D., Thomas T. Veblen Ph.D., and Rosemary L. Sherriff “Are Wildfire Mitigation and Restoration of Historic Forest Structure Compatible? A Spatial Modeling Assessment” Published Online: by the by Association 27

of American Geographers. Sep. 8, 2006 http://www.ingentaconnect.com/content/routledg/anna/2006/00000096/00000003/art00001 ------Timber Harvest Opposing View #50 - "Private lands are more suitable for timber production. National Forest land is on average of lower productivity and on steeper, higher elevation terrain than are private forestlands."

Powell, Douglas S. Ph.D, Joanne L. Faulkner, David R. Darr, Zhiliang Zhu Ph.D. and Douglas W. MacCleery. 1992. "Forest Resources of the United States." USDA Forest Service. Rocky Mt. Forest and Range Experiment Station. Gen. Tech. Rep. RM-234. http://www.fs.fed.us/rm/pubs_rm/rm_gtr234.html ------Timber Harvest Opposing View #52 - “Less than 5% of America's original forests remain, and these forests are found primarily on federal lands. Logging in the last core areas of biodiversity is destroying the remaining intact forest ecosystems in the United States. At the current rate of logging, these forests and their priceless biological assets will be destroyed within a few decades.

We urge Congress to pass the Act to Save America's Forests. It is the first nationwide legislation that would halt and reverse deforestation on all our federal lands. By implementing protective measures based on principles of conservation biology, the bill provides a scientifically sound legislative solution for halting the rapid decline of our nation's forest ecosystems.

The Act to Save America's Forests will:

• Make the preservation and restoration of native biodiversity the central mission of Federal forest management agencies.

• Ban extractive logging in core areas of biodiversity and the last remnant original forest ecosystems: roadless areas, ancient forests and special areas of outstanding biological value.

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• Protect sensitive riparian areas and watershed values by banning extractive logging in streamside buffer zones.

• End clearcutting and other even age logging practices on federal land.

• Establish a panel of scientists to provide guidance to federal forest management.

We believe it is our professional responsibility to ask Congress to align Federal forest management with modern scientific understandings of forest ecosystems. Passage of the Act to Save America's Forests will give our nation's precious forest ecosystems the best chance or survival and recovery into the 21st century and beyond.”

Raven, Peter, Ph.D., Jane Goodall, C.B.E., Ph.D., Edward O. Wilson, Ph. D. and over 600 other leading biologists, ecologists, foresters, and scientists from other forest specialties. From a 1998 letter to congress. http://www.saveamericasforests.org/resources/Scientists.htm ------Timber Harvest Opposing View #53 - “The Act to Save America’s Forests is based on the principles of conservation biology. It would make the protection native biodiversity the primary goal of federal forest management agencies. The bill would protect over 20 million acres of core forest areas throughout the nation, including ancient forests, roadless areas, key watershed, and other special areas. It is a comprehensive, sustainable, and ecologically-sound plan for protecting and restoring the entire federal forest system.

If the current pace of logging planned by the Forest Service continues, nearly all of America’s ancient and roadless wild forests will soon be lost forever. According to a recent report by the World Resources Institute, only one percent of the original forest cover remains in large blocks within the lower 48 states. The Act to Save America’s Forests incorporates the solution recommended by the report, namely to protect core forest areas from any logging and to allow sustainable forest practices around these protected forests. Endorsed by over 600 leading scientists, this bill may be the last hope for America’s forests.”

Raven, Peter, Ph.D., from his February 9, 2001 letter to Senator Jean Carnahan http://www.saveamericasforests.org/Raven.htm

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------Timber Harvest Opposing View #54 - “It is well established that logging and roadbuilding often increase both fuel loading and fire risk. For example, the Sierra Nevada Ecosystem Project (SNEP) Science Team (1996) concluded that “timber harvest…. has increased fire severity more than any other recent human activity” in the Sierra Nevada. Timber harvest may increase fire hazard by drying of microclimate associated with canopy opening and with roads, by increases in fuel loading by generation of activity fuels, by increases in ignition sources associated with machinery and roads, by changes in species composition due to opening of stands, by the spread of highly flammable non native weeds, insects and disease, and by decreases in forest health associated with damage to soil and residual trees (DellaSala and Frost, 2001; Graham et al., 2001; Weatherspoon et al., 1992; SNEP Science Team, 1996). Indeed a recent literature review reported that some studies have found a positive correlation between the occurrence of past logging and present fire hazard in some forest types in the Interior Columbia Basin (DellaSala and Frost, 2001).”

Roberson, Emily B. Ph.D., Senior Policy Analyst, California Native Plant Society Excerpt from a letter to Chief Dale Bosworth and 5 members of congress http://www.plantsocieties.org/PDFs/Fire%20letter%20CNPS%208.02%20letterhead.pdf ------Timber Harvest Opposing View #55 - “I will discuss my views on how activities related to timber harvest adversely affect coastal salmonids in California by destroying, altering, or otherwise disturbing the freshwater habitats upon which these fish depend during crucial phases of their life cycle. I base these opinions on my research and observations in the field, as well as my review of and familiarity with the scientific literature and publications of government agencies, commissions, and scientific review panels. Below I discuss in some detail the life history and habitat needs of coho salmon to illustrate how timber harvest and related roads affect this threatened species. Although Chinook salmon and steelhead trout have similar life histories and habitat needs, and also are negatively affected by timber harvest, I will use coho salmon in my discussion.”

“Loss or degradation of stream habitat has been and remains the single most significant cause of the decline of anadromous salmonids in general in the Pacific Northwest. In 30

my experience the most pervasive and severe impacts to coastal watersheds in California inhabited by coho salmon result from logging and associated activities. These activities cause significant alteration and degradation to coho salmon habitat by 1) increasing sediment input to salmon bearing streams and their tributaries: 2) by decreasing input of LWD into waterways; 3) by altering streamflow regimes, increasing the likelihood of scouring flows and flooding; and 4) by increasing water temperatures. These pervasive changes due to timber harvest decrease the complexity and suitability of coho salmon habitat, including adversely affecting insects and other organisms that provide food for fish.”

Roelofs, Terry D. Ph.D. Testimony for the California State Water Board and Regional Water Quality Control Boards Regarding Waivers of Waste Discharge Requirements on Timber Harvest Plans. August 2003. http://www.docstoc.com/docs/20957789/EXPERT-WITNESS-REPORT-OF-TERRY-D ------Timber Harvest Opposing View #56 - “People moving to the region may do so for reasons related to the social environment and the physical landscape but not care about specific Federal land management practices. We found this not to be true, since 92 percent were concerned with how Federal lands were managed. The most frequent preferences for managing Federal lands were water/watershed and ecosystem protection (table 3). Timber harvesting was cited by 16 percent, grazing and ranching by 6 percent, and mineral exploration/mining by less than 1 percent. Overall, protective strategies made up 76 percent of the preferred management strategies and commodity- based strategies 23 percent. This same trend is evident for the second and third most stated preferences. These findings also contradict the longstanding view of the Federal lands as a public warehouse of commodities to be harvested and jobs to be filled. For newcomers in the rural West, the value of these public lands is related to protecting and preserving them.”

Rudzitis, Gundars. 1999 “Amenities Increasingly Draw People to the Rural West” Rural Development Perspectives, vol. 14, no. 2 http://www.colorado.edu/AmStudies/lewis/west/amenities.pdf ------

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Timber Harvest Opposing View #57 - “Once clear-cutting has occurred, regulation and human silvicultural practices become responsible for the revegetation that follows. The creation of new forest succession patterns are the result of human control over the growing environment. Rather than proceeding at a natural pace, humans attempt to speed up the forest succession process to quickly return to a situation where harvesting is again possible. Reforestation of the disturbed area after clear-cutting also emphasizes maintaining control over the distribution and quality of forest species.

Simplification is a state that results from the forest being harvested before it reaches maturity. Logging simplifies forest ecosystems (Dudley et al 1995) by narrowing the age range of the stand and suppressing diversification through repeated harvesting, burning to remove slash, and replanting with hybrid seedlings. Simplification affects the health and productivity of the forest because simplified forests lack the variety found in older stands, including species diversity, vertical structure, and microhabitat. From an ecological standpoint, a simplified forest of a particular age has less overall bio-mass per acre than a natural forest of the same age, but a simplified forest produces a higher volume of merchantable timber.

Scott, Mark G. “Forest Clearing in the Gray’s River Watershed 1905-1996” A research paper submitted in partial fulfillment of the requirements for the degree of MASTER OF SCIENCE in GEOGRAPHY Portland State University, 2001 http://www.markscott.biz/papers/grays/chapter1.htm ------Timber Harvest Opposing View #58 - “Within this volatile atmosphere the Bush Administration presented a new proposal for fire prevention called the "Healthy Forest Initiative." The plan received wide coverage in the national media in August and September 2002 and continues to be at the center of an attempt to significantly shift public land management in the United States. At the core of the plan is an effort to create private sector incentives to promote logging/thinning projects in the national forests.”

Short, Brant, Ph.D. and Dayle C. Hardy-Short Ph.D. "Physicians of the Forest": A Rhetorical Critique of the Bush Healthy Forest Initiative” Electronic Green Journal, Issue #19, December 2003 http://escholarship.org/uc/item/4288f8j5

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------Timber Harvest Opposing View #59 - “Logging on the National Forests provides less than 5% of the nation's timber supply, but costs the taxpayers more than 1 billion dollars in subsidies every year. Nor is logging a good job provider compared to recreation, which by Forest Service estimates provides over 30 times the economic benefits of logging. These forests are the last remnants of the virgin forests that covered the country, and now have far more value as forest ecosystems, watershed/water supply protection, and recreational assets than for logging. In fact, the justification for the Weeks Act in 1911 which established national forests in the east, was watershed protection.

(A major barrier to the Forest Service changing its ways is that these increased recreational economic benefits flow into the local economy, not to the Forest Service itself, whereas extractive uses of the national forests contribute directly to Forest Service budgets.)

“Our nation is engaged in a great debate over the real purpose of our national forests, with the weight of public opinion swinging more and more strongly toward preservation. Certainly this nation should not be subsidizing logging when it is clear that we understand so little about the functioning of these enormously complex and ancient forest ecosystems that provide millions of people with clean air and water, as well as homes for a myriad of plants and wildlife that can live nowhere else.”

Sierra Club. 2005 “Ending Commercial Logging on Public Lands” http://northcarolina.sierraclub.org/pisgah/conservation/ecl.html ------Timber Harvest Opposing View #60 - “Timber harvesting in British Columbia influences (a) forest hydrology; (b) fluvial geomorphology; (c) terrain stability; and (d) integrated watershed behavior. Impacts on forest hydrology are well understood and include increased average runoff, total water yield, increased storm runoff and advances in timing of floods. Stream channels and valley floors are impacted differently by fine sediment, coarse sediment and large woody debris transport. Terrain stability is influenced through gully and mass movement processes that are accelerated by timber 33

harvesting. Impacts on integrated watershed behavior are assessed through disturbed sediment budgets and lake sediments.”

Slaymaker, Olav Ph.D. “Assessment of the Geomorphic Impacts of Forestry in British Columbia” AMBIO: A Journal of the Human Environment 29(7):381-387. 2000 http://www.bioone.org/doi/abs/10.1579/0044-7447-29.7.381 ------Timber Harvest Opposing View #61 - “In sum, 100 years of fire suppression and logging have created conditions that threaten central Oregon’s natural resources and communities.”

“Thus it is inexplicable that the solution proposed by President Bush and some members of Congress emphasizes fire suppression and commercial logging, the very practices that created today’s crisis. The federal government continues to attempt to suppress over 99% of all wildland fires. The Forest Service continues to measure its success not in terms of ecosystems restored, but in fires put out. The President’s Healthy Forest Initiative, as embodied in H.R. 1904, promotes commercial logging at the expense of citizen participation and oversight of the forests we own.”

Stahl, Andy. “Reducing the Threat of Catastrophic Wildfire to Central Oregon Communities and the Surrounding Environment.” Testimony before the House Committee on Resources, August 25, 2003 http://www.propertyrightsresearch.org/2004/articles6/testimony_of_andy_stahl.htm ------Timber Harvest Opposing View #62 - “Fire, just like insects and disease, are a natural and beneficial part of forest ecosystems and watersheds. Without these natural processes the forest ecosystems quickly degrade. Excessive logging removes and reduces cooling shade adding to the hotter, drier forests along with logging debris creating a more flammable forest. Current "forest management" practices, road building and development cause forest fires to rage for hundreds of miles.

The Sierra Nevada Ecosystem Project said in a report to the U.S. Congress that timber harvests have increased fire severity more than any other recent human activity.

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Logging, especially clear cutting, can change the fire climate so that fires start more easily, spread faster, further, and burn hotter causing much more devastation than a fire ignited and burned under natural conditions. If we stop the logging and stop building fire prone developments, we minimize the loss of lives and property suffered by people in fires.

As long as the people of America let politicians, timber executives, and the Forest Service get away with it - it will not stop. Those corporations that profit will continue to lie, cheat and steal to continue to make more money from our losses. Just like big tobacco.”

Strickler, Karyn and Timothy G. Hermach, “Liar, Liar, Forests on Fire: Why Forest Management Exacerbates Loss of Lives and Property” Published by CommonDreams.org, October 31, 2003 http://www.commondreams.org/scriptfiles/views03/1031-10.htm ------Timber Harvest Opposing View #63 - “The agency’s commercial timber program can contribute to the risk and severity of wildfire in the National Forests, yet Congress devotes nearly one-third of the Forest Service’s entire budget to this wasteful program.” (pg. 1)

“Do not utilize the commercial timber program to reduce the risk of fire. Commercial incentives undercut forest health objectives and can actually increase the risk of fire.” (pg. 9)

“Commercial logging, especially of larger, fire-resistant trees, in the National Forests is one of several factors contributing to the risk and severity of wildfire.” (pg. 19)

“Commercial logging and logging roads open the forest canopy, which can have two effects. First, it allows direct sunlight to reach the forest floor, leading to increased evaporation and drier forests.5 As a consequence, ground fuels (grass, leaves, needles, twigs, etc.) dry out more quickly and become susceptible to fire. Second, an open canopy allows more sunlight to reach the understory trees, increasing their growth.6 This can lead to weaker, more densely-packed forests.” (pgs. 19-20)

“Congress and the Forest Service continue to rely on the commercial logging program to do something it will never accomplish – reduce fire risk. The commercial logging program is designed to provide trees to private timber companies, not to reduce the risk of fire.” (pg. 20)

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Taxpayers for Common Sense. “From the Ashes: Reducing the Harmful Effects and Rising Costs of Western Wildfires” Washington DC , Dec. 2000 http://www.taxpayer.net/library/article/from-the-ashes ------Timber Harvest Opposing View #64 - “Indiscriminate logging is not a viable solution to reducing wildfire risk. Logging can actually increase fire danger by leaving flammable debris on the forest floor. Loss of tree canopy lets the sun in, encouraging the growth of brush, increases wind speed and air temperature, and decreases the humidity in the forest, making fire conditions even worse.”

Thomas, Craig. “Living with risk: Homeowners face the responsibility and challenge of developing defenses against wildfires.” Sacramento Bee newspaper, July 1, 2007. http://www.sierraforestlegacy.org/NR_InTheNews/SFLIP_2007-07-01_SacramentoBee.php ------Timber Harvest Opposing View #65 - "Timber harvest, through its effects on forest structure, local microclimate, and fuels accumulation, has increased fire severity more than any other recent human activity."(pg.62)

University of California; SNEP Science Team and Special Consultants 1996 “Sierra Nevada Ecosystem Project: Final Report to Congress” Volume 1, Chapter 4 – Fire and Fuels. http://www.alibris.com/Sierra-Nevada-Ecosystem-Project-Final-Report-to-Congress-Status-of-the-Sierra- Nevada-University-of-California/book/9814335 ------Timber Harvest Opposing View #67 - "The development of sound forest-management policies requires that consideration be given to the economic benefits associated with competing uses of forest resources. The benefits that may be provided under different

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management regimes include both use values (such as those provided by timber harvesting and recreation) and passive-use (or nonuse) values, including existence value, option value and quasi-option value. Many of these benefits are not revealed in market transactions, and thus cannot be inferred from conventional data on prices and costs."

Vincent, James W. Ph.D., Daniel A. Hagen, Ph.D., Patrick G. Welle Ph.D. and Kole Swanser. 1995. Passive-Use Values of Public Forestlands: A Survey of the Literature. A study conducted on behalf of the U.S. Forest Service, January 31, 1995 http://icbemp.gov/science/vincent.pdf ------Timber Harvest Opposing View #68 - “Unfortunately, there are number of massive logging proposals, disguised as hazardous fuels treatments, that have put environmentalists at odds with the Forest Service. Nearly all of these proposals focus primarily on the removal of mature and old-growth trees. These proposals continue even with overwhelming evidence that commercial logging is more of a problem than a solution. There's simply a cognitive disconnect between the Forest Service's scientists and its timber sale planners, whose budgets are dependent upon selling valuable mature trees.

Ironically, this very type of logging, experts inform us, is likely to increase, not decrease, the frequency and severity of wildland fires.

In the Forest Service's own National Fire Plan, agency scientists warned against the use of commercial logging to address fire management. The report found that ‘the removal of large, merchantable trees from forests does not reduce fire risk and may, in fact, increase such risk.’ “

Voss, René, Ph.D. “Getting Burned by Logging,” July 2002 The Baltimore Chronicle http://www.baltimorechronicle.com/firelies_jul02.shtml ------

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Timber Harvest Opposing View #69 - “Another surprising finding is that mechanical fuels treatment, commonly known as logging and thinning, typically has little effect on the spread of wildfires. In fact, in some cases, it can increase wildfires’ spread and severity by increasing the fine fuels on the ground (slash) and by opening the forest to greater wind and solar penetration, drying fuels faster than in unlogged forests.”

Wuerthner, George. “Logging, thinning would not curtail wildfires” The Eugene Register-Guard, December 26, 2008 http://wuerthner.blogspot.com/2008/12/logging-thinning-would-not-curtail.html ------Timber Harvest Opposing View #70 - “Logging equipment compacts soils. Logging removes biomass critical to future soil productivity of the forest. Logging disturbs sensitive wildlife. Logging typically requires roads and skid trails which create chronic sources of sedimentation that degrades water quality and aquatic organism habitat. Logging roads and skid trails are also a major vector for the spread of weeds. Logging disrupts nutrient cycling and flows. Logging can alter species composition and age structure (i.e. loss of old growth). Logging can alter fire regimes. Logging can change water cycling and water balance in a drainage. The litany of negative impacts is much longer, but suffice it to say that anyone who suggests that logging is a benefit or benign is not doing a full accounting of costs.”

Those who suggest that logging “benefits” the forest ecosystem are using very narrow definitions of “benefit.” Much as some might claim that smoking helps people to lose weight and is a “benefit” of smoking.”

Wuerthner, George “Who Will Speak For the Forests?” NewWest, January 27, 2009 http://www.newwest.net/topic/article/who_will_speak_for_the_forests/C564/L564/ ------Timber Harvest Opposing View #71 - "After logging, peak pipeflow was about 3.7 times greater than before logging."

"The use of heavy logging equipment was expected to compact the soil, reduce infiltration rates, and increase surface runoff. In addition, heavy equipment might 38

collapse some of the subsurface pipes, increasing local pore water pressure and the chance of landslides (Sidle, 1986)."

Ziemer, Robert R. Ph.D., "Effect of logging on subsurface pipeflow and erosion: coastal northern California, USA." Proceedings of the Chengdu Symposium, July 1992. IAHS Publication. No. 209, 1992 http://www.fs.fed.us/psw/publications/ziemer/Ziemer92.PDF ------Timber Harvest Opposing View #72 - “As conservation-minded scientists with many years of experience in biological sciences and ecology, we are writing to bring your attention to the need to protect our National Forests. Logging our National Forests has not only degraded increasingly rare and valuable habitat, but also numerous other services such as recreation and clean water.”

“Unfortunately, the past emphasis of management has been on logging and the original vision for our National Forests has failed to be fully realized. During the past several decades, our National Forests have suffered from intense commercial logging. Today almost all of our old growth forests are gone and the timber industry has turned our National Forests into a patchwork of clearcuts, logging roads, and devastated habitat.”

“It is now widely recognized that commercial logging has damaged ecosystem health, clean water, and recreational opportunities-- values that are highly appreciated by the American public. The continued logging of our National Forests also wastes American tax dollars and diminishes the possibilities of future economic benefits. The Forest Service and independent economists have estimated that timber accounts for only 2.7 percent of the total values of goods and services derived from the National Forests, while recreation and fish and wildlife produce 84.6 percent.”

From an April 16, 2002 letter to President Bush asking him to stop all logging in the national forests. http://www.wvhighlands.org/Voice%20PDFs/VoiceAug02.pdf

The names of the 221 Ph.D. level scientists that signed the letter are listed below:

Dr. E.O. Wilson, Ph.D. Stanford University, Dr. Peter Raven, Ph.D. Harvard University, Department of Biological Missouri Botanical Garden, Department of Biology, Sciences, Sr. Research Director, 2000 National Professor Associate, Center for Medal of Science winner ------Conservation Biology ------Dr. Anne Ehrlich, Ph.D. ------Dr. David R. Foster, Ph.D. 39

Harvard University, Director Tulane University, Museum University of North Carolina- Harvard Forest of Natural History, Director Wilmington, Department of and Curator of Fishes Biology, Professor of Wildlife ------Ecology Dr. Kenneth P. Able, Ph.D. ------University at Albany, SUNY Dr. Fakhri Bazzaz, Ph.D. ------Department of Biological Harvard University, Dr. Herb Boschung, Ph.D. Sciences, Professor Department of Biology, University of Alabama- Mallinckrodt Professor of Tuscaloosa, Department of ------Biology Biological Sciences, Dr. Kraig Adler, Ph.D. Professor Emeritus Cornell University, Vice ------Provost for Life Sciences, Dr. Donald L. Beaver, Ph.D. ------Professor of Biology Michigan State University, Dr. Richard Bradley, Ph.D. Department of Zoology/The Ohio State University, ------Michigan State University Department of Evolution, Dr. Steven C. Anderson, Museum, Professor Emeritus Ecology, and Organismal Ph.D. Biology, Professor University of the Pacific, ------Department of Biological Dr. David L. Bechler, Ph.D. ------Sciences, Professor Emeritus Valdosta State University, Dr. Greg Brown, Ph.D. Department of Biology, Alaska Pacific University, ------Department Head Department of Environmental Dr. William D. Anderson, Jr., Science, Associate Professor Ph.D. ------Grice Marine Biological Dr. Chris Benkman, Ph.D. ------Laboratory New Mexico State University, Dr. David M. Bryant , Ph.D. Department of Biology, Harvard University, ------Associate Professor Department of Earth and Dr. Robert Angus, Ph.D. Planetary Science, Member, University of Alabama------Zi Sigma Pi, the Honorary Birmingham, Department of Dr. Brad Bergstrom, Ph.D. Fraternity of Foresters Biology, Professor Valdosta State University, Department of Biology, ------Professor Dr. Deborah Buitron, Ph.D. Dr. Jonathan W. Armbruster, North Dakota State Ph.D. ------University, Department of Auburn University, Dr. Tim M. Berra, Ph.D. Biological Sciences, Adjunct Department of Biology, Ohio State University, Professor Assistant Professor of Evolution, Ecology & Dr. Rabel J. Burdge, Ph.D. Biology, Curator of Fishes Organismal Biology, Western Washington ------Professor Emeritus University, Department of Dr. David R. Atkinson, Ph.D. ------Sociology, and Cornell University, Professor Dr. Benjamin Blount, Ph.D. Environmental Studies, of Ecology & Evolutionary University of Georgia, Professor Emeritus, Biology Department of Anthropology, ------Professor Dr. Nancy M. Butler, Ph.D. Michelle A. Baker, Ph.D. ------Gustavus Adolphus College, Utah State University, Dr. Dee Boersma, Ph.D. Department of Biology, Department of Biology, University of Washington, Assistant Professor Assistant Professor Department of Zoology, ------Professor Dr. William Calder, Ph.D. Dr. Henry L. Bart, Jr., Ph.D ------University of Arizona, Dr. Eric Bolen, Ph.D. Professor of Ecology and Evolutionary Biology 40

University of Alaska, Curator Columbia University, Center ------of Mammals and Professor of for Environmental Research Kevin Caldwell, Ph.D Biology and Conservation, Associate Appalachian Ecological Research Scientist Consultants, Botanist ------Dr. Jeffery D. Corbin, Ph.D. ------University of California- Dr. Margaret B. Davis, Ph.D. Dr. Todd Campbell, Ph.D. Berkeley, Department of University of Minnesota, University of Tennessee, Integrative Biology, Post- Department of Ecology, Department of Ecology and Doctoral Fellow/ Lecturer Evolution and Behavior, Evolutionary Biology, Post- Regents Professor of Doctoral Research Associate ------Ecology, retired The Institute for Biological Dr. Richard G. Coss, Ph.D. Invasions University of California------Davis, Graduate Groups in Dr. Larry Dew, Ph.D. ------Psychology, Ecology, and University of California-Davis, Kai Chan, Ph.D. Animal Behavior Professor Department of Anthropology Princeton University, Department of Ecology and ------Evolutionary Biology Dr. Tom Cottrell, Ph.D. Dr. Calvin B. DeWitt, Ph.D. Central Washington University of Wisconsin------University, Department of Madison Professor of Dr. Jiquan Chen, Ph.D. Biology, Plant Ecologist Environmental Studies Michigan Tech University, Director, Au Sable Institute of School of Forestry and Wood ------Environmental Studies Products, Associate Dr. Tom Cottrell, Ph.D. Professor, Landscape Central Washington ------Ecology & Ecosystem University, Department of Dr. Janis L. Dickinson, Ph.D. Science Biology, Plant Ecologist University of California- Berkeley Museum of ------Vertebrate Zoology, Assistant Dr. Joel E. Cohen, Ph.D. Dr. Brian I. Crother, Ph.D. Research Zoologist Hastings Rockefeller University, Southeastern Louisiana Natural History Reservation Professor of Populations University, Department of Biology, Associate Professor ------Dr. C. Kenneth Dodd, Jr., Cormac Collier, Ph.D. ------Ph.D. Cape Cod National Dr. Thomas W. Culliney, University of Florida Seashore, Biological Ph.D. Department of Wildlife Technician Hawaii Department of Ecology and Conservation, Agriculture, population Courtesy Associate ------ecologist Dr. Jeff Connor, Ph.D. Professor, President, The Michigan State University, ------Herpetologists' League Department of Botany and Dr. Gretchen C. Daily, Ph.D. ------Plant Pathology, Associate Stanford University, Dr. David Edds, Ph.D. Professor, Kellogg Biological Department of Biological Emporia State University, Station, Associate Editor Sciences, Bing Department of Biological Evolution Interdisciplinary Research Sciences, Professor Scientist, Editor, Nature's ------Services: Societal ------Carol Conway, Ph.D. Dependence on Natural Dr. Joan Edwards, Ph.D. University of California-Davis, Ecosystems Williams University, Department of Ecology Department of Biology, ------Professor of Biology ------Dr. James Danoff-Burg, Dr. Joseph Cook, Ph.D. Ph.D. ------41

Dr. Timothy J. Ehlinger, Ph.D Princeton University, Dr. David G. Hankin, Ph.D. University of Wisconsin- Department of Ecology and Humboldt State University, Milwaukee, Department of Evolutionary Biology, Telonicher Marine Lab Biological Sciences, Lecturer Professor of Fisheries Assistant Professor ------Biology ------Patricia Gensel, Ph.D. ------Dr. Paul Ehrlich, Ph.D. University of North Carolina, Dr. Robert B. Hastings, Ph.D. Stanford University, Professor of Biology, Southeastern Louisiana Department of Biological President Botanical Society University, Department of Sciences, Professor of of America Biology, Professor of Biological Sciences ------Biological Sciences ------Dr. Cameron Ghalambor, ------Dr. W. Hardy Eshbaugh, Ph.D. Dr. Dean A. Hendrickson, Ph.D. University of California- Ph.D Miami University, Department Riverside, Department of University of Texas- Austin, of Botany, Professor Biology Texas Natural History Emeritus Collections, Texas Museum ------of Science and History, ------Dr. Barrie K. Gilbert, Ph.D. Curator of Ichthyology Dr. William J. Etges, Ph.D. Utah State University, University of Arkansas, Department of Fisheries and ------Department of Biological Wildlife-- Ecology Center, Dr. Andrew Hendry , Ph.D. Sciences Senior Scientist University of Massachusetts- Amherst, Organismic and ------Evolutionary Biology Program Dr. Joseph E. Faber, Ph.D. Dr. Douglas S. Glazier, Ph.D. West Virginia University- Juniata College, Department ------Parkersburg, Division of of Biology, Professor of Dr. James D. Hengeveld, Natural Sciences, Assistant Biology Ph.D. Professor Indiana University, ------Department of Biology, ------Dr. Robert H. Gray , Ph.D. Assistant Professor & Lab Elizabeth Fensin, Ph.D. Umatilla Chemical Agent Coordinator N.C. Division of Water Disposal Facility, Principal Quality, Environmental Investigator ------Biologist Dr. Frank H. Heppner, Ph.D. ------University of Rhode Island, ------Dr. Jay Greenberg, Ph.D. Department of Biological Dr. G. Edgar Folk, Ph.D. University of Rochester Sciences, Professor of Iowa State University, Medical Center, Department biological sciences Department of Physiology, of Biochemistry and Professor of Environmental Biophysics ------Physiology Dr. David M. Hillis, Ph.D. ------University of Texas- Austin, ------Dr. Correigh Greene, Ph.D. Director, School of Biological Dr. Johannes Foufopoulos, University of California- Sciences Ph.D. Davis, Section of Evolution Princeton University, and Ecology ------Department of Ecology and Dr. Mark Hixon, Ph.D. Evolutionary Biology, Visiting ------Oregon State University, Assistant Professor Dr. Ed Grumbine, Ph.D. Department of Zoology University of California------Santa Cruz, Extension Sierra ------Dr. ElizaBeth A. Fox, Ph.D. Institute Dr. Karen Holl, Ph.D. ------42

University of California- Humboldt State University, Integrative and Comparative Santa Cruz, Department of Department of Biological Biology Environmental Studies Sciences, Assistant Professor ------Dr. Arthur H. Kopelman, Dr. Robert W Howarth, Ph.D. ------Ph.D. Environmental Defense Dr. James R. Karr, Ph.D. State University of New York, Oceans Program, Senior University of Washington, Department of Science and Scientist and Program Department of Environmental Mathematics, Professor of Manager Health, Professor of Aquatic Science, President Coastal Sciences and Zoology, Research and Education ------Adjunct Professor of Civil Society of Long Island Dr. Bruce Hungate, Ph.D. Engineering Northern Arizona University, ------Department of Biological ------Dr. Don Kroodsma, Ph.D. Sciences, Assistant Dr. Sylvan R. Kaufman, University of Massachusetts, Professor Ph.D. Department of Biology, Harvard University, Biological Professor ------Labs, Postdoctoral Fellow Dr. Alan Hutchcroft, Ph.D. ------Rockford College, Bartels ------Dr. Kenneth Krysko, Ph.D. Professor of Chemistry Dr. Sterling Keeley, Ph.D. University of Florida, Florida University of Hawaii- Manoa, Museum of Natural History, ------Department of Botany, Collections Manager, Division Dr. David W. Inouye, Ph.D. Professor and Chair of Herpetology University of Maryland, Professor & Director, ------Graduate Program in Dr. Melody J. Kemp, Ph.D. Bernard Kuhajda, Ph.D. Sustainable Development University of Notre Dame, University of Alabama- and Conservation Biology Department of Biological Tuscaloosa, Department of Sciences, Postdoctoral Biological Sciences ------Research Associate Dr. Charles Jackson, Ph.D. ------Stephen P. Kunz , Ph.D. ------Dr. Keith T. Killingbeck, Ph.D. Certified Senior Dr. Dan Janzen, Ph.D Univeristy of Rhode Island, Ecologist,Certified Wetland University of Pennsylvania, Department of Biological Scientist Professor Sciences ------Dr. Doug LaFollette, Ph.D. Dr. Robert L. Jeanne, Ph.D. Dr. David R. Klein, Ph.D. Wisconsin Secretary of State University of Wisconsin- University of Alaska- Madison, Department of Fairbanks, Institute of Arctic ------Entomology, Professor of Biology, Professor Emeritus Dr. Robert O. Lawton, Ph.D. Entomology and Zoology University of Alabama------Huntsville, Department of ------Dr. Walter Koenig, Ph.D Biological Sciences University of California- Estella Leopold, Ph.D. Dr. Paul A. Johnsgard, Ph.D. Berkeley, Museum of University of Washington, University of Nebraska- Vertebrate Zoology Department of Botany, Lincoln, Department of Professor Biological Sciences, ------Foundation Professor of Dr. Alan Kohn, Ph.D. ------Biological Sciences University of Washington, Dr. John J. Lepri, Ph.D. Department of Zoology, University of North Carolina, ------Professor Emeritus, Formerly Department of Biology, Dr. Erik S. Jules, Ph.D. President of Society for 43

Associate Professor of University of Cincinnati, Biology Department of Biological ------Sciences Dr. Robert J. Meese, Ph.D. ------University of California, Dr. Malcolm P. Levin, Ph.D. ------Department of Environmental University of Illinois at Dr. Terrence P. McGlynn, Science and Policy Springfield, Department of Ph.D. Environmental Studies, University of San Diego, ------Department Chair Assistant Professor of Dr. Gary K. Meffe, Ph.D. Biology University of Florida, ------Department of Wildlife Dr. John Lichter, Ph.D. ------Ecology and Conservation, Bowdoin College, Biology Dr. James B. McGraw, Ph.D. Adjunct Professor, Editor, Department and West Virginia University, Conservation Biology Environmental Studies Department of Biology, Program, Assistant Professor Eberly Professor of Biology & ------Aldo Leopold Leadership Dr. DeForest Mellon, Ph.D. ------Program Fellow University of Virginia, Dr. William Z. Lidicker, Ph.D. Department of Biology, University of California, ------Professor of Biology Berkeley, Professor of Don McKenzie, Ph.D. Integrative Biology, Emeritus University of Washington, ------College of Forest Resources, Dr. John Miles, Ph.D. ------Research Ecologist Western Washington Dr. David R. Lighthall, Ph.D. University, Huxley College of California Institute for Rural ------Environmental Studies, Studies, Executive Director Dr. John McLaughlin, Ph.D. Professor, Director Center for Western Washington Geography and ------University, Huxley College of Environmental Social Dr. John T. Lill, Ph.D. Environmental Studies,- Sciences University of Missouri- Department of Environmental St.Louis Sciences, Assistant ------Professor Dr. Arlee M. Montalvo, Ph.D. ------University of California- Dr. Randy Linder, Ph.D. ------Riverside, Department of University of Texas- Austin, Dr. David McNeely, Ph.D Botany and Plant Sciences, School of Biology Langston University, Asst. Res. Plant Population Sciences/Section of Department of Biology, Biologist & Lecturer Integrative Biology Professor ------Dr. Harold Mooney , Ph.D. Dr. Robin A. Matthews, Ph.D. Dr. Geoff Meaden, Ph.D. Stanford University, Western Washington Canterbury Christ Church Department of Biological University, Huxley College of University College, Sciences, Paul S. Achilles Environmental Studies, Department of Professor of Environmental Professor, Director, Institute GeographyMarine Fisheries Biology for Watershed Studies GIS Unit ------Dr. Cliff Morden, Ph.D. Dr. Thomas P. Maxwell, Dr. Bruce Means, Ph.D. University of Hawaii- Manoa, Ph.D. Florida State University, Department of Botany, University of Maryland, Department of Biological ProfessorCenter for Institute for Ecological Sciences, Adjunct Professor Conservation Research and Economics, Professor of Biological Science, Training ------Executive Director Coastal Plains Institute ------Dr. Audrey Mayer, Ph.D. Dr. Timothy C. Morton, Ph.D. 44

University of Chicago, North Dakota State and Conservation, Professor Department of Biology, University, Department of of Conservation Biology visiting Assistant Professor, Biological Sciences, Ecological Society of America Professor ------Dr. Mary V. Price, Ph.D. ------University of California- Dr. Peter B. Moyle, Ph.D. Dr. Philip Nyhus, Ph.D. Riverside, Department of University of California- Franklin & Marshall College, Biology, Professor of Biology Davis, Department of Wildlife, Department of Geosciences, Fish, and Conservation Assistant Professor ------Biology, Professor of Fish Dr. Mark Pyron, Ph.D. Biology ------Ball State University, Dr. Dennis Ojima, Ph.D. Department of Biology, ------Natural Resource Ecology Assistant Professor Dr. Helmut C. Mueller, Ph.D. Laboratory, Colorado State University of North Carolina, University, Senior Research ------Department of Biology & Scientist, Aldo Leopold Dr. Peter A. Quinby , Ph.D. Curriculum in Ecology, Leadership Fellow Paul Smith's College, Natural Professor Emeritus Resources, Science and ------Liberal Arts, Assistant Dean ------Dr. Gordon H. Orians, Ph.D. and Associate Professor Dr. Steven Mullin, Ph.D. University of Washington, Eastern Illinois University, Professor Emeritus of ------Department of Biological Zoology Dr. John T. Ratti, Ph.D. Sciences, Professor University of Idaho- Moscow, ------Department of Fish and ------Dr. Michael Ort, Ph.D. Wildlife Dave Neely, Ph.D. University of Northern University of Alabama, Arizona, Department of ------Biodiversity and Systematics Geology, Associate Dr. Stuart Reichler, Ph.D. ProfessorCenter for University of Texas- Austin, ------Environmental Sciences and School of Biology Sciences Dr. Richard Niesenbaum, Education Ph.D. ------Muhlenberg College, ------Dr. Janita Rice, Ph.D. Department of Dr. Richard S. Ostfeld, Ph.D. California State University BiologyAssociate Professor Institute of Ecosystem ------of Biology, Donald and Anne Studies Dr. Carol Riley, Ph.D. Shire Distinguished Teaching Professor ------Dr. Ken Parejko, Ph.D. Dr. Caroljane B. Robertson, ------University of Wisconsin, Ph.D. Dr. Elliott A. Norse, Ph.D. Department of Biology, President, Marine Associate Professor ------Conservation Biology Dr. George Robinson, Ph.D. Institute, Author: Ancient ------State University of New York Forests of the Pacific Dr. Dennis Paulson, Ph.D. at Albany, Department of Northwest University of Puget Sound, Biological Sciences, Slater Museum of Natural Associate Professor ------History, Director Dr. M. Philip Nott, Ph.D. ------The Institute for Bird ------Joe Rocchio, Ph.D. Populations Dr. Ann Phillippi, Ph.D. Colorado Natural Heritage ------Program, Wetland Ecologist Dr. Gary Nuechterlein, Ph.D. Dr. Stuart Pimm, Ph.D. ------Columbia University, Center for Environmental Research 45

Dr. Charles Romesburg, Physiology, Professor of Ph.D. ------Physiology Utah State University, Dr. William H. Schlesinger, Department of Forest Ph.D. ------Resources, Professor Duke University, Dean, Dr. Christoper C. Smith, Nicholas School of the Ph.D. ------Environment and Earth Kansas State University, Dr. Thomas Rooney, Ph.D. Sciences, James B. Duke Division of Biology University of Wisconsin- Professor of Biogeochemistry Madison, Department of ------Botany ------Dr. Bradley F. Smith, Ph.D. Dr. Stephen H. Schneider, Western Washington ------Ph.D University, Huxley College of Dr. Barry Rosenbaum, Ph.D. Stanford University, Environmental Studies, University of Colorado, Department of Biological Dean Research Associate, Institute Sciences of Arctic and Alpine Research ------Dr. Youngsinn Sohn, Ph.D. ------Dr. Peter Schulze, Ph.D. University of Maryland- Dr. Scott D. Russell, Ph.D. Austin College, Associate Baltimore, Geography & University of Oklahoma, Professor of Biology, Environmental Systems, George Lynn Cross Director, Center for Assistant Professor Research Professor of Environmental Studies Botany, Director, Samuel ------Roberts Noble Electron ------Dr. John Soluri, Ph.D. Microscopy Laboratory Burton Shank, Ph.D. Carnegie Mellon University, Florida Fish and Wildlife Department of History, ------Conservation, Assistant Professor of History Dr. John M. Rybczyk, Ph.D. AssociationResearch and Policy Western Washington Biologist University, Huxley College of ------Environmental Studies, ------Dr. Stefan Sommer, Ph.D. Assistant Professor Dr. Sharron K. Sherrod, Idaho State University, Ph.D. Department of Biological ------University of Denver, Sciences, Research Dr. Karin Sable, Ph.D. Department of Biology, Assistant, Professor, Director University of Puget Sound, Professor Natural Heritage Center Department of Economics ------Dr. Fraser Shilling, Ph.D. Dr. Lisa G. Sorenson, Ph.D. Dr. Edward Saiff, Ph.D. University of California- Union of Concerned Ramapo College of New Davis, Section of Microbial Scientists, Global Jersey, Department of and Cellular Biology, Chair Environment Program, Biology, Professor of Biology, Committee on Conservation, Adjunct Research Assistant Fellow, American Association Society for Integrative Professor- Biology for the Advancement of andComparative Biology Department, Science ------BostonUniversity ------Erin A. Shope, Ph.D. ------Dr. Alan H. Savitzky, Ph.D. Brevard University, Dr. Michael Soule, Ph.D. Old Dominion University, Environmental Educator Wildlands Project Associate Professor of Biological Sciences ------Dr. John O. Sawyer, Ph.D. Dr. Clifford Slayman, Ph.D. Dr. Larry T. Spencer, Ph.D. Humboldt State University, Yale School of Medicine Plymouth State College, Emeritus Professor of Botany Cellular and Molecular Professor of Biology ------46

Dr. Timothy P. Spira, Ph.D. Biology- University of Dr. David B. Wake, Ph.D. Clemson University, Virginia, sabbatical University of California, Department of Biological Professor of Integrative Sciences, Associate ------Biology, Curator, Museum of Professor Dr. Douglas W. Tallamy, Vertebrate Zoology Ph.D. ------University of Delaware, ------Dr. Alan Springer, Ph.D. Department of Entomology Dr. Skip Walker, Ph.D. University of Alaska- and Applied Ecology, University of Alaska- Fairbanks, Institute of Marine Professor Fairbanks, Institute of Arctic Science, Professor ------Biology ------Dr. Eric J. Taylor, Ph.D ------Dr. Robert D. Stevenson, Fish and Wildlife Biologist Dr. Lawernce R. Walker, Ph.D. Ph.D. University of Massachusetts------University of Nevada- Las Boston, Department of Dr. John Terborgh, Ph.D. Vegas, Department of Biology, Associate Professor Duke University, Center for Biology, Professor of Biology of Biology Tropical Conservation, James B Duke Professor ------Dr. Diana H. Wall, Ph.D. Dr. Glen R. Stewart, Ph.D. ------Colorado State University, California State Polytechnic Dr. Andrea S. Thorpe, Ph.D. College of natural Resources, University- Pomona, University of Montana, Professor, Director, Natural Department of Biological Division of Biological Resources Ecological Sciences, Professor of Sciences Laboratory Zoology ------Dr. Harry M. Tiebout, Ph.D. Dr. Donald M. Waller, Ph.D. Dr. Craig Stockwell, Ph.D. West Chester University, University of Wisconsin- North Dakota State Department of Biology Madison, Department of University, Department of ------Botany, Editor, Evolution Zoology, Assistant Professor Dr. Gordon Ultsch, Ph.D. ------University of Alabama- Dr. David O. Wallin, Ph.D. Dr. Phillip K. Stoddard, Ph.D. Tuscaloosa, Department of Western Washington Florida International Biological Sciences University, Huxley College of University, Department of ------Environmental Studies- Biological Sciences Dr. Loraine Utter Kohorn, Department of Environmental Ph.D. Sciences, Associate ------Professor Dr. Philip C. Stouffer, Ph.D. Duke University, Department Southeastern Louisiana of Biology/Nicholas School of ------University, Department of the Environment, Visiting Dr. Glen Walsberg, Ph.D. Biological Sciences, Assistant Professor Arizona State University Associate Professor ------Professor of Biology Dr. Daniel M Vernon, Ph.D. President, Cooper ------Ornithological Society Dr. Boyd R. Strain, Ph.D. Whitman University, Department of Biology Dr. Nickolas M. Waser, Ph.D. Duke University, Department University of California- of Biological Sciences, ------Riverside, Department of Professor Emeritus Dr. Richard A. Wahle, Ph.D. Biology, Professor of Biology, ------Bigelow Laboratory for President, Rocky Mountain Dr. Michael C. Swift, Ph.D. Ocean Sciences, Research Biological Laboratory St. Olaf College, Department Scientist ------of Biology, Department of ------Dr. Judith S. Weis, Ph.D. 47

Rutgers University, Appalachian State University, Department of Biological Department of Biology, Sciences, Professor of Assistant Professor of Biology, Past President Biology American Institute of Biological Sciences ------Dr. Marti Witter, Ph.D. ------Dr. John F. Weishampel, ------Ph.D. Dr. Helen Young, Ph.D. University of Central Florida, Middlebury College, Department of Biology Department of Biology Professor ------Dr. Gregory Welch, Ph.D. ------University of Maine, Dr. Joy B. Zedler, Ph.D. Professor Darling Marine University of Wisconsin- Center Madison, Department of Botany and Arboretum, Aldo ------Leopold Professor of Dr. Robert G. Wetzel, Ph.D. Restoration Ecology University of Alabama- Tuscaloosa, Department of ------Biological Sciences, Bishop Dr. Marion Klaus, Ph.D. Professor of Biology Sheridan College

------Dr. Peter S. White, Ph.D. University of North Carolina- Chapel Hill, Department of Biology, Professor, Director North Carolina Botanical Garden ------Dr. Bill Willers, Ph.D. University of Wisconsin- Oshkosh, Department of Biology, Emeritus Professor of Biology ------Dr. Joe Williams, Ph.D. Colorado State University, Department of EPO Biology ------Dr. Ernest J. Willoughby, Ph.D. St. Mary's College of Maryland, Department of Biology, Professor of Biology ------Dr. Michael Windelspecht, Ph.D.

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------Timber Harvest Opposing View #73 - “Recently, so called "salvage" logging has increased on national forests in response to a timber industry invented "forest health crisis" which points the finger at normal forest processes of fire, fungi, bacteria, insects and other diseases. In fact the crisis in the national forests is habitat destruction caused by too much clearcutting.

My long-term studies of forest diseases in Idaho show the loss by disease and insect activity in all age classes of forests to be less than or slightly more than 1 percent per year over the past thirty-eight years. These findings are consistent with Forest Service national level data.

Forests are structured systems of many life forms interacting in intricate ways and disturbances are essential to their functioning. It’s not fire disease fungi bacteria and insects that are threatening the well being of forests. Disease, fire, windthrow, and other disturbances are a natural part of the forest ecosystem and assist in dynamic processes such as succession that are essential to long term ecosystem maintenance. The real threat facing forests are excessive logging, clearcutting and roadbuilding that homogenize and destroy soil, watersheds and biodiversity of native forests.”

Partridge, Arthur Ph.D., professor emeritus, University of Idaho Statement at a Press Conference with Senator Robert Torricelli about S. 977 and HR 1376), the Act to Save America’s Forests April 28, 1998, U.S. Capitol http://www.saveamericasforests.org/news/ScientistsStatement.htm ------Timber Harvest Opposing View #74 – “In our overview of the impacts of forest management activities on soil erosion and productivity, we show that erosion alone is seldom the cause of greatly reduced site productivity. However, erosion, in combination with other site factors, works to degrade productivity on the scale of decades and centuries. Extreme disturbances, such as wildfire or tractor logging, cause the loss of nutrients, mycorrhizae, and organic matter. These combined losses reduce long-term

49

site productivity and may lead to sustained periods of extended erosion that could exacerbate degradation.

Managers should be concerned with harvesting impacts, site preparation disturbances, amount of tree that is removed, and the accumulation of fuel from fire suppression. On erosion-sensitive sites, we need to carefully evaluate such management factors.”

Elliot, W.J.; Page-Dumroese, D.; Robichaud, P.R. 1999. The effects of forest management on erosion and soil productivity. Proceedings of the Symposium on Soil Quality and Erosion Interaction, Keystone, CO, July 7, 1996. Ankeney, IA: Soil and Water Conservation Society. 16 p. http://forest.moscowfsl.wsu.edu/cgi-bin/engr/library/searchpub.pl?pub=1999c ------Timber Harvest Opposing View #75 - “Logging often destroys natural habitats, resulting in the loss of biodiversity and sometimes leading to the local, and possibly global, extinction of species. Although estimates of the rates of loss vary, few deny the reality of the current losses of both flora and fauna.177 “

According to a joint report by the Worldwide Fund for Nature and the Sarawak Forest Department, "Logging causes immediate forest disturbances, long-term habitat changes (e.g. damage to food trees and salt-licks), increased hunting by timber company workers and availability of logging roads as hunting routes. The destruction of wildlife from habitat loss must be recognised to be on an enormous scale".178 In Central Africa, the opening-up of the forest by logging facilitates the illegal hunting of wildlife, including protected species such as primates, and is leading to a decline in wildlife populations.179 Deterioration in water quality has caused a decline in fish stocks and has affected aquatic biological diversity because indigenous animals and plant life are highly vulnerable to oxygen depletion, suspended particulate matter and a lack of light.180

Even so called selective logging severely affects the complex and rich biodiversity of forests through excessive damage to residual stands, destruction of other plant and tree species and the creaming-off of species which are the most valuable for timber. An FAO study in Malaysia has shown that as much as 50% of the standing forest may be damaged and the surface soil destroyed when up to 30% of the ground surface is exposed. During silvicultural treatment in logging operations in Sarawak, so-called uneconomic forest species are deliberately poisoned. This reduces the complexity and species diversity of the tropical forests to only 10% of the original condition, resulting in the systematic elimination of tree genetic resources and contamination of the

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environment.181 According to the IUCN the most frequently recorded of all threats to globally endangered tree species is 'felling'.182 “

Forests Monitor, Environmental Impacts of Logging, 2006 (with photos) http://www.forestsmonitor.org/en/reports/550066/550083 ------Timber Harvest Opposing View #76 - Major report findings:

1) If we ended the timber sales program on national forests and redirected the logging subsidies we could provide over $30,000 for each public lands timber worker for retraining or ecological restoration work - - and still have over $800 million left over for taxpayer savings in the first year alone.

2) We don’t need to log national forests for our timber supply, given the fact that the timber cut annually from national forests nationwide now comprises only 3.3% of this nation’s total annual wood consumption, and less than 4% of the sawtimber used for construction.

3) Logging on national forests INCREASES the risk of forest fires more than any other human activity.

4) A bipartisan nationwide poll conducted in 1998 found that 69% of Americans now oppose allowing timber companies to log our national forests.

Hansen, Chad, Ph.D., Ending Timber Sales on National Forests: THE FACTS (FY ’97) Published in the Earth Island Journal, 1999 http://www.johnmuirproject.org/pdf/Fy-1997-Economic-Report-Ending-Timber-Sales.pdf ------Timber Harvest Opposing View #77 – “However, I believe that their support for logging represents a failure to challenge many of the flawed assumptions that are guiding federal logging programs and in some cases even repeating many of the same pejorative language helps to undermine in the long term conservation efforts. After all if the public believes our forests are sick and unhealthy; that logging will cure them; that 51

logging will preclude wildfires and eliminate beetle kill, and that rural economies are dependent on public lands logging to survive, than they are, in my view, contributing to the wrong message.”

“There may be legitimate rationales for logging, but it’s not the one usually given for logging public forests today. Indeed, the major justifications given for logging public lands is typically some social or ecological benefit—to reduce fires, clean up bug killed trees, fix watersheds, restore forest health or provide for “economic stability” to rural communities. In far too many cases, all of these are just cover to hide the main reason for logging—to maintain the local timber industry at the expense of our forest’s ecological integrity and taxpayer dollars.”

WUERTHNER, GEORGE, “Why are Conservation Groups Advocating Logging Public Forests?” Published by Counterpunch, September 27, 2012 http://www.counterpunch.org/2012/09/27/why-are-conservation-groups-advocating-logging-public-forests/ ------Timber Harvest Opposing View #78 – “Because of the current government shutdown, the public is being kept out of all National Parks and many other federal lands. But ironically, oil, mineral, and timber companies are still allowed to drill, mine, and log on federal lands while the shutdown is going on. Officials in the US Department of Interior and Department of Agriculture, which oversee National Park and National Forest lands respectively, have given us an unusually clear glimpse of where their priorities lie. Federal lands are supposed to be managed for the benefit of the American people, and resource extraction shouldn’t be going on while the public is barred from our National Parks.

During the shutdown, which was caused because Congress has been unable to pass a budget, almost all “nonessential” federal government services are temporarily unavailable. The fact that the Departments of Interior and Agriculture have apparently found the resources to keep public lands open to drilling and logging, but can’t keep National Parks and other recreational areas open, shows resource extraction in being prioritized over public access to our lands. It’s time for this to change.”

“Stop Drilling and Logging on Federal Lands While the Public is Kept Out” A petition targeted for Secretary of the Interior Sally Jewel and Secretary of Agriculture Tom Vilsack Posted at FORCECHANGE.COM, 2013 http://forcechange.com/86223/stop-drilling-and-logging-on-federal-lands-while-the-public-is-kept-out/ 52

------Timber Harvest Opposing View #79 – “"We tried for the past 18-months to work with Supervisor Bull to implement an effective community fuel reduction project up the East Fork. Our proposal - which was favored by 98% of the 13,000 public comments received on this project would have reduced fuels on 1,600 acres of national forest land, pumped $1 million into the local economy and provided 45 local jobs. Unfortunately, this common sense plan was rejected by Supervisor Bull," stated Koehler.”

“ "The attempt by Supervisor Bull to cover-up public knowledge of excessive soil damage in the project area by altering the best-available scientific data and by purging project file documents related to soils is a blatant attempt to white-wash this damaging proposal and cannot go unchallenged," explained Campbell.”

“The East Fork project area is still recovering from historic Forest Service mismanagement including clearcutting, terracing and excessive roadbuilding. 33% of the entire analysis area has already been logged. The analysis area averages 5.2 miles of road per square mile, not including jammer roads. These roads contribute 151.2 tons of sediment per year to streams within the project area. The East Fork, running through the middle of the project area, is officially classified as an impaired stream because its excessive sediment load has compromised its ecological integrity. Several watersheds already exceed established thresholds for clearcutting, which threatens stream channel stability with increased runoff.”

Conservation Groups Look to Hold Forest Service Accountable for Middle East Fork Logging Plan Published by Lowbagger, April 25, 2006 http://www.lowbagger.org/mideast.html

Note: In April of 2009, the Forest Service's Northern Region rewarded Supervisor Bull for his mismanagement of public land with a promotion to the Director of Recreation. ------

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Timber Harvest Opposing View #80 –“Photosynthesis is one of only two significant mechanisms for removing carbon dioxide from the atmosphere (the other being dissolution into water, leading to destructive ocean acidification). Carbon dioxide is released when trees are cut down, and deforestation accounts for at least 15 percent of global carbon emissions. Thus, cutting down trees is a double-whammy because we not only lose carbon capture capacity, but we release more carbon, too.

An erroneous conventional view holds that young trees capture more dioxide than mature trees; therefore, we should cut down mature trees. However, for most species -- 97 percent of 403 tropical and temperate species -- the biggest trees increase their growth rates and sequester more carbon as they age. This conclusion is based on repeated measurements of 673,046 individual trees, some going back more than 80 years, on six continents

We need all levels of government to start preserving forests -- and fast. In addition to switching from dirty to clean energy, President Obama should halt commercial logging on federal lands, eliminate biomass power plant subsidies that drive forest destruction, and permanently protect forests for carbon capture (in addition to forests' many other public benefits).”

Trees Are Our Climate Saviors - So Stop Logging on Public Land 02/12/2014 The Huffington Post http://www.huffingtonpost.com/ellen-moyer-phd/trees-are-our-climate-logging_b_4775894.html ------Timber Harvest Opposing View #81 –“Logging activities have numerous impacts on aquatic systems in the Sierra Nevada. The end result of logged landscapes is a highly altered forest system which creates significant problems related to erosion, sedimentation and altered stream flow patterns. Logging removes large trees that normally fall into streams and provide shelter and thermal cover, raises water temperatures and pH, and degrades the chemical and ecological conditions and food webs that fish need to survive. Logging and the roads created to facilitate logging also significantly degrade stream ecosystems by introducing high volumes of sediment into streams, changing natural streamflow patterns, and altering stream channel morphology. Areas that have been logged are far more likely to suffer from major landslides and erosion events which deposit abnormally high levels of sediment into area streams. Roads, ditches, and newly created gullies form new, large networks of flow paths across the landscape. These logged areas therefore, sustain much higher discharge volumes after a storm event than they ever did when the forest was intact.

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The changes in stream habitat caused by this increase in sediment loads greatly affects the health of aquatic organisms. The survival rates of many fish species are known to significantly decrease as fine sediment levels and temperatures in the water increase. The deposition of fine sediment on the stream bed degrades spawning areas, reduces pool refuge habitat, decreases winter refuge areas for juveniles, and impedes feeding visibility. Likewise, sensitive amphibian and invertebrate species are also adversely affected by increased sediment loads, decreasing in abundance and diversity as sediment levels rise. The drastic changes in the health of aquatic species brought on by logging has far reaching impacts for general forest ecology as well. Invertebrates, amphibians, and fish are important prey species for many mammals, birds and bats that are vital to the biological integrity of the forest.”

Logging Impacts Published by Sierra Forest Legacy, 2012 http://www.sierraforestlegacy.org/FC_FireForestEcology/FFE_LoggingImpacts.php ------Timber Harvest Opposing View #82 – “Natural resource use and extraction leading to habitat modification can have significant direct and indirect impacts to salmon populations. Land use activities associated with logging, road construction, urban development, mining, agriculture, and recreation have significantly altered fish habitat quantity and quality. Associated impacts of these activities include: alteration of streambanks and channel morphology;

Forestry alteration of ambient stream water temperatures; Photo: NOAA degradation of water quality; reduction in available food supply; elimination of spawning and rearing habitat; fragmentation of available habitats; elimination of downstream recruitment of spawning gravels and large woody debris; removal of riparian vegetation resulting in increased stream bank erosion; and increased sedimentation input into spawning and rearing areas resulting in the loss of channel complexity, pool habitat, suitable gravel substrate, and large woody debris. Studies indicate that in most western states, about 80 to 90 percent of the historic riparian habitat has been eliminated. Further, it has been estimated that during the last 200 years, the lower 48 United States have lost approximately 53 percent of all wetlands. Washington and Oregon's wetlands have been estimated to have been diminished by one third, while it is estimated that California has experienced a 91 percent loss of its wetland habitat. 55

Pacific Salmonids: Major Threats and Impacts Published by NOAA fisheries Office of Protecte Resources, May 15, 2014 http://www.nmfs.noaa.gov/pr/species/fish/salmon.htm ------Timber Harvest Opposing View #83 – “It is impossible to overstate the importance of humankind's clearing of the forests. The transformation of forested lands by human actions represents one of the great forces in global environmental change and one of the great drivers of biodiversity loss. The impact of people has been and continues to be profound. Forests are cleared, degraded and fragmented by timber harvest, conversion to agriculture, road-building, human-caused fire, and in myriad other ways. The effort to use and subdue the forest has been a constant theme in the transformation of the earth, in many societies, in many lands, and at most times. Deforestation has important implications for life on this planet.

Just think, originally, almost half of the United States, three-quarters of Canada, almost all of Europe, the plains of the Levant, and much of the rest of the world were forested. The forests have been mostly removed for fuel, building materials and to clear land for farming. The clearing of the forests has been one of the most historic and prodigious feats of humanity.”

“Since 1600, 90% of the virgin forests that once covered much of the lower 48 states have been cleared away. Most of the remaining old-growth forests in the lower 48 states and Alaska are on public lands. In the Pacific Northwest about 80% of this forestland is slated for logging.”

Global Deforestation Published by the University of Michigan, 01/04/2010 http://www.globalchange.umich.edu/globalchange2/current/lectures/deforest/deforest.html ------Timber Harvest Opposing View #84 –“The Forest Service’s proposed Spotted Bear logging project would jeopardize the area’s wildife, which are already teetering on the edge of survival. The project would use helicopters, ground-based equipment, and skylines to remove approximately 11 million board foot of timber across 1,853 acres of 56

pristine wildlife habitat adjacent to the Great Bear and Bob Marshall Wilderness areas. An additional 1,347 acres would be burned. Most of the units slated to be logged are mature, 75-140 year old stands of Doug-fir, western larch, spruce, and lodgepole pine that have never been logged (this area burned in the late 1800s and early 1900s). The project would require 2,200 log truckloads traveling back and forth on a narrow dirt road over 55 miles from the nearest town.

To access the remote area, the Forest Service is proposing to open 9.7 miles of roads that were closed to provide security for elk and grizzly bears and build 6.6 miles of new “temporary” roads that will be used over the next 6 years. The Forest Service also proposes to increase motorized access to the project area by extending the season of use by an additional five weeks. Motorized users will now be allowed to access the area in early June causing added trauma to the grizzlies who will have just recently emerged from their dens and will be nutrionally stressed.

“The Spotted Bear area is a critical wildlife connector”, said Keith Hammer, Chair of Swan View Coalition. “Calving elk and nutritionally stressed bears need more springtime and early summer security, not more motor vehicle traffic.” “

Groups Challenge Industrial Logging of Pristine Wildlife Habitat Along South Fork Flathead River A Western Environmental Law Center Press Release, 2/28/2012 http://www.westernlaw.org/article/groups-challenge-industrial-logging-pristine-wildlife-habitat-along-south- fork-flathead-rive ------Timber Harvest Opposing View #85 –“Four conservation groups — Alliance for the Wild Rockies, Swan View Coalition, Friends of the Wild Swan and Native Ecosystems Council — sued to halt the sale in June 2013. The groups claimed the project would harm grizzly bear, lynx, wolverine and other species and plants while damaging the forest’s remaining old growth.”

“The project area is within the designated “grizzly recovery zone” of the Northern Continental Divide Ecosystem. It is also considered critical habitat for other species listed under the ESA, including bull trout.”

“The Forest Service published its Environmental Assessment in August 2012 and concluded that the Glacier-Loon Timber Sale would have no effect on grizzly bears, Canada lynx, bull trout, bull trout critical habitat and water howellia, a threatened plant species under the ESA.”

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“The judge ordered the project be stopped and said these Forest Service lands have to be managed under federal environmental laws to protect native species just like all other national forests, Garrity said.

“It’s unfortunate that we had to once again take the federal government to court to force them to follow the law,” Garrity said. “We had no other choice if we want to conserve the last remaining habitat for bull trout, grizzly bears, lynx and other old growth dependent wildlife since the Forest Service insists on being serial law breakers.” “

Judge Halts Glacier Loon Timber Sale in Swan Valley Published in the Flathead Beacon, Sep 26, 2014 http://flatheadbeacon.com/2014/09/26/judge-halts-glacier-loon-timber-sale-swan-valley/ ------Timber Harvest Opposing View #86 –“That makes four timber projects since May in which U.S. District Judge Dana Christensen found fault with the U.S. Forest Service and the U.S. Fish and Wildlife Services' conclusion that cutting and burning in those areas would not significantly harm the big cats' territory.”

“Christensen ruled the Endangered Species Act requires the agencies to determine whether lynx "may be present" there, which is a lesser standard than what the agencies used in concluding lynx don't "occupy" the area.”

“The judge said the government approved those projects based on an unreliable conclusion they would not harm the lynx's critical habitat.”

Judge stops 3 Montana logging projects over lynx By Matt Volz, Associated Press June 26, 2013 http://news.yahoo.com/judge-stops-3-montana-logging-141919567.html ------Timber Harvest Opposing View #87 –“A federal judge has blocked logging proposed for the Klamath National Forest in Siskiyou County, chiding the U.S. Forest Service for its review of the environmental damage that would result.”

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“The service should have done a full environmental review and done a better job projecting the impact on wildlife and forest conditions, ruled U.S. District Judge Frank C. Damrell Jr.”

Judge blocks Klamath logging plan By Don Thompson,Associated Press October 16, 2004 http://www.wildcalifornia.org/media/epic-in-the-news/judge-blocks-klamath-logging-plan/ ------Timber Harvest Opposing View #88 –“The fact is, commercial logging doesn't prevent catastrophic fires; it causes them. In the latter part of the 19th century, this was common knowledge. Relentless clearing of forests in the Great Lakes region left huge areas largely devoid of the cooling shade of trees, replacing moist natural forest microclimates with the hotter, drier conditions characterized by stump fields. Flammable logging "slash debris" covered the landscape.”

It was in this setting that a massive, cataclysmic fire started near Peshtigo, Wisconsin in 1871. More than 1,200 people were killed. Similar blazes erupted in subsequent years.”

One of the primary reasons that the national forest system was established in 1891 was to prevent the destructive fires caused by logging. It was not until 1897 that, under industry pressure, our national forests were first opened up to timber sales by an appropriations rider. The first timber sale was offered in 1899--100 years ago.

“Like the timber industry, the Forest Service also recognized an emerging public relations dilemma several years ago. It knew that it would no longer be able to justify its timber sales program on economic grounds. Instead of dropping the program, it simply gave it a sexy new name--"Forest Stewardship."

The Forest Stewardship program was born in 1993 and was marketed fraudulently as a series of management activities supposedly conducted primarily for the health of the forests. The USFS attempted to distinguish this new program from its Timber Commodity program, which clearly was concerned with nothing more than commercial resource extraction.”

“In April 1999, the US General Accounting Office (GAG) released a report on the Forest Service's approach to fire management that called into serious question the use of the timber sales to address fire issues.

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The GAO noted that "most of the trees that need to be removed to reduce accumulated fuels are small in diameter and have little or no commercial value."

The report also found that Forest Service managers "tend to (1) focus on areas with high-value commercial timber rather than on areas with high fire hazards or (2) include more large, commercially valuable trees in a timber sale than are necessary to reduce the accumulated fuels." The "low value materials," observed the GAG, "are unattractive to timber purchasers." “

Hansen, Chad Ph.D., The Big Lie: Logging and Forest Fires Published by the Earth Island Journal, spring 2000 issue http://yeoldeconsciousnessshoppe.com/art6.html

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Opposing Views Attachment #4

Roads Damage the Proper Ecological Functioning of the Natural Resources in a Forest

Road Construction Opposing View #1 - “Fragmentation has been considered as one of the most major factors that lead to the decline of many wildlife species (Brittingham and Temple 1983, Yahner 1988, Winslow et al. 2000) because fragmentation tends to decrease population productivity (Robinson et al. 1995). Therefore, Meffe states that “fragmentation has become a major subject of research and debate in conservation biology” (Meffe et al. 1997, p. 272). Forest fragmentation usually occurs when large and continuous forests are divided into smaller patches as a result of road establishment, clearing for agriculture, and human development (Robinson et al. 1995, Meffe et al. 1997).” (Pg. 1)

“Generally, habitat fragmentation is an ecological process in which a large patch of habitat is divided into smaller patches of habitats. Usually, this process is caused by human activities (roads, agriculture, and logging). It also reduces the value of the landscape as habitat for many species (plants and animals). Fragmentation alters natural habitat in many ways, including reduction of patches’ sizes, increment of distances between similar patches, and increment of edges and predation (Brittingham and Temple 1983, Robinson et al. 1995).” (Pp. 2 and 3)

Al-jabber, Jabber M. 2003 “Habitat Fragmentation: Effects and Implications” http://faculty.ksu.edu.sa/a/Documents/Habitat%20Fragmentation%20Effects%20and%20Implica tion.pdf ------Road Construction Opposing View #2 - "Debris slides over a 20-year period were inventoried on 137,500 acres of forested land in the Klamath Mountains of southwest Oregon. Frequency during the study period was about one slide every 4.3 years on each 1,000 acres-an erosion rate of about 1/2 yd3 per acre per year. Erosion rates on roads and landings were 100 times those on undisturbed areas, while erosion on harvested areas was seven times that of undisturbed areas. Three-quarters of the slides were found on slopes steeper than 70 percent and half were on the lower third of slopes."

"Soil erosion rates due to debris slides were many times higher on forests with roads, landings, and logging activity than on undisturbed forests."

Amaranthus, Mike P. Ph.D., Raymond M. Rice Ph.D., N. R. Barr and R. R. Ziemer Ph.D. "Logging and forest roads related to increased debris slides in southwestern Oregon." Journal of Forestry Vol. 83, No. 4. 1985. http://www.humboldt.edu/~rrz7001/pubs/Ziemer85.PDF ------Road Construction Opposing View #3 - " ‘Roads may have unavoidable effects on streams, no matter how well they are located, designed or maintained. The sediment contribution to streams from roads is often much greater than that from all other land management activities combined, including log skidding and yarding.’ (Gibbons and Salo 1973). Research by Megahan and Kidd in 1972 found that roads built in areas with highly erosive soils can contribute up to 220 times as much sediment to streams as intact forests.”

“Applying Ecological Principles to Management of the U.S. National Forests” Issues in Ecology Number 6 Spring 2000 http://www.watertalk.org/wawa/ecosci.html ------Road Construction Opposing View #4 - “Plot-level studies have demonstrated the ability of forest roads to intercept and route both subsurface and surface overland flow more efficiently to the stream network. Significant amount of subsurface throughflow can be intercepted by the road, as a function of the road cut depth and the current saturation deficit, and then redirected, concentrating the flow in particular areas below the road. Road drainage concentration increases the effective length of the channel network and strongly influences the distribution of erosional processes. The concept of wetness index has been used in the study as a surrogate for subsurface throughflow, and the effect of forest roads on subsurface throghflow rerouting has been assessed by evaluating the changes in terms of draining upslope areas. A threshold model for shallow slope instability has been used to analyse erosional impacts of drainage modifications. In the model, the occurrence of shallow landsliding is evaluated in terms of drainage areas, ground slope and soil properties (i.e., hydraulic conductivity, bulk density, and friction angle). The model has been used to generate hypotheses about the broader geomorphic effect of roads. Modelling results have been compared with available field data collected in north-eastern Italy.”

Borga, M., F. Tonelli, G. Dalla Fontana and F. Cazorzi “Evaluating the Effects of Forest Roads on Shallow Landsliding” Geophysical Research Abstracts, Vol. 5, 13312, 2003 http://www.cosis.net/abstracts/EAE03/13312/EAE03-J-13312.pdf ------Road Construction Opposing View #5 - “A large scale land use experiment has taken place over the last 40 years in the mountainous areas of the northwestern U.S. through timber harvesting. This land use change effects the hydrology of an area through two mechanisms:

• Clear-cut logging which causes changes in the dynamics of Rain-On-Snow (ROS) events due to changes in the accumulation and ablation of snow caused by vegetation effects on snow interception and melt; and

• Construction and maintenance of forest roads which channel intercepted subsurface flow and infiltration excess runoff to the stream network more quickly.”

Bowling, L.C., D. P. Lettenmaier, M. S. Wigmosta and W. A. Perkins “Predicting the Effects of Forest Roads on Streamflow using a Distributed Hydrological Model” from a poster presented at the fall meeting of the American Geophysica Union, San Francisco, CA, December 1996. http://www.ce.washington.edu/~lxb/poster.html ------Road Construction Opposing View #6 - "American rivers and streams face destruction by sedimentation. Clearcutting, along with the vast network of logging roads, result in sedimentation and soil erosion into our national forest’s rivers and streams. Sedimentation degrades the water quality, impairs the habitat for fish and macroinvertebrates, and limits the ecosystem functions and services of streams.

By Dr. Seth Reice is Associate Professor of Biology in the Department of Biology and Curriculum in Ecology, University of North Carolina. From Press Conference with Senator Robert Torricelli, April 28, 1998, U.S. Capitol regarding the proposed Act to Save America’s Forests (S. 977, HR 1376) ------Road Construction Opposing View #7 - "Surface erosion from road surfaces, cutbanks, and ditches represents a significant and, in some landscapes, the dominant source of road-related sediment input to streams. Increased sediment delivery to streams after road building has been well documented in the research literature in the Pacific Northwest and Idaho (Bilby and others 1989, Donald and others 1996, Megahan and Kidd 1972, Reid and Dunne 1984, Rothacher 1971, Sullivan and Duncan 1981) and in the Eastern United States (Kochenderfer and others 1997, Swift 1985, 1988). Rates of sediment delivery from unpaved roads appear highest in the initial years after building (Megahan and Kidd 1972)” (pg 23)

“Roads interact directly with stream channels in a variety of ways, depending on orientation to streams (parallel, orthogonal) and landscape position (valley bottom, midslope, ridge). The geomorphic consequences of these interactions, particularly during storms, are potentially significant in terms of erosion rates, direct and off-site effects on channel morphology, and drainage network structure, but they are complex and often poorly understood.” (pg 24)

“Findings: Habitat loss has broader effects than just the conversion of a small area of land to road surfaces. Roads fragment by changing landscape structure and by directly and indirectly affecting species. Habitat effects of roads on the landscape include dissecting vegetation patches, increasing the edge-affected area and decreasing interior area, and increasing the uniformity of patch characteristics, such as shape and size (Reed and others 1996). Whenever forest roads are built, changes in habitat and modified animal behavior will lead to changes in wildlife populations (Lyon 1983).” (pgs 30 and 31)

“The effects of roads are not limited to those associated with increases in fine-sediment delivery to streams; they can include barriers to migration, water temperature changes, and alterations to streamflow regimes.” (pg 34)

“Findings: Roads contribute more sediment to streams than any other land management activity (Gibbons and Salo 1973, Meehan 1991), but most land management activities, such as mining, timber harvest, grazing, recreation, and water diversions depend on roads. Most of the sediment from timber harvest activities is related to roads and road building (Dunne and Leopold 1978, Megahan and others 1978, MacDonald and Ritland 1989, Chamberlain and others 1991, Furniss and others 1991) and the associated increases in erosion rates (Swanson and Dyrness 1975, Swanston and Swanson 1976, Beschta 1978, Gardner 1979, Reid and Dunne 1984, Meehan 1991, Reid 1993, Rhodes and others 1994).” (pg 36)

Forest Service Roads: A Synthesis of Scientific Information, June, 2000

Edited by: Hermann Gucinski, Pacific Northwest Research Station Corvallis, OR Michael J. Furniss, Rocky Mtn Res. Station, Stream SystemsTechnology Center, Fort Collins, CO. Robert R. Ziemer, Pacific Southwest Research Station, Arcata, CA Martha H. Brookes, Pacific Northwest Research Station, Portland

https://www.fs.fed.us/eng/road_mgt/science.pdf ------Road Construction Opposing View #8 - "Sediment input to freshwater is due to either the slower, large-scale process of soil erosion, or to rapid, localized “mass movements,” such as landslides. Forest practices can increase the rate at which both processes occur. Most sediment from forestry arises from landslides from roads and clearcuts on steep slopes, stream bank collapse after riparian harvesting, and soil erosion from logging roads and harvested areas. Roads, particularly those that are active for long periods of time, are likely the largest contributor of forestry-induced sediment (Furniss et al. 1991)."

"Sediment can increase even when roads comprise just 3% of a basin (Cederholm et al. 1981)."

"More than half the species present in the study area will likely be negatively impacted by sedimentation from logging roads."

"In areas made highly turbid (cloudy) from sedimentation, the foraging ability of adults and juveniles may be inhibited through decreased algal production and subsequent declines in insect abundance, or, for visual-feeding taxa dependent on good light, through their inability to find and capture food. Highly silted water may damage gill tissue and cause mortality or physiological stress of adults and juveniles."

Bunnell, Fred L. Ph.D., Kelly A. Squires and Isabelle Houde. 2004 "Evaluating effects of large-scale salvage logging for mountain pine beetle on terrestrial and aquatic vertebrates." Mountain Pine Beetle Initiative Working Paper 1. Canadian Forest Service. http://warehouse.pfc.forestry.ca/pfc/25154.pdf ------Road Construction Opposing View #9 - "The road construction and right-of-way logging were immediately detrimental to most aquatic invertebrates in South Fork Caspar Creek"

"Salmonid populations decreased immediately after the road construction."

"Sustained logging and associated road construction over a period of many years do not afford either the stream or the 'fish population a chance to recover."

Burns, James W., "Some Effects of Logging and Associated Road Construction on Northern California Streams." Transactions of the American Fisheries Society, Volume 1, Number 1, January 1972. http://www.fs.fed.us/psw/publications/4351/Burns72.pdf ------Road Construction Opposing View #10 – “Road construction in the steep, often unstable terrain of Oregon's mountains is both, difficult and hazardous. It is also costly, both in terms of direct construction and damage to the aquatic environment. We know that in Oregon, forest roads are our greatest source of problems with mass soil movement ( Brown and, Krygier, 1971;Fredriksen, 1970; Dyrness, 1967 ). Yet we do not understand the processes well enough to be able to predict with reasonable certainty where road failures will occur or how alternative road designs will affect mass movements except in the most obvious places.”

Brown, George W. Ph.D., The Impact of Timber Harvest on Soil and Water Resources Dr. BROWN is the Forest Hydrologist, School of Forestry, Oregon State University http://andrewsforest.oregonstate.edu/pubs/pdf/pub1695.pdf ------Road Construction Opposing View #11 - “Forested watersheds typically release clean water, yet forest roads and trails can drastically impact water quality. Increased stream sedimentation from road and skid trail crossings represent the most significant water quality threat associated with forestry operations.”

From Forest Roads and Sediment Project PROJECT DURATION:1 January 2011 to 30 November 2019 Published by Virginia Tech University By W. Mike Aust,Ph.D., Kevin McGuire, Ph.D., M. Chad Bolding, Ph.D. and Scott Barrett, Ph.D. http://hydro.vwrrc.vt.edu/research/projects/forest-roads-and-sediment-project/ ------Road Construction Opposing View #12 - "Roads often cause serious ecological impacts. There are few more irreparable marks we can leave on the land than to build a road."

Dombeck, Mike Ph.D., US Forest Service Chief, 1997-2001 Remarks made to Forest Service employees and retirees at the University of Montana. February 1998. https://www.uwsp.edu/cnr/gem/Dombeck/MDSpeeches/CD%20COPY/Chief%20Mike%20Domb eck%27s%20Remarks%20to%20Forest%20Service%20Employees%20and%20.htm ------Road Construction Opposing View #13 - "Few marks on the land are more lasting than roads."

"The negative effects on the landscape of constructing new roads, deferring maintenance, and decommissioning old roads are well documented. Unwanted or non- native plant species can be transported on vehicles and clothing by users of roads, ultimately displacing native species. Roads may fragment and degrade habitat for wildlife species and eliminate travel corridors of other species. Poorly designed or maintained roads promote erosion and landslides, degrading riparian and wetland habitat through sedimentation and changes in streamflow and water temperature, with associated reductions in fish habitat and productivity. Also, roads allow people to travel into previously difficult or impossible to access areas, resulting in indirect impacts such as ground and habitat disturbance, increased pressure on wildlife species, increased litter, sanitation needs and vandalism, and increased frequency of human-caused fires."

EPA entry into the Federal Register: March 3, 2000 (Volume 65, Number 43) Page 11675, "National Forest System Road Management." https://www.federalregister.gov/documents/2000/03/03/00-5002/national-forest-system-road- management ------Road Construction Opposing View #14 - “Fragmentation caused by roads is of special interest because the effects of roads extend tens to hundreds of yards from the roads themselves, altering habitats and water drainage patterns, disrupting wildlife movement, introducing exotic plant species, and increasing noise levels. The land development that follows roads out into rural areas usually leads to more roads, an expansion process that only ends at natural or legislated barriers.”

“Forest Fragmentation and Roads” Eastern Forest Environmental Threat Assessment Center U.S. Forest Service - Southern Research Station http://www.forestthreats.org/publications/su-srs-018/fragmentation ------Road Construction Opposing View #15 - “A huge road network with vehicles ramifies across the land, representing a surprising frontier of ecology. Species-rich roadsides are conduits for few species. Roadkills are a premier mortality source, yet except for local spots, rates rarely limit population size. Road avoidance, especially due to traffic noise, has a greater ecological impact. The still-more-important barrier effect subdivides populations, with demographic and probably genetic consequences. Road networks crossing landscapes cause local hydrologic and erosion effects, whereas stream networks and distant valleys receive major peak-flow and sediment impacts. Chemical effects mainly occur near roads. Road networks interrupt horizontal ecological flows, alter landscape spatial pattern, and therefore inhibit important interior species. Thus, road density and network structure are informative landscape ecology assays. Australia has huge road-reserve networks of native vegetation, whereas the Dutch have tunnels and overpasses perforating road barriers to enhance ecological flows. Based on road-effect zones, an estimated 15–20% of the United States is ecologically impacted by roads.”

Forman, Richard T. and Lauren E. Alexander “Roads and their Major Ecological Effects” Annual Review of Ecology and Systematics, Vol. 29: 207-231, November 1998 http://arjournals.annualreviews.org/doi/abs/10.1146/annurev.ecolsys.29.1.207?cookieSet=1&jou rnalCode=ecolsys.1 ------Road Construction Opposing View #16 - “Questions to consider: Roads dramatically alter forest ecosystems

1. Does the management prescription account for the ecological effects of the road construction and maintenance activities associated with carrying out such activities?

2. Have alternatives to road building been considered? How does the plan attempt to address the effects of roads?” (page 37)

Franklin, Jerry Ph.D., David Perry Ph.D., Reed Noss Ph.D., David Montgomery Ph.D. and Christopher Frissell Ph.D. 2000. "Simplified Forest Management to Achieve Watershed and Forest Health: A Critique." A National Wildlife Federation publication sponsored by the Bullitt Foundation http://www.coastrange.org/documents/forestreport.pdf ------Road Construction Opposing View #17 - “The authors warned that cutting roads into current roadless areas could bring much more harm to wildlife, soil and fisheries than the beetle-killed trees pose to the forest.”

Frey, David “Logging Won’t Halt Beetles, Fire, Report Says” NewWest.net, 3-03-10 http://www.newwest.net/topic/article/logging_wont_halt_beetles_fire_report_says/C41/L41/ ------Road Construction Opposing View #18 - "Rarely can roads be designed and built that have no negative impacts on streams. Roads modify natural drainage patterns and can increase hillslope erosion and downstream sedimentation. Sediments from road failures at stream crossings are deposited directly into stream habitats and can have both on-site and off-site effects. These include alterations of the channel pattern or morphology, increased bank erosion and changes in channel width, substrate composition, and stability of slopes adjacent to the channels."

"All of these changes result in important biological consequences that can affect the entire stream ecosystem. One specific example involves anadromous salmonids, such as salmon and steelhead, that have complex life histories and require suitable stream habitat to support both juvenile and adult life stages."

"A healthy fishery requires access to suitable habitat that provides food, shelter, spawning gravel, suitable water quality, and access for upstream and downstream migration. Road-stream crossing failures have direct impacts on all of these components."

Furniss, Michael J., Michael Love Ph.D. and Sam A. Flanagan "Diversion Potential at Road-Stream Crossings." USDA Forest Service. 9777 1814—SDTDC. December 1997. http://www.stream.fs.fed.us/water-road/w-r-pdf/diversionpntl.pdf ------Road Construction Opposing View #19 - “Barry Noon, a professor of wildlife ecology at Colorado State University, noted that scientific research has consistently shown the adverse effects of roads on hydrologic processes and fish and wildlife populations.

“ “One of the key things to recognize is the effects of the roads extend far beyond their immediate footprint,” Noon said. For example, “in terms of hydrology, the roads are leading to faster runoff of water, often with great increases in sedimentation, particularly following storm events, and roads in watersheds often lead to increases in the intensity of floods.” “

These changes degrade fish habitat because of the increased sedimentation that leads to decreases in water quality, Noon said. And roads fragment wildlife habitat and create areas that animals avoid, often as result of increased hunting, he said.”

Gable, Eryn “Battling beetles may not reduce fore risks – report” Land Letter, March 4, 2010 http://www.xerces.org/2010/03/04/battling-beetles-may-not-reduce-fire-risks-report/ ------Road Construction Opposing View #20 - "Roads and skid trails have been identified as a major contributor to increased turbidity of water draining logging areas resulting in increases from 4 to 93 parts per million (Hoover, 1952). Forest roads have been found to have erosion rates from one to three orders of magnitude greater than similar undisturbed areas (Megahan, 1974) and perhaps account for as much as 90 percent of all forest erosion (Megahan, 1972). Forest roads can also cause soil erosion and stream sedimentation, which adversely impact on the nation’s water quality (Authur et al., 1998).

Grace, Johnny M. III Ph.D. 2003. "Minimizing the impacts of the forest road system." In: Proceedings of the conference 34 international erosion control association; ISSN 1092-2806. [Place of publication unknown]: International Erosion Control Association: 301-310. http://www.srs.fs.usda.gov/pubs/ja/ja_grace011.pdf ------Road Construction Opposing View #21 - "Roads have well-documented, short- and long-term effects on the environment that have become highly controversial, because of the value society now places on unroaded wildlands and because of wilderness conflicts with resource extraction."

"(Road) consequences include adverse effects on hydrology and geomorphic features (such as debris slides and sedimentation), habitat fragmentation, predation, road kill, invasion by exotic species, dispersal of pathogens, degraded water quality and chemical contamination, degraded aquatic habitat, use conflicts, destructive human actions (for example, trash dumping, illegal hunting, fires), lost solitude, depressed local economies, loss of soil productivity, and decline in biodiversity."

Gucinski, Hermann Ph.D., Michael J. Furniss, Robert R. Ziemer Ph.D. and Martha H. Brookes, Editors. 2001. "Forest Roads: A Synthesis of Scientific Information." USDA Forest Service, General Technical Report PNW-GTR-509. http://www.fs.fed.us/pnw/pubs/gtr509.pdf ------Road Construction Opposing View #22 - "Fires in the roaded areas are more intense, due to drier conditions, wind zones on the foothill/valley interface, high surface-fuel loading, and dense stands."

Hann, W.J. et al. 1997 Landscape dynamics of the Basin. Pp. 337-1,055 in: Quigley, T.M. and S.J. Arbelbide (eds.) An Assessment of Ecosystem Components in the Interior Columbia Basin and Portions of the Klamath and Great Basins: Volume II. USDA Forest Service, PNW-GTR-405 http://www.fs.fed.us/pnw/pubs/gtr405/pnw_gtr405aa.pdf ------Road Construction Opposing View #23 - “Many forested landscapes are fragmented by roads, but our understanding of the effects of these roads on the function and diversity of the surrounding forest is in its infancy. I investigated the effect of roads in otherwise continuous forests on the macroinvertebrate fauna of the soil. I took soil samples along transects leading away from the edges of unpaved roads in the Cherokee National Forest in the Southern Appalachian mountains of the United States. Roads significantly depressed both the abundance and the richness of the macroinvertebrate soil fauna. Roads also significantly reduced the depth of the leaf- litter layer. These effects persisted up to 100 m into the forest. Wider roads and roads with more open canopies tended to produce steeper declines in abundance, richness, and leaf-litter depth, but these effects were significant only for canopy cover and litter depth. The macroinvertebrate fauna of the leaf litter plays a pivotal role in the ability of the soil to process energy and nutrients. These macroinvertebrates also provide prey for vertebrate species such as salamanders and ground-foraging birds. The effect of roads on the surrounding forest is compounded by the sprawling nature of the road system in this and many other forests. My data suggest that even relatively narrow roads through forests can produce marked edge effects that may have negative consequences for the function and diversity of the forest ecosystem.”

Haskell, David G. Ph.D. 1999 “Effects of Forest Roads on Macroinvertebrate Soil Fauna of the Southern Appalachian Mountains” http://www.jstor.org/stable/2641904 ------Road Construction Opposing View #24 - “Roads remove habitat, alter adjacent areas, and interrupt and redirect ecological flows. They subdivide wildlife populations, foster invasive species spread, change the hydrologic network, and increase human use of adjacent areas. At broad scales, these impacts cumulate and define landscape patterns.”

Hawbaker, Todd J. Ph.D., Volker C. Radeloff Ph.D., Murray K. Clayton Ph.D., Roger B. Hammer Ph.D., and Charlotte E. Gonzalez-Abraham Ph.D. “Road Development, Housing Growth, and Landscape Fragmentation In Northern Wisconsin: 1937–1999” Ecological Applications: Vol. 16, No. 3, pp. 1222-1237. http://www.esajournals.org/doi/abs/10.1890/1051- 0761%282006%29016%5B1222%3ARDHGAL%5D2.0.CO%3B2?journalCode=ecap ------Road Construction Opposing View #25 - “Last winter was unusually wet in the Pacific Northwest. The result was landslides all over caused by logging roads; five people died, spawning streams were ruined, water supplies were contaminated and the flooding was tremendously aggravated. According to David Bayles, conservation director of the Pacific Rivers Council, aerial surveys documented more than 650 landslides in February in Washington and Oregon alone. The stupidest and most dangerous practice is allowing logging roads on steep slopes — that's really asking for it.

You may ask yourself why the taxpayers are expected to pony up to build roads for profitable logging companies. Build roads for the timber companies in order to stimulate the U.S. logging, paper and building industries. There's just one problem. A lot of U.S. logs get shipped overseas, mostly to Japan. We're actually subsidizing Japanese companies while doing terrible damage to our environment and not helping the U.S. job scene much except when it comes to cutting

Start with the assumption that the U.S. Forest Service a component of the Department of Agriculture, is simply an auxiliary branch of the timber industry and you'll pretty much have the picture of what's going on. Last winter, the Forest Service refused a bid at a timber auction from an environmentalist who wanted to save, not harvest, a stand of evergreens in the Okanogan National Forest in Washington. Instead, the Forest Service accepted a bid of $15,000 from a logging company that cut 3.5 million board- feet of lumber in that stand. Try to find a price like that at Home Depot.”

Ivins, Molly Creators Syndicate, August 3 1997 08 03 http://www.creators.com/opinion/molly-ivins/molly-ivins-august-3-1997-08-03.html ------Road Construction Opposing View #26 - "Although disturbance patches are created by peak flow and debris flow disturbances in mountain landscapes without roads, roads can alter the landscape distributions of the starting and stopping points of debris flows, and they can alter the balance between the intensity of flood peaks and the stream network's resistance to change."

Jones, Julia A. Ph.D., Frederick J. Swanson Ph.D. Beverley C. Wemple Ph.D., and Kai U. Snyder. "Effects of roads on hydrology, geomorphology, and disturbance patches in stream networks." Conservation Biology 14, No. 1. 2000. http://www.jstor.org/stable/2641906 ------Road Construction Opposing View #27 - "In the Pacific Northwest, the two main processes that contribute to sediment production are mass failure and surface erosion from forest roads (Fredriksen 1970, Reid and Dunne 1984). In the Clearwater River basin in the State of Washington, as much as 40 percent of the sediment produced in the watershed was attributed to logging roads (Reid 1980)."

Kahklen, Keith. "A Method for Measuring Sediment Production from Forest Roads." Pacific Northwest Research Station, USDA Forest Service. Research note PNW-RN-529, April 2001. http://www.fs.fed.us/pnw/pubs/rn529.pdf ------Road Construction Opposing View #28 - "It is indisputable that roads are one of the greatest threats to the ecological integrity of forested systems and associated river, wetland, lake, and coastal ecosystems. Yet, the USFS has failed to adopt a policy that mandates reversing the worst ecological effects of roads, or that precludes incursion of roads into roadless areas. Despite widespread recognition of these facts, the USFS diverts staff and money to extraordinarily costly salvage logging projects at the expense of reducing the extent of the road network or undertaking needed fine-fuels reductions in unburned forests."

Karr, James R. Ph.D., Christopher A. Frissell Ph.D., Jonathan J. Rhodes, David L. Perry Ph.D. and G. Wayne Minshall Ph.D. Excerpt from a letter to the Subcommittee on Forests & Forest Health U.S. House of Representatives. 3 July, 2002. http://www.nativeforest.org/campaigns/wildfire_info_center/letter_from_beschta.htm ------Road Construction Opposing View #29 - “Forest fragmentation, as scientists call the intentional felling of woodland, is actually two processes. In populated areas such as the Atlantic seaboard, it means reduction in the size of forest tracts, usually due to suburbanization and development. In less inhabited areas--northern New England, for example--forest fragmentation refers to isolation of one patch of forest from another by logging, or by the building of roads or power lines.”

Lawren, Bill 1992 “Singing the Blues for Songbirds: Bird lovers lament as experts ponder the decline of dozens of forest species” National Wildlife http://www.nwf.org/News-and-Magazines/National-Wildlife/Birds/Archives/1992/Singing-the- Blues-for-Songbirds.aspx ------Road Construction Opposing View #30 - "The compaction of forest road soils is known to reduce aeration, porosity, infiltration rates, water movement, and biological activity in soils. Research indicates that soil bulk density, organic matter, moisture, and litter depths are much lower on roads than on nearby forest lands. Macropores, which provide soil drainage and infiltration, have been shown to significantly decrease in size as a result of road construction and use. Reduced infiltration and increased compaction promote soil erosion, especially during the seasonal southwestern monsoon rains (Elseroad 2001)."

"Physical disturbances caused by road construction and vehicle use create ideal conditions for colonization by invasive exotic plant species. The use of roads by vehicles, machinery, or humans often aids the spread of exotic plant seeds. Once established, they can have long-term impacts on surrounding ecosystems and can be difficult to remove."

"Roads are known to cause habitat fragmentation. Many create ecological 'edges' with different plant species, light levels, and hiding cover, all of which may alter animal survival, reproductive success, and movement patterns. The introduction of exotic plants can disrupt the availability of native vegetation used by wildlife for food and shelter (Trombulak and Frissell 1999)."

"Forest roads often develop a water-repellent soil layer caused by lack of vegetative cover and changes in soil composition. This can substantially influence how runoff is processed. Erosion, the formation of water channels beside the road, and increased sediment loads in nearby streams are common results of this process (Baker 2003)."

"Because they provide easier access to many forest tracts, forest roads often allow more human-caused fires to be ignited."

Lowe, Kimberly Ph.D.,"Restoring Forest Roads." A Northern Arizona University Ecological Restoration Institute publication Working Paper 12. June, 2005. http://www.eri.nau.edu/en/information-for-practitioners/restoring-forest-roads ------Road Construction Opposing View #31 - "Almost everywhere people live and work they build and use unimproved roads, and wherever the roads go, a range of environmental issues follows."

"Among the environmental effects of unimproved roads, those on water quality and aquatic ecology are some of the most critical. Increased chronic sedimentation, in particular, can dramatically change the food web in affected streams and lakes."

"The nearly impervious nature of road surfaces (or treads) makes them unique within forested environments and causes runoff generation even in mild rainfall events, leading to chronic fine sediment contributions."

"If we look at the issue of what we need to learn or the research priorities for forest road hydrology, I would argue that the areas of cutslope hydrology and effectiveness of restoration efforts are perhaps most critical."

"At a few sites in the mountains of Idaho and Oregon a substantial portion of the road runoff (80–95%) came from subsurface flow intercepted by the cutslope (Burroughs et al., 1972; Megahan, 1972; Wemple, 1998)."

Luce, Charles H. Ph.D., 2002. "Hydrological processes and pathways affected by forest roads: what do we still need to learn?" Hydrologic Processes: 16, 2901–2904. http://www.fs.fed.us/rm/boise/teams/soils/Publications/Luce%202002%20HP.pdf ------Road Construction Opposing View #32 - "Roads in the watershed contribute to sediment production by concentrating runoff, thereby increasing sediment load to the stream network. Most unimproved (dirt) roads connect either directly or indirectly with streams and, therefore, act as extensions of stream networks by effectively increasing watershed drainage density and subsequently sediment loads to streams. In the South Fork subwatershed of Squaw Creek, road connectivity has resulted in an increase in effective drainage density of approximately 250%. Throughout the Squaw Creek watershed, it is estimated that dirt roads potentially contribute as much as 7,793 metric tons/year to the watershed sediment budget."

Maholland, Becky and Thomas F. Bullard Ph.D., "Sediment-Related Road Effects on Stream Channel Networks in an Eastern Sierra Nevada Watershed." Journal of the Nevada Water Resources Association, Volume 2, Number 2, Fall 2005. http://www.nvwra.org/docs/journal/vol_2_no_2/NWRAjournal_fall2005_article4.pdf ------Road Construction Opposing View #33 - “One of the greatest impacts of roads and (especially motorized) trails is their effect on the hydrology of natural landscapes, including the flow of surface and ground water and nutrients. These hydrologic effects are responsible for changes to geomorphic processes and sediment loads in roaded areas (Luce and Wemple 2001).” (pg. 12)

Malecki, Ron W. “A New Way to Look at Forest Roads: the Road Hydrologic Impact Rating System (RHIR)” The Road-RIPorter, Autumn Equinox, 2006 http://www.wildlandscpr.org/files/uploads/RIPorter/rr_v11-3.pdf ------Road Construction Opposing View #34 - "A study was made on 344 miles of logging roads in northwestern California to assess sources of erosion and the extent to which road-related erosion is avoidable. At most, about 24 percent of the erosion measured on the logging roads could have been prevented by conventional engineering methods. The remaining 76 percent was caused by site conditions and choice of alignment. On 30,300 acres of commercial timberland, an estimated 40 percent of the total erosion associated with management of the area was found to have been derived from the road system."

McCashion, J. D. and R. M. Rice Ph.D. 1983. "Erosion on logging roads in northwestern California: How much is avoidable?" Journal of Forestry 8(1): 23-26. http://www.fs.fed.us/psw/rsl/projects/water/McCashion.pdf ------Road Construction Opposing View #35 - "Research has shown that roads can have adverse impacts on the water quality on the forest landscape (Authur et al. 1998; Binkley and Brown 1993; Megahan et al. 1991). The forest road system has been identified by previous research as the major source of soil erosion on forestlands (Anderson et. al 1976; Patric 1976; Swift 1984; Van Lear et al. 1997). Furthermore, roads are cited as the dominant source of sediment that reaches stream channels (Packer 1967; Trimble and Sartz 1957; Haupt 1959)."

McFero III, Grace, J. "Sediment Plume Development from Forest Roads: How are they related to Filter Strip Recommendations?" An ASAE/CSAE Meeting Presentation, Paper Number: 045015, August 1-4, 2004. http://www.srs.fs.usda.gov/pubs/ja/ja_grace017.pdf ------Road Construction Opposing View #36 - “Overall, roads had a greater impact on landscape structure than logging in our study area. Indeed, the 3-fold increase in road density between 1950–1993 accounted for most of the changes in landscape configuration associated with mean patch size, edge density, and core area.”

McGarigal, Kevin Ph.D., William H. Romme Ph.D. Michele Crist Ph.D.and Ed Roworth Ph.D. “Cumulative effects of roads and logging on landscape structure in the San Juan Mountains, Colorado (USA)” Landscape Ecology, Volume 16, Number 4 / May, 2001 http://www.springerlink.com/content/w12557624742tv77/ ------Road Construction Opposing View #37 - “Road construction in remote areas appears to be the major long term impact of resource extraction industries and the most significant problem facing grizzly bears in most locations. Open roads are an influence in all 5 ways that people affect bears. Vehicles on roads can harass bears, displace them from quality habitats, and cause reduced bear use of altered habitats, such as cutting units. Bears that are displaced from roads may cause social disruption in areas away from roads. Finally, roads permit access for many people and some of these will shoot bears.” (Pg. 62)

McLellan, Bruce N. “Relationships between Human Industrial Activity and Grizzly Bears” Bears: Their Biology and Management, Vol. 8 International Conference on Bear Research and Management February 1989 (1990), pp. 57-64 http://www.bearbiology.com/fileadmin/tpl/Downloads/URSUS/Vol_8/McClellan_8.pdf ------Road Construction Opposing View #38 - “Erosion from forest roads can be a large source of sediment in watersheds managed for timber production.”

Megahan, Walter F. Ph.D. “Predicting Road Surface Erosion from Forest Roads in Washington State” from a presentation presented at the 2003 Geological Society of America meeting. http://gsa.confex.com/gsa/2003AM/finalprogram/abstract_67686.htm ------Road Construction Opposing View #39 - “Today, addressing the adverse impacts of forest roads is consistently identified as one of the highest watershed restoration priorities in U.S. forests—in many forested watersheds in the western United States there is a greater road density than stream density. It is simply irrational to spend millions of dollars subsidizing further forest road construction when we are simultaneously spending millions of dollars to offset detrimental effects associated with similar actions in the past.”

Montgomery, David Ph.D., Statement at a Press Conference with Senator Robert Torricelli about S. 977 and HR 1376), the Act to Save America’s Forests April 28, 1998, U.S. Capitol http://www.saveamericasforests.org/news/ScientistsStatement.htm ------Road Construction Opposing View #40 - “Nothing is worse for sensitive wildlife than a road. Over the last few decades, studies in a variety of terrestrial and aquatic ecosystems have demonstrated that many of the most pervasive threats to biological diversity - habitat destruction and fragmentation, edge effects, exotic species invasions, pollution, and overhunting - are aggravated by roads. Roads have been implicated as mortality sinks for animals ranging from snakes to wolves; as displacement factors affecting animal distribution and movement patterns; as population fragmenting factors; as sources of sediments that clog streams and destroy fisheries; as sources of deleterious edge effects; and as access corridors that encourage development, logging and poaching of rare plants and animals.”

"Most public agencies disregard the ecological impacts of roads, and attempt to justify timber roads as benefiting recreation and wildlife management. Even when a land manager recognizes the desirability of closing roads, he or she usually contends that such closures would be unacceptable to the public."

“The Forest Service and other public agencies will claim that road closures, revegetation, and other restorative measures are too expensive to be implemented on a broad scale. But much of the approximately $400 million of taxpayers' money squandered annually by the Forest Service on below-cost timber sales goes to road- building. Road maintenance is also expensive. Virtually all of this money could be channeled into road closures and associated habitat restoration. This work would be labor-intensive, and providing income to the many laid off loggers, timber sale planners, and road engineers -- for noble jobs, rather than jobs of destruction!”

Noss, Reed F., Ph.D. 1995. “The Ecological Effects of Roads or the Road to Destruction” Wildlands CPR http://www.wildlandscpr.org/ecological-effects-roads ------Road Construction Opposing View #41 - “Numerous studies have reported lower densities of breeding Ovenbirds (Seiurus aurocapillus) adjacent to forest edges. However, none of these studies has considered habitat use and reproductive success to address mechanisms underlying the observed pattern, and most were conducted in fragmented landscapes and ignored juxtapositions of forest with narrow openings such as roads. We studied the influence of forest roads on Ovenbird density in an extensively forested region of Vermont, evaluating habitat use and reproductive success relative to mechanisms proposed to explain the density-edge relationship. Territory densities on seven study plots were 40% lower within edge areas (0 to 150 m from unpaved roads) than within interior areas (150 to 300 m from roads). We simulated the distribution of Ovenbird territories and concluded that passive displacement, where birds perceive habitat interfaces as boundaries and limit their territories entirely to forest habitat, did not account for the observed density-edge pattern. Territory size was inversely related to distance from roads, providing an alternative explanation for reduced densities near edges and suggesting that habitat quality was higher away from roads. Pairing success was lower within edge areas than within interior zones, but the difference was not statistically significant. The proportion of males that produced fledglings did not differ between edge and interior areas. We conclude that habitat quality for Ovenbirds may be lower within 150 m of unpaved roads in extensive forested landscapes, affecting territory density and possibly reproductive success.”

Ortega, Yvette K.; Capen, David E. 1999. “Effects of forest roads on habitat quality for Ovenbirds in a forested landscape” Auk. 116(4): 937-946. http://www.fs.fed.us/rm/pubs_other/rmrs_1999_ortega_y001.html ------Road Construction Opposing View #42 - “Increasingly, previously extensive, continuous tracts of forest are being reduced to widely dispersed patches of remnant forest vegetation by logging and road-building, but few measures of the effects of roads on forest fragmentation are available. Fragmentation affects animal populations in a variety of ways, including decreased species diversity and lower densities of some animal species in the resulting smaller patches. This study seeks to quantify the effects of roads and logging activities on forest habitat.”

“Roads precipitate fragmentation by dissecting previously large patches into smaller ones, and in so doing they create edge habitat in patches along both sides of the road, potentially at the expense of interior habitat. As the density of roads in landscapes increases, these effects increase as well. McGurk and Fong (1995) considered the additive effects of clearcuts and roads, but did not measure the amount of associated edge habitat. Thus a more direct measurement of the impacts of roads on landscapes is needed.”

Reed, R.A., Johnson-Barnard, J., and Baker, W.A. 1996. "Contribution of Roads to Forest Fragmentation in the Rocky Mountains." Conservation Biology 10: 1098-1106. http://cpluhna.nau.edu/Research/contribution_of_roads_to_forest_.htm ------Road Construction Opposing View #43 - “Erosion on roads is an important source of fine-grained sediment in streams draining logged basins of the Pacific Northwest. Runoff rates and sediment concentrations from 10 road segments subject to a variety of traffic levels were monitored to produce sediment rating curves and unit hydrographs for different use levels and types of surfaces. These relationships are combined with a continuous rainfall record to calculate mean annual sediment yields from road segments of each use level. A heavily used road segment in the field area contributes 130 times as much sediment as an abandoned road. A paved road segment, along which cut slopes and ditches are the only sources of sediment, yields less than 1% as much sediment as a heavily used road with a gravel surface.”

Reid, L. M. Ph.D. and T. Dunne (1984), “Sediment Production from Forest Road Surfaces,” Water Resour. Res., 20(11), 1753–1761. http://www.agu.org/pubs/crossref/1984/WR020i011p01753.shtml ------Road Construction Opposing View #44 - "Roads are associated with high sediment inputs and altered hydrology, both of which can strongly influence downstream channel habitats. Roads are also important as a source of indirect human impacts and as an agent of vegetation change and wildlife disturbance."

"Any ground disturbance increases the potential for erosion and hydrologic change, and roads are a major source of ground disturbance in wildlands. Compacted road surfaces generate overland flow, and much of this flow often enters the channel system, locally increasing peak flows. Localized peak flows are also increased where roads divert flow from one swale into another, and where roadcuts intercept subsurface flows."

"Overland flow from the road surface is a very effective transport medium for the abundant fine sediments that usually are generated on road surfaces. Road drainage also can excavate gullies and cause landslides downslope in swales. Cut and fill slopes are often susceptible to landsliding, and road-related landsliding is the most visible forestry-related erosional impact in many areas."

Reid, Leslie M. Ph.D., Robert R. Ziemer Ph.D., and Michael J. Furniss 1994. "What do we know about Roads?" USDA Forest Service. http://www.fs.fed.us/psw/publications/reid/4Roads.htm ------Road Construction Opposing View #45 - "Disturbances from roadbuilding and logging changed the sediment/discharge relationship of the South Fork from one which was supply dependent to one which was stream power dependent, resulting in substantial increases in suspended sediment discharges."

"Road construction and logging appear to have resulted in increases in average turbidity levels (as inferred from suspended sediment increases) above those permitted by Regional Water Quality Regulations."

Rice, Raymond M. Ph.D., Forest B. Tilley and Patricia A. Datzman. 1979. "Watershed's Response to Logging and Roads: South Fork of Caspar Creek, California, 1967-1976." USDA Forest Service, Research Paper PSW-146. http://www.fs.fed.us/psw/publications/rice/Rice79.pdf ------Road Construction Opposing View #46 - "Sediment eroded from gravel roads can be a major component of the sediment budget in streams in this region (Van Lear, et al, 1995)."

Riedel, Mark S. Ph.D. and James M. Vose Ph.D., "Forest Road Erosion, Sediment Transport and Model Validation in the Southern Appalachians." Presented at the Second Federal Interagency Hydrologic Modeling Conference, July 28 – August 1, 2002. http://www.srs.fs.usda.gov/pubs/ja/ja_riedel002.pdf ------Road Construction Opposing View #47 - “Early studies of elk were among the first to address effects of roads on wildlife, establishing a precedent for subsequent research on a wide range of terrestrial and aquatic species. These early elk-roads studies included those reported in a symposium on the topic in 1975 (Hieb 1976), the seminal studies of Jack Lyon in Montana and northern Idaho (Lyon 1979, 1983, 1984), the Montana Cooperative Elk-Logging Study (Lyon et al. 1985), and work by Perry and Overly (1977) in Washington and Rost and Bailey (1979) in Colorado.

As research and analysis techniques have become more sophisticated, particularly with the advent of geographic information systems (GIS) and high-resolution remote imagery, the study of effects of roads on terrestrial and aquatic communities has evolved into a unique discipline of “road ecology” (Forman et al. 2003). Road effects are far more pervasive than originally believed and include such disparate consequences as population and habitat fragmentation, accelerated rates of soil erosion, and invasion of exotic plants along roadways. Indeed, “in public wildlands management, road systems are the largest human investment and the feature most damaging to the environment” (Gucinski et al. 2001:7). Summaries of the effects of roads on wildlife habitats and biological systems in general have been compiled by Forman and Alexander (1998), Trombulak and Frissell (2000), Gucinski et al. (2001), Forman et al. (2003) and Gaines et al. (2003).”

Rowland, M. M., M. J. Wisdom, B. K. Johnson, and M. A. Penninger 2005. “Effects of Roads on Elk: Implications for Management in Forested Ecosystems.” Pages 42-52 in Wisdom, M. J., technical editor, The Starkey Project: a synthesis of long-term studies of elk and mule deer Reprinted from the 2004 Transactions of the North American Wildlife and Natural Resources Conference, Alliance Communications Group. http://www.fs.fed.us/pnw/pubs/journals/pnw_2004_rowland001.pdf ------Road Construction Opposing View #48 - “The consequences of road construction to wildlife are generally negative. Roads result in increased human access, habitat fragmentation, disturbance, and in some cases direct mortality due to vehicle collisions.”

“Research has documented an 80% decline in grizzly bear habitat use within 1 km of open roads used by motorized vehicles in Montana9. This has been ascribed either to bears avoiding humans or to the selective over-harvest of bears habituated to humans that would otherwise more fully use areas heavily influenced by people.”

Schwartz, Chuck Ph.D. - March 1998 “Wildlife and Roads” The Interagency Forest Ecology Study Team (INFEST) newsletter http://www.sf.adfg.state.ak.us/sarr/forestecology/fsroads.cfm ------Road Construction Opposing View #49 - “The effects of forest roads on hydrology are related to the effects of forest clearing. Most logging requires road access, and the roads often remain after the logging, so there are both short and long-term effects.94 Forest road surfaces are relatively impermeable. Water readily runs over the road surface and associated roadside ditches, often directly to a stream channel, with the net effect of extending channel networks and increasing drainage density.95 In addition to providing conduits for overland flow, forest roads involve slope-cuts and ditching that may intersect the water table and interrupt natural subsurface water movement.96 This diversion of subsurface water may be quantitatively more important than the overland flow of storm water in some watersheds.97 The importance of roads in altering basin hydrology has been underscored in paired-watershed studies and recent modeling studies.98 “ (Pgs. 730 and 731)

Shanley, James B. and BeverleyWemple Ph.D. “Water Quantity and Quality in the Mountain Environment” Vermont Law Review, Vol. 26:717, 2002 http://www.uvm.edu/~bwemple/pubs/shanley_wemple_law.pdf ------Road Construction Opposing View #50 - "Roads are often the major source of soil erosion from forested lands (Patric 1976)."

"Generally, soil loss is greatest during and immediately after construction."

Swift Jr., L. W. "Soil losses from roadbeds and cut and fill slopes in the Southern Appalachian Mountains." Southern Journal of Applied Forestry 8: 209-216. 1984. http://cwt33.ecology.uga.edu/publications/403.pdf ------Road Construction Opposing View #51 - “More subtle causes of habitat loss include the construction of roads and power lines. These linear barriers also have been correlated with a decline in neotropical migrant songbirds (Berkey 1993; Boren et al. 1999; Ortega and Capen 2002). Whether by forest conversion or the construction of roads and power lines, fragmentation subdivides habitat into smaller and smaller parcels. The result is an increase of edge habitat, or the boundary between intact forest and surrounding impacted areas. Small forests with large amounts of edge habitat are a hostile landscape for nesting neotropical migratory songbirds. In these areas, songbirds face two great threats: 1) the loss of eggs and nestlings to predators and, 2) parasitism by cowbirds.”

Switalski, Adam “Where Have All the Songbirds Gone? Roads, Fragmentation, and the Decline of Neotropical Migratory Songbirds” Wildlands CPR, September 8, 2003 http://www.wildlandscpr.org/node/213 ------Road Construction Opposing View #52 - “Roads are a widespread and increasing feature of most landscapes. We reviewed the scientific literature on the ecological effects of roads and found support for the general conclusion that they are associated with negative effects on biotic integrity in both terrestrial and aquatic ecosystems. Roads of all kinds have seven general effects: mortality from road construction, mortality from collision with vehicles, modification of animal behavior, alteration of the physical environment, alteration of the chemical environment, spread of exotics, and increased use of areas by humans. Road construction kills sessile and slow-moving organisms, injures organisms adjacent to a road, and alters physical conditions beneath a road. Vehicle collisions affect the demography of many species, both vertebrates and invertebrates; mitigation measures to reduce roadkill have been only partly successful. Roads alter animal behavior by causing changes in home ranges, movement, reproductive success, escape response, and physiological state. Roads change soil density, temperature, soil water content, light levels, dust, surface waters, patterns of runoff, and sedimentation, as well as adding heavy metals (especially lead), salts, organic molecules, ozone, and nutrients to roadside environments. Roads promote the dispersal of exotic species by altering habitats, stressing native species, and providing movement corridors. Roads also promote increased hunting, fishing, passive harassment of animals, and landscape modifications. Not all species and ecosystems are equally affected by roads, but overall the presence of roads is highly correlated with changes in species composition, population sizes, and hydrologic and geomorphic processes that shape aquatic and riparian systems. More experimental research is needed to complement post-hoc correlative studies. Our review underscores the importance to conservation of avoiding construction of new roads in roadless or sparsely roaded areas and of removal or restoration of existing roads to benefit both terrestrial and aquatic biota.”

Trombulak, Stephen C. Ph.D. and Christopher A. Frissell Ph.D. “Review of Ecological Effects of Roads on Terrestrial and Aquatic Communities” Conservation Biology, Volume 14, No. 1, Pages 18–30, February 2000 http://www.transwildalliance.org/resources/200922144524.pdf ------Road Construction Opposing View #53 - "Roads are a major contributor to habitat fragmentation because they divide large landscapes into smaller patches and convert interior habitat into edge habitat. As additional road construction and timber harvest activities increase habitat fragmentation across large areas, the populations of some species may become isolated, increasing the risk of local extirpations or extinctions (Noss and Cooperrider 1994)."

"Habitat fragmentation creates landscapes made of altered habitats or developed areas fundamentally different from those shaped by natural disturbances that species have adapted to over evolutionary time (Noss and Cooperrider 1994 in Meffe et al. 1997). Adverse effects of habitat fragmentation to both wildlife populations and species include:

"Increased isolation of populations or species, which leads to:

• Adverse genetic effects; i.e. inbreeding depression (depressed fertility and fecundity, increased natal mortality) and decreased genetic diversity from genetic drift and bottlenecks,

• Increased potential for extirpation of localized populations or extinction of narrowly distributed species from catastrophic events such as hurricanes, wildfires or disease outbreaks,

• Changes in habitat vegetative composition, often to weedy and invasive species,

• Changes in the type and quality of the food base,

• Changes in microclimates by altering temperature and moisture regimes,

• Changes in flows of energy and nutrients,

• Changes in the availability of cover and increases edge effect, bringing together species that might otherwise not interact, potentially increasing rates of predation, competition and nest parasitism, and

• Increased opportunities for exploitation by humans, such as poaching or illegal collection for the pet trade."

Watson, Mark L. "Habitat Fragmentation and the Effects of Roads on Wildlife and Habitats." Background and Literature Review 2005. http://www.wildlife.state.nm.us/conservation/habitat_handbook/documents/2004EffectsofRoads onWil dlifeandHabitats.pdf ------Road Construction Opposing View #54 - "Our analysis also indicated that >70 percent of the 91 species are affected negatively by one or more factors associated with roads."

"Roads in forested areas increase trapping pressures for martens and fishers, resulting in significantly higher captures in roaded versus unroaded areas (Hodgman and others 1994) and in logged versus unlogged areas, in which the difference was again attributed to higher road densities in logged stands (Thompson 1994). Secondary roads also might increase the likelihood that snags and logs will be removed for fuel wood. This could impact fishers, martens and flammulated owls, and also could have a negative effect on the prey base for goshawks (Reynolds and others 1992)."

"An additional, indirect effect of roads is that road avoidance leads to underutilization of habitats that are otherwise high quality."

Wisdom, Michael J., Richard S. Holthausen Ph.D. Barbara C. Wales Ph.D., Christina D. Hargis Ph.D. Victoria A. Saab Ph.D., Danny C. Lee Ph.D. Wendel J. Hann Ph.D. Terrell D. Rich, Mary M. Rowland, Wally J. Murphy, and Michelle R. Eames "Source Habitats for Terrestrial Vertebrates of Focus in the Interior Columbia Basin: Broad-Scale Trends and Management Implications Volume 2 – Group Level Results." USDA Forest Service, PNW-GTR-485, May 2000. http://maps.wildrockies.org/ecosystem_defense/Science_Documents/Wisdom_et_al_2000/Vol_ 2a.pdf ------Road Construction Opposing View #55 - “According to the DEIS, the Forest now manages a total of 5,914 miles of roads across the Forest. Scientific literature has established that roads have numerous widespread, pervasive and, if left untreated, long-lasting biological and physical impacts on aquatic ecosystems that continue long after completion of construction. (Angermeier et al. 2004). Roads increase surface water flow, alter runoff patterns, alter streamflow patterns and hydrology, and increase sedimentation and turbidity. Roads are the main source of sediment to water bodies from forestry operations in the United States. (US EPA 2002). Road construction can lead to slope failures, mass wasting and gully erosion. Road crossings can act as barriers to movement for fish and other aquatic organisms, disrupting migration and reducing population viability. (Schlosser and Angermeier 1995). Chemical pollutants that enter streams via runoff, such as salt and lead from road use and management, compound these impacts. Most of these adverse effects are persistent and will not recover or reverse without human intervention. The techniques for road remediation are well established, agreed upon and readily available. (Weaver et al. 2006).” (Pg. 2)

Wright, Bronwen, Policy Analyst and Attorney Pacific Rivers Council Excerpt from a May 11, 2009 letter to the Rogue River-Siskiyou National Forest Travel Management Team http://www.pacificrivers.org/protection-defense/comment- letters/Rogue%20River%20Siskiyou%20TMP%20DEIS.pdf ------Road Construction Opposing View #56 - “Fires do not leave a large road network in place (assuming the blaze was not suppressed otherwise there may be dozer lines, etc.). Logging creates roads that fragment habitat and generally increase human access, both of which affect the use of the land by wildlife. Moreover, roads and logging equipment can become vectors for the dispersal of weeds.”

Wuerthner, George 2008 “Ecological Differences between Logging and Wildfire” http://wuerthner.blogspot.com/2008/12/ecological-differences-between-logging.html ------Road Construction Opposing View #57 - “Forest fragmentation occurs when large, contiguous blocks of forest are broken up into isolated islands by development, roads, or clearing for agriculture. Just as inbreeding among the royal families of Europe spread hemophilia, forest fragmentation negatively impacts the long term sustainability of both plant and animal communities. Geographic isolation results in inbreeding and diminishes biodiversity.”

Zimmerman, E.A. and P.F. Wilbur “A Forest Divided” New Roxbury Land Trust newsletter, 2004 http://www.ourbetternature.org/forestfrag.htm

Opposing Views Attachment #11

Caring USFS Officials will Always Take the Most Effective Action Available to Reduce the Risk Of Homes Burning and Loss of Life should a Wildfire Start Near Neighborhoods Located in the Woods

Not Analyzing an Alternative in Detail that Applies Dr. Cohen’s Fine Fuels Removal Methods Discussed below Indicates the Responsible USFS Official Believes Timber Removal resulting from Hazardous Fuels Reduction Logging is more Important than Preventing Homes from Burning

Dr. Cohen’s background Dr. Jack Cohen is a research fire physicist who does his research in the Forest Service's Missoula Fire Sciences Laboratory at the Rocky Mountain Research Station. Dr. Cohen is a Forest Service employee. His research findings clearly show that commercial logging to reduce fuels will not protect homes from wildfire damage in the Wildland Urban Interface (WUI).

Dr. Cohen’s Research Findings Represent Best Science and Empirical Evidence Shows his Fire Damage Risk Reduction Methods that remove the Fine Fuels Near the Home are Far Superior to Hazardous Fuel Removal Dr. Cohen Is likely the only Ph.D. fire physicist in America who specializes in determining the best actions to reduce the risk of wildfire damage to homes. Dr. Cohen is a well published scientist-author. He has published 12 peer-reviewed scientific papers summarizing his research findings. ------Independent Sources Emphasize the Effectiveness of Dr. Cohen’s Fire Damage Risk Reduction Methods

“Homeowners are their own first line of defense. Saving a home from wildfire depends primarily on two factors: roofing material and the quality of the “defensible 8 space” surrounding it. Research Physical Scientist Jack Cohen noted after visiting homes that survived the Rodeo-Chediski Fire and those that were consumed, that had homeowners followed guidelines for creating defensible space—described as creating an area around a structure where fuels and vegetation are treated, cleared, or reduced to slow the spread of fire—more homes would have survived.”

Fact Sheet: Understanding Fire and Fire Behavior Ontario Aviation and Forest Fire Management http://www.emifpa.org/PDF/FactSheetUnderstandingFire.pdf ------Dr. Cohen’s opposing view #1 - “Research results indicate that the home and its immediate surroundings within 100-200 feet (30-60 meters) principally determines the home ignition potential during severe wildland-urban fires. Research has also established that fire is an intrinsic ecological process of nearly all North American ecosystems. Together, this understanding forms the basis for a compelling argument for a different approach to addressing the wildland-urban fire problem.” (Pg. 1 – abstract)

Source: Wildland-Urban Fire—A different approach http://www.nps.gov/fire/download/pub_pub_wildlandurbanfire.pdf ------Dr. Cohen’s opposing view #2 - “A senior physicist at the Stanford Research Institute, C.P. Butler (1974), coined the term "urban-wildland interface" and described this fire problem as follows:

"In its simplest terms, the fire interface is any point where the fuel feeding a wildfire changes from natural (wildland) fuel to man-made (urban) fuel.” (Pg. 1)

Dr. Cohen’s opposing view #3 - “The results of the diverse analytical methods are congruent and consistently indicate that ignitions from flames occur over relatively short distances--tens of meters not hundreds of meters. The severe-case estimate of SIAM indicates distances of 40 meters or less. Experimental wood walls did not ignite at 10 meters when exposed to experimental crown fires. And, case studies found that vegetation clearance of at least 10 meters was associated with a high occurrence of home survival.” (Pg. 4)

Dr. Cohen’s opposing view #4 - “Analyses of southern California home losses done by the Stanford Research Institute for the 1961 Belair-Brentwood Fire (Howard and others 1973) and by the University of California, Berkeley, for the 1990 Painted Cave Fire (Foote and Gilless 1996) are consistent with SIAM estimates and the experimental crown fire data. Given nonflammable roofs, Stanford Research Institute (Howard and others 1973) found a 95 percent survival with a clearance of 10 to 18 meters and Foote and Gilless (1996) at Berkeley, found 86 percent home survival with a clearance of 10 meters or more.” (Pgs. 3 and 4)

Dr. Cohen’s opposing view #5 - “Extensive wildland vegetation management does not effectively change home ignitability.” (Pg. 5)

Dr. Cohen’s opposing view #6 - “Home ignitability also dictates that effective mitigating actions focus on the home and its immediate surroundings rather than on extensive wildland fuel management. Because homeowners typically assert their authority for the home and its immediate surroundings, the responsibility for effectively reducing home ignitability can only reside with the property owner rather than wildland agencies.” (Pg. 5)

Dr. Cohen’s opposing view #7 - “As stated, the evidence indicates that home ignitions depend on the home materials and design and only those flammables within a few tens of meters of the home (home ignitability). The wildland fuel characteristics beyond the home site have little if any significance to WUI home fire losses.” (Pg. 5)

Dr. Cohen’s opposing view #8 - “Home ignitability implies that homeowners have the ultimate responsibility for WUI home fire loss potential. As shown, the ignition and flammability characteristics of a structure and its immediate surroundings determine the home fire loss potential. Thus, the home should not be considered a victim of wildland fire, but rather a potential participant in the continuation of the wildland fire. Home ignitability, i.e., the potential for WUI home fire loss, is the homeowner's choice and responsibility.” (Pg. 5)

Dr. Cohen’s opposing view #9 - “However, public and management perceptions may impede homeowners from taking principal responsibility. For example, the Federal Wildland Fire Management, Policy and Program Review (1995) observes, ‘There is a widespread misconception by elected officials, agency managers, and the public that wildland/urban interface protection is solely a fire service concern.’ In a Journal of Forestry article, Beebe and Omi (1993) concur, stating that, ‘Public reaction to wildfire suggests that many Americans want competent professionals to manage fire flawlessly, reducing the risks to life, property, and public lands to nil.’ These statements agree with Bradshaw's (1988) description of the societal roles in the WUI problem. He observes that homeowners expect that fire protection will be provided by others. Contrary to these expectations for fire protection, the fire services have neither the resources for effectively protecting highly ignitable homes during severe WUI fires, nor the authority to reduce home ignitability.” (Pg. 6)

Source for quotes #2 to #9 above: Reducing the Wildland Fire Threat to Homes: Where and How Much? Presented as the Fire Economics Symposium in San Diego, California on April 12, 1999. http://www.fs.fed.us/rm/pubs_other/rmrs_1999_cohen_j001.pdf ------Dr. Cohen’s opposing view #10 - “Vegetation management beyond the structure's immediate vicinity has little effect on structure ignitions. That is, vegetation management adjacent to the structure would prevent ignitions from flame exposure; but vegetation management away from the structure would not affect ignition from flame exposure and would not significantly reduce ignitions from firebrands.” (Pg. 4)

Dr. Cohen’s opposing view #11 - “Past reports and recommendations as well as experimental research and modeling suggest that W-UI fire-loss mitigation should concentrate on the residence and its immediate surroundings. Any strategy for effectively reducing the W-UI fire problem must initially focus on residential fire resistance.” (Pg. 5 – Conclusion)

Dr. Cohen’s opposing view #12 - “Instead of all fire protection responsibilities residing with fire agencies, homeowners take responsibility for assuring firewise conditions and the initial fire defense of their residences during wildland fires. The fire agencies become a community partner that provides information, coordinates and assists in meeting firewise requirements, and provides fire suppression assistance.” (Pg. 5)

Source for quotes #10 to #12 above: Structure Ignition Assessment can Help Reduce Fire Damages in the WUI Published in Fire Management Notes, Volume 57 No. 4, 1997 http://www.fs.fed.us/rm/pubs_other/rmrs_1997_cohen_j001.pdf ------Dr. Cohen’s opposing view #13 - “My examination suggests that the abundance and ubiquity of pine needles, dead leaves, cured vegetation, flammable shrubs, wood piles, etc. adjacent to, touching and or covering the homes principally contributed to the residential losses.” (Pg. 4)

Source: Examination of the Home Destruction in Los Alamos Associated with the Cerro Grande Fire July 10, 2000 Source: USDA Forest Service, Rocky Mountain Research Station, Missoula, Montana, 2000. http://www.fusee.org/docs/Preparedness/Cohen_examlosalamos%20copy.pdf ------Dr. Cohen’s opposing view #14 - "The wildland fire management approach for preventing WUI fire disasters largely addresses the wildfire outside the home ignition zone rather than a home's ignition potential as determined by the conditions within the home ignition zone. Since 2000, agency fire management policy initiatives have emphasized fire suppression." (Pg. 24)

Dr. Cohen’s opposing view #15 - "Preventing WUI fire disasters requires that the problem be framed in terms of home ignition potential. Because this principally involves the home ignition zone, and the home ignition zone primarily falls within private ownership, the responsibility for preventing home ignitions largely falls within the authority of the property owner. Preventing wildfire disasters thus means fire agencies helping property owners mitigate the vulnerability of their structures. The continued fire management focus on fire suppression suggests the WUI fire problem persists largely as a consequence of framing the WUI fire problem primarily in terms of the fire exclusion paradigm." (Pg. 25)

Dr. Cohen’s opposing view #16 - "The continued focus on fire suppression largely to the exclusion of alternatives that address home ignition potential suggests a persistent inappropriate framing of the WUI fire problem in terms of the fire exclusion paradigm." (Pg. 25)

Source for quotes #14 to #16 above: The Wildland-Urban Interface Fire Problem: A Consequence of the Fire Exclusion Paradigm Published in Forest History Today, Fall 2008 http://www.foresthistory.org/Publications/FHT/FHTFall2008/Cohen.pdf ------Dr. Cohen’s opposing view #17 - “For the same reason, mitigating home ignition potential during extreme wildland fires must focus activities within and immediate to the residential area, i.e. the home ignition zone. But the home ignition zone largely corresponds to private property. Thus, with minor exception, the authority for effectively reducing the home ignition potential belongs to homeowners. Public land management agencies can facilitate homeowner mitigations and these agencies may be able to reduce fire intensities and the extent of burning around communities. But these agencies cannot accomplish the necessary and sufficient actions necessary to prevent residential fire disasters during extreme fire conditions by treating beyond the home ignition zone.” (Pg. 2)

Source: Thoughts on the Wildland-Urban Interface Fire Problem, June 2003 http://www.nps.gov/fire/download/pub_pub_wildurbaninterface.pdf ------Dr. Cohen’s opposing view #18 - “A home with its immediate surroundings (about 100-150 feet from the structure) is called the Home Ignition Zone. Many factors about the HIZ determine the potential for ignition during a wildland fire, such as flammable wood roofs and materials like trees, grass, decks, or adjacent structures leading up to a home.” (Pg. 1)

Source: Saving Homes from Wildfires: Regulating the Home Ignition Zone Published in Zoning News, May 2001 http://www.battle-creek.net/docs/fire/Zoning.pdf ------Dr. Cohen’s opposing view #19 - “SIAM calculations indicate that large wildland flame fronts (e.g., forest crown fires) will not result in piloted wood ignitions (e.g., the typical variety of exterior wood walls) at distances greater than 40 meters (Cohen and Butler [In press]).” (Pg. 4)

Dr. Cohen’s opposing view #20 - “Field studies conducted during the International Crown Fire Modeling Experiment (Alexander et al. 1998) provided measured data for comparisons with SIAM model estimates. Total heat transfer (radiation and convection) and ignition data were obtained from heat flux sensors placed in wooden wall sections. The instrumented walls were located on flat, cleared terrain at 10, 20, and 30 meters downwind from the edge of the forested plots. The forest was variably composed of an overstory of jack pine (Pinus banksiana) about 13 meters high with an understory of black spruce (Picea mariana). The spreading crown fire produced flames approximately 20 meters high.” (Pg. 5)

Dr. Cohen’s opposing view #21 - “Five burns were conducted where wall sections were exposed to a spreading crown fire. As the crown fires reached the downwind edge of the plot, turbulent flames extended into the clearing beyond the forest edge. In two of the five burns, flames extended beyond 10 meters to make contact with the wall section placed at 10 meters from the forest edge. When flame contact occurred, the walls ignited; however, without flame contact, only scorch occurred. The wooden panels at 20 and 30 meters never ignited and the panel at 30 meters never scorched.” (Pg. 6)

Dr. Cohen’s opposing view #22 - “Case studies of actual W-UI fires provide an independent comparison with SIAM and the crown fire experiments. The actual fires incorporate a wide range of fire exposures. The case studies chosen examine significant factors related to home survival for two fires that destroyed hundreds of homes. The Bel Air fire resulted in 484 homes destroyed (Howard et al. 1973) and the Painted Cave fire destroyed 479 homes (Foote 1994). Analyses of both fires indicate that home ignitions depend on the characteristics of a home and its immediate surroundings. Howard et al. (1973) observed 95 percent survival for homes with nonflammable roofs and a vegetation clearance of 10 to 18 meters. Foote (1994) observed 86 percent survival for homes with nonflammable roofs and a clearance of 10 meters or more.” (Pg. 7)

Dr. Cohen’s opposing view #23 - “The high survival rate for homes with nonflammable roofs and 10-20 meter vegetation clearances included firebrands as an ignition factor, thus indicating that firebrand ignitions also depend on the ignition characteristics of the home and the adjacent flammable materials.” (Pg. 8)

Dr. Cohen’s opposing view #24 - “Wildland fuel reduction beyond the home ignition zone does not necessarily change home ignitability; therefore, wildland fuel reduction does not necessarily mitigate the W-UI fire loss problem.” (Pg. 9)

Dr. Cohen’s opposing view #25 - “Effective landscape fuel reduction does not necessarily prevent W-UI home fire destruction.” (Pg. 10)

Dr. Cohen’s opposing view #26 - “Fire losses depend on home ignitions and home ignitions depend on home ignitability. Thus, home ignitability, being limited to a home and its immediate surroundings, offers us the opportunity to separate the W-UI structure fire loss problem from other landscape-scale fire management issues. This conclusion has significant implications for the actions and responsibilities of homeowners and fire agencies, such as identifying and mapping the potential for W-UI residential fire destruction, identifying appropriate and effective mitigating actions, and determining who should take responsibility for home ignitability.” (Pg. 10)

Dr. Cohen’s opposing view #27 - “Thus, wildland fuel reduction that is effective for reducing the wildland fire intensity might be insufficient for reducing the destruction of highly ignitable homes. In contrast, a low home ignition potential reduces the chances of fire destruction without extensive wildland fuel reduction. These findings indicate that the W-UI home fire loss problem is a home ignitability issue largely independent of landscape fuel reduction issues.” (Pg. 10)

Dr. Cohen’s opposing view #28 - “The extent of the home ignition zone corresponds more to specific home and community ownership than to the landscapes of federal, state and local land management agencies. This suggests a corresponding responsibility for W-UI home fire loss potential residing with homeowners and communities. Thus, the home should not be considered a victim of wildland fire, but rather a potential participant in the continuation of the wildland fire. Home ignitability, i.e., the potential for W-UI home fire loss, is a homeowner and community choice and responsibility.” (Pg. 11)

Source for quotes #19 to #28 above: What is the Wildland Fire Threat to Homes? Presented as the Thompson Memorial Lecture, April 10, 2000 http://www.nps.gov/fire/download/pub_pub_wildlandfirethreat.pdf ------Dr. Cohen’s opposing view #29 - “Model results indicate that ignitions from flame radiation are unlikely to occur from burning vegetation beyond 40 meters of a structure. Thinning vegetation within 40 meters has a significant ignition mitigation effect.” (Pg. 81)

Dr. Cohen’s opposing view #30 - “Vegetation management to prevent ignitions from radiation does not require extensive vegetation removal hundreds of meters from a structure. Our analysis indicated that 40 meters was sufficient for a 20 meter flame height.” (Pg. 86 – Conclusions)

Source for quotes #29 and #30 above: Modeling Potential Structure Ignitions from Flame Radiation Exposure with Implications for Wildland/Urban Interface Fire Management Presented at the 13th Fire and Forest Meteorology Conference. Lorne, Australia, 1996 http://www.firewise.org/resources/files/WUI_HIR/Modelingpotentialignitions.pdf ------Dr. Cohen’s opposing view #31 - “Miracles aside, the characteristics of the surviving home and its immediate surroundings greatly influenced its survival.” (Pg. 15)

Dr. Cohen’s opposing view #32 - “Based on severe-case assumptions of flame radiation and exposure time, SIAM calculations indicate that wild-land flame fronts comparable to crowning and torching trees (flames 20 meters high and 50 meters wide) will not ignite wood surfaces at distances greater than 40 meters (Cohen and Butler, in press). Figure 2 shows the radiant heat a wall would receive from flames depending on its distance from the fire. The incident radiant heat flux, defined as the rate of radiant energy per unit area received at an exposed surface, decreases as the distance increases.” (Pg. 17)

Dr. Cohen’s opposing view #33 - “Analyses of both fires indicate that home ignitions depend on the characteristics of a structure and its immediate surroundings. Howard et al. (1973) observed 86 percent survival for homes with nonflammable roofs and a clearance of 10 meters or more.” (Pg. 19)

Dr. Cohen’s opposing view #34 - “Using the model results as guidance with the concurrence of experiments and case studies, we can conclude that home ignitions are not likely unless flames and firebrand ignitions occur within 40 meters of the structure. This finding indicates that the spatial scale determining home ignitions corresponds more to specific home and community sites than to the landscape scales of wildland fire management. Thus, the W-UI fire loss problem primarily depends on the home and its immediate site.” (Pg.20)

Dr. Cohen’s opposing view #35 - “Thus, the W-UI fire loss problem can be defined as a home ignitability issue largely independent of wildland fuel management issues. This conclusion has significant implications for the actions and responsibilities of homeowners and fire agencies, such as defining and locating potential W-UI fire problems (for example, hazard assessment and mapping), identifying appropriate mitigating actions, and determining who must take responsibility for home ignitability.” (Pg.20)

Dr. Cohen’s opposing view #36 - “The W-UI fire case studies indicated approximately 90 percent survival with a vegetation clearance on the order of 10 to 20 meters for homes with nonflammable roofs. Thus, the case studies support the general flame-to- structure distance range of 10 to 40 meters as found through modeling and experiments.” (Pg.20)

Dr. Cohen’s opposing view #37 - “A change needs to take place in the relationship between homeowners and the fire services. Instead of home-related presuppression and fire protection responsibilities residing solely with fire agencies, homeowners must take the principal responsibility for ensuring adequately low home ignitability.” (Pg.21)

Source for quotes #31 to #37 above: Preventing Disaster Home ignitability in the Wildland- Urban Interface Published in the Journal of Forestry 98(3): 15-21, 2000 http://www.nps.gov/fire/download/pub_pub_preventingdisaster.pdf ------Dr. Cohen’s opposing view #38 - “Many scientists and natural resource agencies suggest extensive fuel treatments to reduce the possibility of severe and intense wildfires that could damage ecosystems, destroy property, and take human life (USDA Forest Service, 2000; GAO, 2003a,b). However, there are a number of misconceptions and misunderstandings about fuel treatments and their use as a panacea for fire hazard reduction across the United States (Finney and Cohen, 2003; Franklin and Agee, 2003).” (Pg.1998)

Dr. Cohen’s opposing view #39 - “Given the right conditions, wildlands will inevitably burn. It is a misconception to think that treating fuels can ‘‘fire-proof’’ important areas. It would be virtually impossible to exclude fire from most temperate terrestrial ecosystems because ignition sources are prevalent and fuels cannot be eliminated. Ignition is rarely affected by fuel treatment.” (Pg.1998)

Dr. Cohen’s opposing view #40 - “Treating fuels to facilitate suppression is an example in circular logic. If fuel treatment makes suppression more successful in general, then less area will be burned in the short run and more acreage will tend to burn under extreme conditions, when suppression is ineffective. The inevitable result is that more area is burned in fewer, more unmanageable events with greater consequences. In addition, fire suppression leads to continued fuel accumulation and, in turn, more difficult conditions for suppression. This phenomenon has been described as ‘‘the wildland fire paradox’’ (Brown and Arno, 1991). Rather than creating conditions where fire is easier to suppress, fuel treatments should strive to create conditions where fire can occur without the need for suppression.” (Pg.1998)

Dr. Cohen’s opposing view #41 - “Bessie and Johnson (1995) show weather (fuel moisture and wind) is far more important than fuels in determining fire behavior; reducing fuels may have a limited impact on fire occurrence.” (Pg.1999)

Dr. Cohen’s opposing view #42 - “Treating fuels to reduce fire occurrence, fire size, or amount of burned area is ultimately both futile and counter-productive.” (Pg.1999)

Dr. Cohen’s opposing view #43 - “Since the home ignition zone largely occurs on private lands, most land management agencies do not have the authority to mitigate the WUI ignition potential directly (Cohen, 2000b). However, the opportunity exists to explicitly define responsibilities for the WUI fire potential (i.e. the home ignition zone) consistent with areas of jurisdiction and separately from ecological wildfire issues.” (Pg.1999)

Dr. Cohen’s opposing view #44 - “It may not be necessary or effective to treat fuels in adjacent areas in order to suppress fires before they reach homes; rather, it is the treatment of the fuels immediately proximate to the residences, and the degree to which the residential structures themselves can ignite that determine if the residences are vulnerable.” (Pg.1999)

Dr. Cohen’s opposing view #45 - “WUI fuel treatments can be designed such that an extreme wildfire can occur in the WUI without having a residential fire disaster. Although general wildfire control efforts may not benefit from fuel treatments during extreme fire behavior, fuel modifications can significantly change outcome of a wildfire within a treatment area. Research has shown that a home’s characteristics and its immediate surroundings principally determine the WUI ignition potential during extreme wildfire behavior (Cohen, 2000a,c, 2003, 2004). The area that primarily determines WUI ignition potential is called the home ignition zone (Cohen, 2001). WUI fuel treatments can address the home ignition zone by removing flammable materials immediately adjacent to residences.” )Pg. 1999)

Dr. Cohen’s opposing view #46 - “Treating fuels may not reduce suppression expenditures. It is a natural mistake to assume that a successful fuel treatment program will result in reduced suppression expenditures. Suppression expenditures rarely depend directly on fuel conditions, but rather on fire location and on what resources are allocated to suppression. The only certain way to reduce suppression expenditures is to make a decision to spend less money suppressing fires.” (Pg. 2000)

Dr. Cohen’s opposing view #47 - “Thinning to reduce crown fire potential requires careful evaluation of the tradeoffs in treatment effects on potential surface fire behavior and crown fire behavior (Scott and Reinhardt, 2001). Thinning will often result in increased potential surface fire behavior, for several reasons. First, thinning reduces the moderating effects of the canopy on windspeed, so surface windspeed will increase (Graham et al., 2004). It also results in increased solar radiation on the forest floor, causing drier surface fuels. It may also cause an increase in flammable grassy and shrub fuels over time, due to the reduced tree competition.” (Pg.2000)

Dr. Cohen’s opposing view #48 - “Some viable fuel treatments may actually result in an increased rate of spread under many conditions (Lertzman et al., 1998; Agee et al., 2000). For example, thinning to reduce crown fire potential can result in surface litter becoming drier and more exposed to wind. It can also result in increased growth of grasses and understory shrubs which can foster a rapidly moving surface fire.” (Pg.2000)

Dr. Cohen’s opposing view #49 - “Treating fuels may not improve ecosystem health. Ecosystem restoration treatment and fuel treatment are not synonymous. Some ecosystem restoration treatments reduce fuel hazard, but not all fuel treatments restore ecosystems. Ecosystem restoration treatments are often designed to recreate presettlement fire regimes, stand structures and species compositions while fuel treatment objectives are primarily to reduce fuels to lessen fire behavior or severity— this is known as ‘’hazard Reduction.’’ Achieving fuel hazard reduction goals in the absence of ecosystem restoration is insufficient (Dombeck et al., 2004; Kauffman, 2004).” (Pg.2000)

Dr. Cohen’s opposing view #50 - “Conversely, some fuel treatments can reduce fuels but create stands that are quite dissimilar from their historical analogs. Examples include mastication treatments that break, chip, or grind canopy and surface woody material into a compressed fuelbed and thinning treatments that remove the fire adapted species and leave shade-tolerant, late successional species.” (Pg.2000)

Source for quotes #38 to #50 above: Objectives and considerations for wildland fuel treatment in forested ecosystems of the interior western United States Published in Forest Ecology and Management 256, 2008 http://www.firewise.org/Information/Research-and-Guidance/WUI-Home-Ignition- Research/~/media/Firewise/Files/Pdfs/Research/CohenFuelTreatment.pdf ------

Concluding Comments Nearly all Forest Service projects that claim to lessen the risks to homeowners living in the WUI propose to reduce hazardous fuels. The NEPA documents that analyze these fuels reduction treatments conveniently do not mention Dr. Cohen’s methods because the Purpose & Need is to reduce fuels … not (emphasis added) to protect homeowners as it should be.

Reducing hazardous fuels is an alternative way to lessen the risks to homeowners living in the WUI. It is definitely not a goal or objective unto itself and should never appear in the Purpose & Need.

However there is a reason most USFS line-officers deal with WUI risks this way. They know hazardous fuels reduction treatments include the logging of merchantable trees which produces volume and helps them meet their supervisor’s volume expectations and spends the allocated “timer” money each FY.

Line-Officers who propose hazardous fuels reduction projects are clearly more interested in accumulating volume than they are protecting the public in the WUI.

There are laws that prohibit such actions by a public servant whose salary is partially paid by the families living in the WUI.

Opposing Views Attachment #17

Mountain Pine Beetle Activity in Lodgepole Pine does not Increase the Fire Risk

Bark Beetle Opposing View #1 Article Excerpt: “Dead surface fuel loads of all size categories did not differ among undisturbed, red, and gray-stage stands. Compared to undisturbed sites, red and gray- stage sites had on average 53% lower canopy bulk density, 42% lower canopy fuel load, and 29% lower canopy moisture content, but had similar canopy base heights (3.1 m). In subsequent decades, coarse wood loads doubled and canopy base height declined to 0 m. Modeling results suggested that undisturbed, red, and gray-stage stands were unlikely to exhibit transition of surface fires to tree crowns (torching), and that the likelihood of sustaining an active crown fire (crowning) decreased from undisturbed to gray-stage stands. Simulated fire behavior was little affected by beetle disturbance when wind speed was either below 40 km/h or above 60 km/h, but at intermediate wind speeds, probability of crowning in red- and gray-stage stands was lower than in undisturbed stands, and old post-outbreak stands were predicted to have passive crown fires. Results were consistent across a range of fuel moisture scenarios.

Dr. Martin Simard, Dr. William H. Romme, Dr. Jacob M. Griffin, and Dr. Monica G. Turner “Do mountain pine beetle outbreaks change the probability of active crown fire in lodgepole pine forests?” Ecological Monographs, 81(1), 2011, pp. 3–24, 2011 by the Ecological Society of America http://esa.org/papers/pdf/emon-81-01-04_3.24.pdf ------Bark Beetle Opposing View #2 Article Excerpt: “The researchers explain that while green pine needles might appear moister and harder to burn, they actually contain high levels of flammable volatile oils.

When those needles die, the flammable oils begin to break down. As a result, depending on the weather conditions, dead needles may be less likely to catch and sustain a fire than live needles.

Secondly, when beetles kill a lodgepole pine tree, the needles fall off and decompose on the forest floor relatively quickly. In a sense, the beetles thin the forest, so that the naked trees left behind are essentially akin to large fire logs.

However, just as you can’t start a fire in a fireplace with just large logs and no kindling, wildfires are less likely to ignite and carry in a forest of dead tree trunks and low needle litter.

Forest ecologists noted this same phenomenon after the massive Yellowstone wildfires in 1988. After the large fires swept through and burned off all the tree needles, only the dead trunks remained. In the years that have followed, new wildfires have tended to slow and sometimes even burn out when they reach the standing dead forest; there simply hasn’t been enough fuel to propel the fire. “

CTV.ca News Staff “Could pine beetles actually reduce forest fire risk?” Published Sunday, Sep. 12, 2010 http://www.ctvnews.ca/could-pine-beetles-actually-reduce-forest-fire-risk-1.551560 ------Bark Beetle Opposing View #3 Article Excerpt: “Tree thinning and logging across millions of acres of Western lodgepole pine and spruce-fir forest is unlikely to reduce fire risk or alleviate future large-scale epidemics of bark beetles, according to a new report prepared by forest ecologists.

“Extensive areas of dead trees have understandably led to widespread concern about the increased risk for forest fires,” said Dominik Kulakowski, one of the report’s authors and a professor of geography and biology at Clark University in Worcester, Mass. “This is a logical concern, but the best available science indicates that the occurrence of large fires in lodgepole pine and spruce-fir forests is mainly influenced by climatic conditions, particularly drought.”

“Although the scale of the recent beetle outbreak is unprecedented in modern times, experts note that insect outbreaks and fires are a natural part of Western forest ecosystems. As such, the report found no causal link between insect outbreaks and the incidence of wildfire.”

Gable, Eryn, “Battling beetles may not reduce fire risks – report” Published in Land Letter and the Xerces Newsletter, March 2010 http://www.xerces.org/2010/03/04/battling-beetles-may-not-reduce-fire-risks-report/ ------Bark Beetle Opposing View #4 Article Excerpt: “Throughout the West, an outbreak of mountain pine beetles and other native bark beetles has been turning large tracts of coniferous forests brown. These natural cycles of periodic pulses of beetle activity may be influenced by global warming because the extended periods of extreme low temperature in the spring that would ordinarily kill the beetles and halt the outbreak have not happened in recent years. Logging interests have fanned the flames of controversy surrounding the beetle outbreaks proposing massive logging projects to halt the outbreaks, even though it is well known that logging cannot stop or even slow bark beetles.”

“It is widely believed that beetle-killed forests are markedly more vulnerable to forest fires but this is largely a myth. Beetle-infested trees have an elevated fire risk only during the brief period after the needles have turned red but still remain on the tree. After the needles are dropped, a beetle-killed forest actually has a lower fire risk than a comparable healthy forest filled with green trees.

The drumbeat of beetle mania is music to the ears of opportunists seeking to turn beetle invasions into timber sales. But logging, for any stated purpose, leads to soil erosion, soil nutrient loss and a potential increase in fine fuels that increase fire risk. Further, logging mountain pine beetle- killed trees destroys wildlife habitat. Southern Rockies woodpeckers and sapsuckers such as the hairy woodpecker and Williamson's sapsucker suffer negative effects of logging followed by slash burning where dead and dying trees (the "snags" that are their homes and feeding sites) have been removed or destroyed by fire.”

“Beetle Mania” Published by the Biodiversity Conservation Alliance http://www.voiceforthewild.org/clearcutting/beetle_mania.html ------Bark Beetle Opposing View #5 Article Excerpt: “ "There is a risk of fire, but that risk was here prior to the outbreak of pine beetles," said Dominik Kulakowski, a professor of geography and biology at Clark University in Massachusetts, on a media tour of beetle-devastated areas in Summit County.

While dead trees burn easily, even green ones are susceptible to raging wildfires in dry times, said Kulakowski, who has studied the naturally occurring cycles of beetle outbreaks in Colorado for nine years.”

“Logging dead trees in reaction to the current beetle outbreak - which has decimated an estimated 660,000 acres of Colorado pine forests - shouldn't be confused with efforts to reduce wildfire hazards, Kulakowski said.” “

“Pine beetles' role in fire risk devalued -- Drought, which dries out trees and promotes the insect outbreaks, is the key hazard, a Massachusetts researcher says.” Published in the Denver Post, August 2007 http://www.denverpost.com/news/ci_6520740 ------Bark Beetle Opposing View #6 Article Excerpt: “ “When we started seeing mountain pine beetle kill in the lodgepole pine forests in the late 1990s, there was a kneejerk reaction among many fire managers and policy makers that there should be a huge increase in the likelihood of catastrophic fire,” says Tom Veblen, professor of geography and head of CU’s biogeography lab. “But the conventional wisdom is not supported.”

“Using data from past fires in lodgepole forests in west-central Colorado and computer modeling developed by Tania Schoennagel, adjunct assistant professor in geography and research scientist at CU’s Institute of Arctic and Alpine Research, the researchers found that under extreme fire conditions, there was no significant difference in fire behavior between beetle-kill stands and those unaffected by infestation.”

Evans, Clay, Ph.D.,“Verdict’s still out on pine-beetle-kill fire effects” Colorado Arts and Sciences magazine http://artsandsciences.colorado.edu/magazine/2012/10/verdicts-still-out-on-pine-beetle-kill-fire- effects/ ------Bark Beetle Opposing View #7 Article Excerpt: “The news on pine beetle outbreak is not necessarily all bad, according to a new study from researchers at the University of Colorado.

Professor William Lewis, interim director of CU's Cooperative Institute for Research in Environmental Sciences, is an author of a new study that reports that small trees and other vegetation near waterways that survive pine beetle infestation increase their uptake of nitrate, a pollutant associated with forest disturbances such as logging and severe storms.

Logging activity or storms can drive stream nitrate concentrations up by as much as 400 percent for multiple years, but the study participants did not discover similar levels of nitrate increase concentration in the wake of widespread pine beetle infestations.

"We found that the beetles do not disturb watersheds in the same way as logging and severe storms," Lewis said in a news release.

"They leave behind smaller trees and other understory vegetation, which compensates for the loss of larger pine trees by taking up additional nitrate from the system. Beetle- kill conditions are a good benchmark for the protection of sub-canopy vegetation to preserve water quality during forest management activities."

A paper on the subject was published Monday in the Proceedings of the National Academy of Sciences.”

CU-Boulder researchers see an upside to pine beetle kill Camera staff Posted: January 15, 2013 http://www.dailycamera.com/cu-news/ci_22378043/cu-boulder-researchers-see-an-upside-pine- beetle ------Bark Beetle Opposing View #8 Article Excerpt: “Even forest thinning, which is widely promoted as a solution by reducing tree susceptibility to outbreaks, has had mixed results and is unlikely to stem bark beetle epidemics on a large landscape scale, especially during drought cycles. Further, this type of thinning would not be a one-time treatment, but would require regular thinning of all treated stands every decade or so because thinning tends to promote rapid growth of understory vegetation, making it a potential fuel ladder. Moreover, too much thinning can moderate stand climates, which may be favorable to some beetles, and increase wind speeds adding to crown fire spread.”

“Scientists, land managers and residents of Colorado are concerned about how wildfire might affect our forests and communities. If the goal is to protect communities, fire- mitigation efforts should be focused around those communities and homes, not in remote and ecologically valuable areas.”

“These forests may look different to us, but beetle-affected forests are still functioning ecosystems that provide food and shelter for animals, cool clear water for fish and humans, and irreplaceable refuges for wildlife from the effects of logging, road building and climate change.” (Pp 23 and 24)

Black, S. H. Ph.D., D. Kulakowski Ph.D., B.R. Noon Ph.D., and D. DellaSala Ph.D. 2010. “Insects and Roadless Forests: A Scientific Review of Causes, Consequences and Management Alternatives.” National Center for Conservation Science & Policy, Ashland OR. http://nccsp.org/files/Insect%20and%20Roadless%20Forests.pdf ------Bark Beetle Opposing View #9 Article Excerpt: “While it may seem intuitive that dead trees will lead to more fires, there is little scientific evidence to support the contention that beetle-killed trees substantially increase risk of large blazes. In fact, there is evidence to suggest otherwise.”

“More importantly, bark beetles are increasingly recognized by ecologists as “ecosystem engineers,” much as beavers are now recognized as important to the creation of wetlands and riparian areas. Beetles are essential to maintaining biodiversity and healthy forests.”

“One study found that bark beetles created habitat for a wide array of other insect species, including many pollinating bees and wasps that maintain flowering species in the forest. Beetle-created snags provide important habitat for birds, with as much as 45 percent of all bird species dependent on dead trees for home and other habitat needs.”

“Snags are used by many small mammals for shelter. When snags fall into streams, they contribute to fish habitat and stream bank stability. Suffice it to say, removal of beetle-killed trees from the forest actually leads to a reduction in forest ecosystem health.”

George Wuerthner, “Pine beetles are accomplished ecosystem engineers” The Bozeman Daily Chronicle, guest opinion, March 29, 2010 http://bozemandailychronicle.com/opinions/guest_columnists/article_bf43fc58-3ac3-11df-aa79- 001cc4c03286.html ------Bark Beetle Opposing View #10 Article Excerpt:“A report released Tuesday by a conservation group finds that efforts to log beetle-killed trees in the backcountry won’t reduce fire risk or beetle outbreaks.”

“The report, released by Oregon-based National Center for Conservation Science and Policy, found that bark beetle outbreaks may not lead to greater fire risk, and that thinning the trees won’t keep the beetles from spreading.”

“ “The primary driver of fire is not beetle kill. It’s climate,” said Barry Noon, a wildlife ecology professor at Colorado State University and an author of the report. “It’s drought and temperature.” “

“ “We’re certainly not arguing against cutting down some of these trees, but we think that the cutting effort needs to be focused around communities and homes,” Noon said. “It makes little sense to have wide-scale cutting of these trees.” “

“The report was authored by Noon; Clark University professor Dominik Kulakowski ; Scott Black, executive director of the Xerces Center for Invertebrate Conservation and Dominick DellaSala, president and chief scientist for the National Center for Conservation Science and Policy.”

“The report found that beetle-killed trees have little impact on fire danger because they drop their dead needles within three years, reducing the fuel in the tree crowns that often causes forest fires to spread.”

Frey, David “Logging Won’t Halt Beetles, Fire, Report Says” NewWest.net, March 3, 2010 http://www.newwest.net/topic/article/logging_wont_halt_beetles_fire_report_says/C41/L41/ ------Bark Beetle Opposing View #11 Article Excerpt: “While research is ongoing and important questions remain unresolved, to date most available evidence indicates that bark beetle outbreaks do not substantially increase the risk of active crown fire in lodgepole pine (Pinus contorta) and spruce (Picea engelmannii)-fir (Abies spp.) forests under most conditions. Instead, active crown fires in these forest types are primarily contingent on dry conditions rather than variations in stand structure, such as those brought about by outbreaks. Preemptive thinning may reduce susceptibility to small outbreaks but is unlikely to reduce susceptibility to large, landscape-scale epidemics. Once beetle populations reach widespread epidemic levels, silvicultural strategies aimed at stopping them are not likely to reduce forest susceptibility to outbreaks. Furthermore, such silvicultural treatments could have substantial, unintended short— and long-term ecological costs associated with road access and an overall degradation of natural areas.

Black, Scott H. Ph.D., Kulakowski, Dominik Ph.D., Barry R. Noon Ph.D., Barry R., DellaSala, Dominick A. Ph.D. “Do Bark Beetle Outbreaks Increase Wildfire Risks in the Central U.S. Rocky Mountains? Implications from Recent Research” Published in Natural Areas Journal, January 2013 http://www.bioone.org/doi/abs/10.3375/043.033.0107 ------Bark Beetle Opposing View #12 Article Excerpt: “Another new study published by the Ecological Society of America titled “Does wildfire likelihood increase following insect outbreaks in conifer forests?” by Garrent Meigs and co authors concludes that bark beetles outbreaks do not lead to greater likelihood of fires. This research joins a growing list of studies, all using different methods of evaluation, that finds that bark beetles are not a driving force in wildfire. Rather climate, terrain, and other factors are more important.”

However a host of studies demonstrate that beetle killed forests are no more likely to burn than green forests. Indeed, some studies suggest that for a period of time after a bark beetle outbreak, forests are less likely to burn.

“This is easily explained by fuels. One of the big misconceptions about wildfire is that fuels drive them and the more biomass, so the thinking goes, the more likely you are to have a major fire. But the “fuels” that carry wildfires are the small flashy fine fuels like pine needles, cones, small branches, not the boles of trees. That is why there are “snags” left after a fire. Most of the tree is not consumed or burned in a wildfire. So once a beetle kill tree loses its needles and the small branches break off in winter storms, they are actually less flammable than live green trees.

In fact, green trees, due to their abundance of resin-filled needles and branches will burn more intensely than dead wood under extreme weather conditions of low humidity, high temperatures and high winds. These are the kind of weather conditions that drive large wildfires.”

Wuerthner, George “Bark Beetles and Forest Fires: Another Myth Goes Up in Smoke” Published in Counterpunch, July 28, 2015 Link: http://www.counterpunch.org/2015/07/28/bark-beetles-and-forest-fires-another-myth-goes- up-in-smoke/ ------Bark Beetle Opposing View #13 Article Excerpt: “We've all seen the sensational headlines: according to the U.S. Forest Service, bark beetles, spurred on by the drought, have killed 25 million trees in California's forests this year, greatly increasing the spread and intensity of recent fires.

What we haven't seen is a critical assessment of these claims. Are bark beetles really increasing fire intensity? Are they really threatening the ecological health of our forests?”

“Rather than pests, both the bark beetle and wood-boring beetle species at issue are native species that fill essential roles in native forests. They evolved in these forests over many millennia; in many ways, they're a cornerstone of the biodiversity in forest ecosystems in California and the western U.S

“But the public is being profoundly misled on these issues. First, trees killed by bark beetles do not increase fire intensity and spread. Numerous scientific studies have been published on this issue, and they consistently reach this conclusion. The most recent and most comprehensive of these, published this year in the Proceedings of the National Academy of Sciences, investigated whether recent tree mortality from bark beetles increased fire spread, studying forests across the western U.S., including forests throughout California. Lead author Sarah Hart and her co-authors concluded that "the annual area burned in the western United States has not increased in direct response to bark beetle activity." “

Hanson, Chad, Ph.D., In defense of the Bark Beetle: a keystone species of Western forest ecosystems Seen on KCETLink, formerly Community Television of Southern California, October 14, 2015 http://www.kcet.org/news/redefine/rewild/commentary/in-defense-of-the-bark-beetle.html

and

Published in Counterpunch and Ecologist, 28th October 2015 http://www.theecologist.org/essays/2985889/in_defense_of_the_bark_beetle_a_keystone_speci es_of_western_forest_ecosystems.html http://www.counterpunch.org/2015/10/15/in-defense-of-the-bark-beetle/ ------Bark Beetle Opposing View #14 Article Excerpt: “Contrary to the expectation of increased wildfire activity in recently infested red-stage stands, we found no difference between observed area and expected area burned in red-stage or subsequent gray-stage stands during three peak years of wildfire activity, which account for 46% of area burned during the 2002–2013 period. Although MPB infestation and fire activity both independently increased in conjunction with recent warming, our results demonstrate that the annual area burned in the western United States has not increased in direct response to bark beetle activity. Therefore, policy discussions should focus on societal adaptation to the effects of recent increases in wildfire activity related to increased drought severity.”

Hart, Sarah, Ph.D., Schoennagen, Tanya, Ph.D., Veblen, Thomas, Ph.D., and Chapman, Teresa, Ph.D., Area burned in the western United States is unaffected by recent mountain pine beetle outbreaks Published in the proceedings of the National Academy of Sciences, December 15, 201 http://www.pnas.org/content/112/14/4375.abstract ------Bark Beetle Opposing View #15 Article Excerpt: “We found that stands with recent high pre-fire tree mortality due to drought and insects did not burn at higher severity in coniferous forests of the San Bernardino Mountains, southern California, in the two fires we examined. Pollet and Omi [32] reported anecdotally that stands of lodgepole pine (P. contorta) that experienced an insect epidemic in the 1940s in Yellowstone National Park burned at lower severities compared to adjacent burned areas in the 1994 Robinson Fire. A widespread low-severity fire in subalpine forests in the White River National Forest, Colorado did not burn any beetle-affected stands [13]. Further, Bebi et al. [12] found that stands of Engelmann spruce (Picea engelmannii) and subalpine fir (A. lasiocarpa) in the White River National Forest influenced by a spruce beetle outbreak in the 1940s did not show higher susceptibility to 303 subsequent forest fires that burned after 1950. Our study area differed from these previous sites because most of the trees killed by insects and drought just prior to the fires in the San Bernardino Mountains were still standing and had retained needles. Despite differences in sites and forest types, previous studies and our results provide compelling evidence that when fire does occur, stands with considerable tree mortality due to drought and insects will not burn at higher severity than stands without significant tree mortality, either in the short or long term.”

Bond, Monica, Lee, Derek. Ph.D., Bradley, Curtis and Hanson, Chad, Ph.D., Influence of Pre- Fire Tree Mortality on Fire Severity in Conifer Forests of the San Bernardino Mountains, California The Open Forest Science Journal, 2009, 2, 41-47 http://www.biologicaldiversity.org/publications/papers/Bond_et_al.pdf ------Bark Beetle Opposing View #16 Article Excerpt: “Dead surface fuel loads of all size categories did not differ among undisturbed, red, and gray-stage stands. Compared to undisturbed sites, red and gray- stage sites had on average 53% lower canopy bulk density, 42% lower canopy fuel load, and 29% lower canopy moisture content, but had similar canopy base heights (3.1 m). In subsequent decades, coarse wood loads doubled and canopy base height declined to 0 m. Modeling results suggested that undisturbed, red, and gray-stage stands were unlikely to exhibit transition of surface fires to tree crowns (torching), and that the likelihood of sustaining an active crown fire (crowning) decreased from undisturbed to gray-stage stands. Simulated fire behavior was little affected by beetle disturbance when wind speed was either below 40 km/h or above 60 km/h, but at intermediate wind speeds, probability of crowning in red- and gray-stage stands was lower than in undisturbed stands, and old post-outbreak stands were predicted to have passive crown fires. Results were consistent across a range of fuel moisture scenarios. Our results suggest that mountain pine beetle outbreaks in Greater Yellowstone may reduce the probability of active crown fire in the short term by thinning lodgepole pine canopies.”

Martin Simard, Martin, Ph.D., Romme, William, Ph.D., Griffin, Jacob, Ph.D. and Turner, Monica, Ph.D., Do mountain pine beetle outbreaks change the probability of active crown fire in lodgepole pine forests? Published by the Ecological Society of America, 2011 http://www.esajournals.org/doi/abs/10.1890/10-1176.1 ------Bark Beetle Opposing View #17 Article Excerpt: “Mountain pine beetles are native to western forests, and they have evolved with the trees they infest, such as lodgepole pine and whitebark pine trees. However, in the last decade, warmer temperatures have caused pine beetle numbers to skyrocket. Huge areas of red, dying forest now span from British Columbia through Colorado, and there's no sign the outbreak is slowing in many areas.

The affected regions are so large that NASA satellites, such as Landsat, can even detect areas of beetle-killed forest from space. Today, NASA has released a new video about how scientists can use Landsat satellite imagery to map these pine beetle outbreaks, and what impact the beetle damage might have on forest fire.”

“Their preliminary analysis indicates that large fires do not appear to occur more often or with greater severity in forest tracts with beetle damage. In fact, in some cases, beetle-killed forest swaths may actually be less likely to burn. What they're discovering is in line with previous research on the subject.

The results may seem at first counterintuitive, but make sense when considered more carefully. First, while green needles on trees appear to be more lush and harder to burn, they contain high levels very flammable volatile oils. When the needles die, those flammable oils begin to break down. As a result, depending on the weather conditions, dead needles may not be more likely to catch and sustain a fire than live needles.

Second, when beetles kill a lodgepole pine tree, the needles begin to fall off and decompose on the forest floor relatively quickly. In a sense, the beetles are thinning the forest, and the naked trees left behind are essentially akin to large fire logs. However, just as you can't start a fire in a fireplace with just large logs and no kindling, wildfires are less likely to ignite and carry in a forest of dead tree trunks and low needle litter.”

NASA Sattelites Reveal Surprising Connection between Beetle Attacks, Wildfire A NASA publication, September 8, 2010 http://www.nasa.gov/topics/earth/features/beetles-fire.html ------Bark Beetle Opposing View #18 Article Excerpt: “But the public is being profoundly misled on these issues. First, trees killed by bark beetles do not increase fire intensity and spread. Numerous scientific studies have been published on this issue, and they consistently reach this conclusion. The most recent and most comprehensive of these, published this year in the Proceedings of the National Academy of Sciences, investigated whether recent tree mortality from bark beetles increased fire spread, studying forests across the western U.S., including forests throughout California. Lead author Sarah Hart and her co-authors concluded that "the annual area burned in the western United States has not increased in direct response to bark beetle activity."

Other studies have investigated whether forests with higher numbers of dead trees from bark beetles burn more intensely, and over and over again they have found no such increase in fire activity. A 2009 paper by Monica Bond et al, which I co-authored, looked at the same question in mixed-conifer forests in the San Bernardino National Forest in southern California. Again, the forests with the highest levels of snags from bark beetles did not burn more intensely.”

In Defense of The Bark Beetle by Chad Hanson, Phd., John Muir Project Aired by KCET public TV, October 14, 2015 http://www.kcet.org/news/redefine/rewild/commentary/in-defense-of-the-bark-beetle.html

------Bark Beetle Opposing View #19 Article Excerpt:

Forest officials agree: Beetle infestation doesn’t determine fire severity Report downplays correlation between tree die-offs, fires By Peter Marcus, Herald Denver Bureau Published by The Journal, November 17, 2015 http://www.cortezjournal.com/article/20151117/NEWS01/151119854/0/SEARCH/Forest- officials-agree:-Beetle-infestation-doesn%E2%80%99t-determine-fire-severity