Steamboat Project

Final Environmental Impact Statement

Appendix F

Response to Scientific Conclusion Papers
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-2

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Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-3

The following is a response to the scientific conclusions papers submitted by Dick Artley in response to 

the Steamboat Project DEIS. The numbering convention used on the papers as submitted are 

maintained here. The full text of the papers is located in the project file and is available upon request. 

Other comments submitted by Mr. Artley are addressed in Appendix E.

Response to Scientific Conclusions Paper #1

Citation: 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.pd

f

Quotation: None

Response: Habitat fragmentation was analyzed in the Phase II Amendment FEIS. If a project meets 

Forest Plan direction (as amended by Phase II) for structural stage distribution, fragmentation is not a 

concern. The Steamboat Project would contribute to the Forest-wide structural stage objectives for 

Management Area 5.4. 

The species with the highest level of concern regarding habitat fragmentation in the Black Hills is the 

pine marten. Marten are typically found in dense spruce habitat in the Black Hills. The Steamboat 

project area contains only 138 acres of spruce and no known occurrences of marten.

***

Citation: 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.alliancepipeline.com/contentfiles/45____Sediment_generation.pdf

Quotation: “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 that disturb soil surfaces such as 

site preparations, clear-cutting, log skidding, yarding, slash burns, heavy equipment operation and road 

construction and maintenance.”

Response: Impacts to soil and water resources are analyzed in detail in the Steamboat EIS (Section 3.8) 

and in the Hydrology and Soils Specialist Report.

***
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-4

Citation: “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

Quotation: “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).”

Response: The Forest Plan includes objectives for maintaining down and dead woody material on site 

and providing for age and class diversity through structural stage distributions. The Steamboat Project 

would contribute to those objectives as described in Forest Resources section (3.2). Some timber 

harvest methods (e.g. lop and scatter, cut-to-length) would contribute additional woody material to the 

units. These methods are avoided when fuel loading is of particular concern (within the WUI) but would 

be utilized in other areas.

***

Citation: 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

Quotation: “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.”

Response: The cited document was compiled by the cited author and the original author(s) are not 

clearly identified. This article does not cite specific scientific literature. It is an opinion piece expressing 

disagreement with the Bush administration’s environmental policy and the Forest Service’s 

implementation of the National Fire Plan, which is beyond the scope of the Steamboat Project.
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-5

***

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

June 1999, Volume 6, Number 5

http://www.sierraclub.org/planet/199905/ecl1.asp

Quotation: “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.”

Response: The quote is from an obviously biased anti-logging article with no clear scientific relevance 

to the Steamboat Project.

***

Citation: 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=&spo

n=&pagewanted=print

Quotation: “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.”
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-6

Response: This article reports on a 1999 OIG audit of the Forest Service. The Black Hills National Forest 

was not included in the audit. The Steamboat Project includes design criteria to prevent or minimize 

negative effects. Annual Black Hills National Forest monitoring reports and periodic Best Management 

Practice audits demonstrate that problems such as those described in the article are uncommon on this 

national forest.

***

Citation: Dombeck, Mike Ph.D. "Through the Woods" The News Hour with Jim Lehrer. 19 June 1998.

http://www.pbs.org/newshour/bb/fedagencies/jan-june98/road_6-19.html

Quotation: "The timber harvest shouldn't be dominant. It should be on an equal plane with recreation 

concerns, with wildlife concerns, hunting, fishing, protecting our cultural heritage. That's what the 

American public is asking us to do.”

Response: The quoted text is from a news program about the debate over roadless areas in Idaho in the 

late 1990s. It does not provide new information and its relevance to the Steamboat Project is not clear.

***

Citation: 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

Quotation: “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."

Response: The Steamboat DEIS does not disagree with the cited message. The analysis shows that 

proposed activities would not be expected to negatively affect long-term sustainability of any resource 

or value.

***

Citation: Ehrlich, Anne Ph.D., David Foster Ph.D. and Peter Raven Ph.D. 2002 “Call to End Logging Based 
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-7

on Conservation Biology.” Native Forest Network. 

http://www.nativeforest.org/campaigns/public_lands/stb_5_30_02.htm

Quotation: “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.”

Response: The benefits, and impacts, of the Steamboat Project on a wide range of resources including 

recreation, wildlife, and water is presented in Chapter 3 of the Steamboat EIS.

***

Citation: “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

Quotation: “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 misinformation about forest fires in order to benefit timber 

industry campaign contributors.”

Response: While claiming that there is little evidence to support timber thinning to reduce fire hazard, 

no evidence is provided to support the claim that “logging roads and industrial logging cause wildfires”. 

The Steamboat Project implements Forest Plan direction, which is based on scientific analysis 

summarized in the Forest Plan Revision FEIS and the Phase II Amendment FEIS.

***

Citation: 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
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-8

Quotation: "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)"

Response: The Steamboat EIS does not claim that forest reserves are unnecessary or undesirable or 

that all forest values are protected by logging (see analysis of effects in Chapter 3).

***

Citation: 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

Quotation: “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)

“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)

Response: The Steamboat Project would move the project area toward the Forest Plan structural stage 

objectives. It is unclear from this quoted text how those objectives are specifically flawed.

***

Citation: Giuliano, Jackie Alan, Ph.D. “Fire Suppression Bush Style: Cut Down the Trees!” Environmental 

News Service, 2008.

http://www.ens-newswire.com/ens/aug2002/2002-08-23g.asp

Quotation: “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 
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-9

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.’”

Response: No environmental laws have been undermined during development of the Steamboat 

Project. NEPA procedures have been adhered to and the project implements a Forest Plan that meets 

the requirement of NFMA.

***

Citation: 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

Quotation: "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 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."

Response: This report was prepared in 1999, prior to passage of the Healthy Forests Restoration Act of 

the 2003. The Steamboat DEIS does not dispute the findings of the report. While fire hazard reduction is 

one aspect of this project, activities are proposed in response to various Forest Plan objectives and 

public concerns. DEIS conclusions regarding the effects of thinning on fire hazard are based on peerreviewed literature (Agee and Skinner 2005, Agee et al. 2000, Graham and McCaffrey 2004, etc.). 

Funding practices across the Forest Service are beyond the scope of the Steamboat Project.

***

Citation: 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

Quotation: “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.”
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-10

“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)”

Response: The Black Hills National Forest, and the Steamboat project area, is almost entirely comprised 

of ponderosa pine. The concern of Douglas-fir creating a ladder fuel and increasing fire hazard or risk of 

insects and disease does not exist in the Steamboat project area.

KV funds are used to finance post-sale activities. However, any negative impacts to wildlife habitat are 

not mitigated through KV activities. KV activities might include habitat improvement projects, such as 

aspen or meadow enhancement, but any mitigation measures are not dependent on KV funds, they are 

built into the project in the form of design criteria, which are implemented during the timber sale and 

are entirely independent of KV funding.

***

Citation: Hanson, Chad. 2000. Commercial logging doesn't prevent catastrophic fires, it causes them. 

New York Times. May 19, 2000.

http://www.commondreams.org/views/051900-101.htm

Quotation: “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.”
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-11

“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.”

Response: While fire hazard reduction is one aspect of this project, activities are proposed in response 

to various Forest Plan objectives and public concerns. DEIS conclusions regarding the effects of thinning 

on fire hazard are based on peer-reviewed literature (Agee and Skinner 2005, Agee et al. 2000, Graham 

and McCaffrey 2004, etc.). The viewpoints described in this quote are not backed up by scientific 

research.

***

Citation: Hanson, Chad, Ph.D. “Logging for Dollars in National Forests” Special to The Sacramento Bee -

November 14, 2001

http://www.johnmuirproject.org/news-logging-for-dollars.html

Quotation: "The Forest Service keeps the vast majority of timber sale revenues, which gives it a 

perverse incentive to do more cutting. It has developed a huge bureaucracy around the selling of timber 

from national forest land."

Response: It is unclear how this quote relates directly to the Steamboat Project. The Steamboat 

Project does include commercial timber sales, which would be conducted in accordance with Forest Plan 

direction.

***

Citation: 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/L4

1/

Quotation: “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 ...”

Response: It is unclear how the reference editorials relate to the Steamboat Project. The Steamboat 

Project implement Forest Plan direction for reducing fire hazard and the risk of mountain pine beetle 

infestation as well as for providing structural diversity in big game winter range.

***

Citation: 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=l2sdf2

hphia2.alexandra
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-12

Quotation: "Logging reduces the organic parent material (duff and woody residues) available for soilformation processes."

Response: The Forest Plan includes an objective (212) for maintaining levels of dead and down woody 

material. The Steamboat DEIS includes an analysis of the effects to soils resources (Section 3.8).

***

Citation: 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

Quotation: "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."

Response: It is unclear how this quote specifically relates to the Steamboat Project. The Steamboat 

Project included public involvement as stipulated by NEPA.

***

Citation: H. R. 1494 text. April 4, 2001

http://www.agriculturelaw.com/legis/bills107/hr1494.htm

Quotation: "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."

Response: The Steamboat Project would have no impact to salmon fishing. Impacts to recreation are 

analyzed in the Steamboat DEIS (Section 3.11).

***

Citation: 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
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-13

Quotation: "Human tampering with nature has not been without costs. Human manipulation of 

existing ecosystems has also sometimes had unfortunate consequences."

Response: It is unclear how this quote directly relates to the Steamboat Project. Analysis of the impacts 

of the Steamboat Project are discussed in Chapter 3.

***

Citation: 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 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=C8D

DB611DB29D3716BBF313AADBA2E70?sequence=1

Quotation: “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.”

Response: This report summarizes, “There were large increases in potential smoke production from the 

historical to the current periods for many sample watersheds due to changes in fuel loadings associated 

with management activities and, presumably, fire suppression.” The Steamboat DEIS acknowledges the 

fire hazard posed by untreated activity fuels and includes measures to mitigate this hazard (pages 43-

44). It acknowledges the role of fire suppression in creating the existing conditions in the project area 

and proposes activities to move toward a more representative condition class (pages 12-13, Section 3.3).

***

Citation: 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

Quotation: "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 
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-14

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' without evidence of Congress or the QLG being aware of this history of previous fuelbreak 

programs."

Response: TheSteamboat DEIS acknowledges that timber harvest may have negative effects but 

demonstrates that the types of effects described in this paper (eroded topsoil, degraded water quality, 

destroyed wildlife habitat, and extirpated species) would not be expected to occur. Proposed shaded 

fuel breaks (as distinct from the California fuel breaks where no overstory was retained) may require 

periodic maintenance but would favor less flammable vegetation and would not be expected to become 

"a much more flammable vegetation type than the original forest cover".

***

Citation: Ingalsbee, Timothy Ph.D. 2000. “Commercial Logging for Wildfire Prevention: Facts Vs 

Fantasies”

http://www.fire-ecology.org/citizen/logging_and_wildfires.htm

Quotation: “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, 
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-15

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.”

Response: The Forest Plan and Phase II Amendment analysis was based on the best available science 

applicable to the Black Hills and ponderosa pine ecosystems. The Steamboat Project implements Forest 

Plan direction.

***

Citation: 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

Quotation: "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."

Response: While fire hazard reduction is one aspect of this project, activities are proposed in response 

to various Forest Plan objectives and public concerns (DEIS, pages 14-23). DEIS conclusions regarding the 

effects of thinning on fire hazard are based on peer-reviewed literature (Agee and Skinner 2005, Agee et 

al. 2000, Graham and McCaffrey 2004, etc.).

***

Citation: Ingalsbee, Timothy Ph.D. “The wildland fires of 2002 illuminate fundamental questions about 

our relationship to fire.” The Oregon Quarterly, Winter 2002

http://fireecology.org/research/wildfire_paradox.pdf

Quotation: “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)

Response: While fire hazard reduction is one aspect of this project, activities are proposed in response 

to various forest plan objectives and public concerns (DEIS, pages 14-23). DEIS conclusions regarding the 

effects of thinning on fire hazard are based on peer-reviewed literature (Agee and Skinner 2005, Agee et 

al. 2000, Graham and McCaffrey 2004, etc.). Proposed activities include non-commercial thinning and 

treatment of activity fuels to reduce fire hazard in treated areas (pages 43-44, 46-47).

***
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-16

Citation: 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

Quotation: "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 socalled '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 thinsized fire-susceptible understory trees. The resulting logging slash and the increased solar and wind 

exposure can paradoxically increase the fuel hazards and fire risks."

Response: While fire hazard reduction is one aspect of this project, activities are proposed in response 

to various forest plan objectives and public concerns (DEIS, pages 14-23). DEIS conclusions regarding the 

effects of thinning on fire hazard are based on peer-reviewed literature (Agee and Skinner 2005, Agee et 

al. 2000, Graham and McCaffrey 2004, etc.). Proposed activities include non-commercial thinning and 

treatment of activity fuels to reduce fire hazard in treated areas (pages 43-44, 46-47).

***

Citation: 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

Quotation: “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.”

Response: While fire hazard reduction is one aspect of this project, activities are proposed in response 
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-17

to various forest plan objectives and public concerns (DEIS, pages 14-23). DEIS conclusions regarding the 

effects of thinning on fire hazard are based on peer-reviewed literature (Agee and Skinner 2005, Agee et 

al. 2000, Graham and McCaffrey 2004, etc.). Proposed activities include non-commercial thinning and 

treatment of activity fuels to reduce fire hazard in treated areas (pages 43-44, 46-47).

***

Citation: 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.capp.ca/getdoc.aspx?DocId=24902&DT=PDF

Quotation: “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 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.”

Response: The Steamboat project area, and the Black Hills as a whole, does not contain any grizzly 

bears or wolverines.

***

Citation: Keene, Roy “Logging does not prevent wildfires” Guest Viewpoint, the Eugene Register Guard

January 11, 2009

http://www.highbeam.com/doc/1G1-192070397.html

Quotation: “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.”

Response: DEIS conclusions regarding the effects of thinning on fire hazard are based on peer-reviewed 

literature (Agee and Skinner 2005, Agee et al. 2000, Graham and McCaffrey 2004, etc.). Proposed 

activities include non-commercial thinning and treatment of activity fuels to reduce fire hazard in 

treated areas (pages 43-44, 46-47).
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-18

***

Citation: 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

Quotation: “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 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?”

Response: DEIS conclusions regarding the effects of thinning on fire hazard are based on peer-reviewed 

literature (Agee and Skinner 2005, Agee et al. 2000, Graham and McCaffrey 2004, etc.). Proposed 

activities include non-commercial thinning and treatment of activity fuels to reduce fire hazard in 

treated areas (pages 43-44, 46-47). Analysis of the impacts of the Steamboat Project to resources such 

as soil, water, plants and wildlife is presented in Chapter 3.

***

Citation: Keppeler, Elizabeth T. Robert R. Ziemer Ph.D., and Peter H. Cafferata "Effects of HumanInduced Changes on Hydrologic Systems." An American Water Resources Association publication, June 

1994

http://www.fs.fed.us/psw/publications/ziemer/Ziemer94a.PDF

Quotation: "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."

Response: Analysis of the impacts of the Steamboat Project on soil and water resources is presented in 

Section 3.8 of the DEIS.

***

Citation: Klein, Al 2004. Logging Effects on Amphibian Larvae Populations in Ottawa National Forest.

http://www.nd.edu/~underc/east/education/documents/AKlein2004Preloggingsurveyofamphibianlarvaeinvernalpools.pdf

Quotation: "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)."
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-19

"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 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."

Response: The Steamboat DEIS acknowledges potential negative effects associated with logging and 

includes design criteria (Appendix C) to prevent or minimize these effects. Potential effects on wetlands 

are disclosed in the DEIS in Section 3.8. Potential effects on amphibians of concern are summarized in 

Section 3.4 and discussed in more detail in the Wildlife and Fisheries Specialist Report and Biological 

Evaluation.

***

Citation: 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.

http://www.fs.fed.us/emc/hfi/president.pdf

Quotation: “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.”

Response: The Steamboat Project includes non-commercial thinning and prescribed burning in each of 

the action alternatives to reduce the number of small-diameter trees, shrubs and other fuels in the 

understory.

***

Citation: Lawrence, Nathaniel, NRDC senior attorney “Gridlock on the National Forests” Testimony 

before the U.S. Houseof Representatives Subcommittee on Forests and Forest
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-20

Health (Committee on Resources) December 4, 2001.

Quotation: “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.”

Response: DEIS conclusions regarding the effects of thinning on fire hazard are based on peer-reviewed 

literature (Agee and Skinner 2005, Agee et al. 2000, Graham and McCaffrey 2004, etc.). The Steamboat 

DEIS includes activity fuel treatment and non-commercial thinning to minimize the fire hazard posed by 

slash and pine regeneration. The analysis and monitoring data indicate that detrimental soil 

compaction is unlikely to occur or persist (DEIS, Section 3.8). 

***

Citation: 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

Quotation: “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.

Response: The Steamboat DEIS includes activity fuel treatment and non-commercial thinning to 

minimize the fire hazard posed by slash and pine regeneration.

***

Citation: 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://maps.wildrockies.org/ecosystem_defense/Resources_Species_Topics/Fire/Misuse%20of%20Fire

%20Plan%20funds.pdf

Quotation: "We concluded that commercial timber sales do not meet the criteria for forest 

restoration." (Pg. 11)

Response: The quoted text is specific to the National Fire Plan definition of "forest restoration" and 

expenditure of National Fire Plan funds to perform activities meeting that definition. The Steamboat 
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-21

Project would not use National Fire Plan funds.

***

Citation: 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/cgi/content/summary/283/5410/1996

Quotation: “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.”

Response: The quote refers to national policy, which is outside the scope of the Steamboat Project. It is 

unclear how this directly relates to the Steamboat Project.

***

Citation: 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/

Quotation: "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."

Response: The Forest Plan acknowledges the importance of woody debris, which is integral to the 

existence of microorganisms (e.g., objective 212, guidelines 1102a, 1204, 1205, 2307, 2308b). The 

Steamboat Project implements Forest Plan direction.

***

Citation: 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/

Quotation: "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)

Response: The effects of the Steamboat Project on soils, including erosion and nutrient levels, are 

analyzed in Section 3.8 of the DEIS. The Forest Plan acknowledges the importance of woody debris, 

which is integral to the existence of microorganisms (e.g., objective 212, guidelines 1102a, 1204, 1205, 

2307, 2308b). The Steamboat Project implements Forest Plan direction.
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-22

***

Citation: 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/

Quotation: "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.”

Response: The effects of the Steamboat Project on stream sedimentation and water temperature are 

discussed in Section 3.8 of the DEIS. The effects on wildlife habitat and select wildlife species are 

summarized in Section 3.4 and discussed in detail in the Wildlife and Fisheries Specialist Report and 

Biological Evaluation.

***

Citation: 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

Quotation: “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.”

Response: Effects of the Steamboat Project alternatives on streams are discussed in Section 3.8 of the 

DEIS.

***

Citation: 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://www.esa.org/science_resources/issues/TextIssues/issue4.php

Quotation: "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 
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-23

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."

Response: Analysis in the Steamboat DEIS did not identify any loss of species diversity as a result of the 

Steamboat Project. Potential effects to botanical and wildlife resources are discussed in the DEIS in 

Sections 3.4 and 3.5 as well as in the Wildlife and Fisheries Specialist Report and Biological Evaluation 

and the Botany Specialist Report and Biological Evaluation.

***

Citation: 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

Quotation: "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."

Response: This quote takes issue with national Forest Service programs, which are beyond the scope of 

the Steamboat analysis.

***

Citation: 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/cgi/content/abstract/277/5325/522?maxtoshow=&HITS=10&hits=10&RES

ULTFORMAT=&fulltext=logging&searchid=1136659907310_5043&FIRSTINDEX=0&journalcode=sci

Quotation: "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 

conservationand catchment purposes. Management strategies for sustainable forestry are being 

developed, but there is a need for furtherinteraction among foresters, ecologists, community 

representatives,social scientists, and economists."

Response: Sustainable management of national forests is required by NFMA and MUSYA. The 

Steamboat Project implements Forest Plan direction for providing structural diversity and multiple uses 

on a landscape scale. No loss of biodiversity is expected as a result of the Steamboat Project (DEIS, 

Sections 3.4 and 3.5).

***
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-24

Citation: 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

Quotation: "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."

"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'."

Response: It is unclear how a survey conducted in Vermont regarding the Green Mountain National 

Forest is pertinent to the Steamboat Project.

***

Citation: Okoand Ilan Kayatsky, Dan. “Fight Fire with Logging?” Mother Jones, August 1, 2002

http://www.motherjones.com/news/feature/2002/08/fireplan.html

Quotation: “Still, forestry experts warned in the 2000 plan that logging should be used carefully and 

rarely; in fact, the original draft states plainly that the "removal of large merchantable trees from forests 

does not reduce fire risk and may, in fact, increase such risk."
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-25

“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.”

Response: While fire hazard reduction is one aspect of this project, activities are proposed in response 

to various Forest Plan objectives and public concerns (DEIS, pages 14-23). DEIS conclusions regarding the 

effects of thinning on fire hazard are based on peer-reviewed literature (Agee and Skinner 2005, Agee et 

al. 2000, Graham and McCaffrey 2004, etc.).

***

Citation: Parfitt, Ben and Laurel Brewster. 2000. "Muddied Waters: The Case for Protecting Water 

Sources in B.C." A publication of: the Tuwanek Ratepayers Association, the Red Mountain Residents 

Association, the B.C. Watershed Stewardship Alliance, and the B.C. Tap Water Alliance.

http://www.library.for.gov.bc.ca/ipac20/ipac.jsp?session=1RW012320B660.2434272&profile=mof&sour

ce=~!forest&view=subscriptionsummary&uri=full=3100001~!46491~!9&ri=1&aspect=basic_search&me

nu=search&ipp=20&spp=20&staffonly=&term=parfitt&index=.GW&uindex=&aspect=basic_search&men

u=search&ri=1#focus

Quotation: "Each year in British Columbia more than 200,000 hectares of forest is logged, the majority 

of it clearcut."

"Almost all of that logging activity takes place in watersheds or forested valleys that contain important 

surface water supplies such as reservoirs, lakes, rivers or streams. Often, valleys contain a multitude of 

water bodies connected with one another. The small ephemeral streams in a valley’s upper reaches 

feed into bigger creeks that carry water into valley-bottom rivers."

"This report examines the costs to human communities and fisheries when logging-related damage to 

these interconnected and finely balanced water systems occurs."

"As this report reveals, the costs are extremely high. If the 100 B.C. communities outside of Vancouver 

and Victoria who currently use unfiltered water from surface sources were forced to filter their water to 

get rid of unwanted sediments, the cost would be about $700 million. The ongoing cost of running the 

new filtration plants would be about $30 million annually. Such costs can be avoided, but only if landuse practices around surface supplies don’t muddy the water."

"Logging in watersheds also poses significant threats to the environment, particularly the critically 

important in-stream habitats of spawning and rearing salmon. Every time a logging road or logging 

operation triggers increased water runoff into streams, chances are high that elevated levels of 

sediment and debris are washed into waterways inhabited by fish."

"To date, more than $300 million in public money has been channeled through the Crown Corporation, 

Forest Renewal BC, to pay for “watershed restoration” projects in the province. Expenditures to clean 

up streams and surrounding hillsides damaged by logging activities continue. It was recently estimated 

that up to 40 years of funding might be required to rehabilitate salmon habitat and surrounding forests 
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-26

damaged by logging."

"Clearly, the public has paid and will continue to pay a steep price for logging practices that damage 

surface waters."

Response: The Steamboat Project does not proposed large-scale clearcutting. Patch clearcuts are 

proposed, which would create small open areas (less than 10 acres) to increase structural diversity and 

to provide browsing areas for deer, elk and other wildlife. The effects of the Steamboat alternatives on 

watersheds are described in the hydrology and soils section of the DEIS (Section 3.8).

***

Citation: Peters, Robert L. Ph.D, Evan Frost, and Felice Pace. 1996 “Managing for Forest Ecosystem 

Health: A Reassessment of the ‘Forest Health Crisis”

http://www.magicalliance.org/Forests/Forest%20Health%20Evaluated.htm

Quotation: “Traditionally, the term ‘forest health’ has been used in a limited, utilitarian sense by 

professional foresters to refer to the growth and vigor of trees (see Kolb et al. 1994). For example, 

according to one Forest Service publication, a forest is healthy when "biotic and abiotic influences on 

forests do not threaten management objectives now or in the future" (USFS 1993). From this 

perspective, a forest is healthy if trees are free from insects and pathogens and growing at maximum 

rates; it is unhealthy if trees are dead or dying. Anything that decreases or threatens to decrease yield 

(insects, disease, decaying trees, fire) is something to be controlled or eliminated. Managers therefore 

argue for removal and commercial utilization of trees that are perceived to be in danger from such 

threats.”

“However, many conservationists and forest scientists have expressed concern about such thinking. 

This narrow definition of forest health does not consider the health of the entire ecosystem, such as 

water and soil quality and the diversity and interactions of other life forms. It does not provide guidance 

for management of resources other than timber. It has encouraged foresters to simplistically view 

insects and other non-timber elements of forest ecosystems as good or bad, based only on how they 

affect the growth rates of commercial tree species.”

“When viewing forests from an ecosystem health perspective, scientists do not recognize the ‘forest 

health crisis’ described by the proponents of salvage logging who are concerned about losing 

economically valuable timber to fire or insects. To the scientists, insects, disease and fire are normal 

parts of healthy ecosystems, essential for forest regeneration, cycling of nutrients and maintaining a 

variety of dead and living trees for wildlife habitat. Attempts to control or eliminate these agents may 

lead to unforeseen and undesirable consequences. For example, widespread removal of dead and dying 

trees eliminates habitat required by bird species that feed on insects that attack living trees, with the 

result that outbreaks of pests may increase in size or frequency (Torgersen et al. 1990).”

Response: The Steamboat DEIS analyzes the impacts to a variety of resources including plants, wildlife, 

soils and water, and scenery. 

***

Citation: Peterson, Mike testimony to the Senate Agriculture, Nutrition, and Forestry Committee 
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-27

concerning the Healthy Forests Restoration Act, HR 1904. June 26 2003

http://agriculture.senate.gov/Hearings/testimony.cfm?id=824&wit_id=2258

Quotation: “H.R 1904 does not include any specific measures to protect homes or communities. It is 

also inconsistent with the Western Governors' Association 10-Year Comprehensive Strategy, which does 

not call for any changes in existing laws. The only proven method to protect homes and communities is 

to reduce flammable materials in the immediate vicinity of structures, yet the definitions in H.R. 1904 

would not require any activities to be near homes. Instead, the bill seeks to further subsidize the timber 

industry and eliminate obstacles to logging large, fire-resistant trees miles away from the nearest home. 

The country's top forest scientists, including the Forest Service's own scientists, have found that this 

kind of logging can actually increase fire risk and make fires larger and more intense.”

Response: The Steamboat Project does not implement the HFRA. While fire hazard reduction is one 

aspect of the Steamboat Project, activities are proposed in response to various forest plan objectives 

and public concerns (DEIS pages 14-23). DEIS conclusions regarding the effects of thinning on fire hazard 

are based on peer-reviewed literature (Agee and Skinner 2005, Agee et al. 2000, Graham and McCaffrey 

2004, etc.).

***

Citation: 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 of American Geographers. Sep. 8, 2006

http://www.ingentaconnect.com/content/routledg/anna/2006/00000096/00000003/art00001

Quotation: “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.”

Response: The Steamboat Project does not implement the HFRA. While fire hazard reduction is one 

aspect of the Steamboat Project, activities are proposed in response to various forest plan objectives 

and public concerns (DEIS pages 14-23). DEIS conclusions regarding the effects of thinning on fire hazard 
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-28

are based on peer-reviewed literature (Agee and Skinner 2005, Agee et al. 2000, Graham and McCaffrey 

2004, etc.).

***

Citation: 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

Quotation: "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."

Response: This is an extremely general term that has no clear connection to the Steamboat project area 

or the Black Hills National Forest.

***

Citation: Quigley, Thomas M. Ph.D., Richard W. Haynes and Russell Graham Tech. editors. 1996. 

“Integrated Scientific Assessment for Ecosystem Management in the Interior Columbia Basin

and Portions of the Klamath and Great Basins.” USDA Forest Service, PNW-GTR-382, 303 p.

http://www.fs.fed.us/pnw/publications/icbemp.shtml

Quotation: "Fire severity has generally increased and fire frequency has generally decreased over the 

last 200 years. The primary causative factors behind fire regime changes are effective fire prevention 

and suppression strategies, selection and regeneration cutting, domestic livestock grazing, and the 

introduction of exotic plants."

Response: The Steamboat DEIS acknowledges the roles of fire suppression and historic timber harvest 

in modifying Black Hills fire regime/condition class (pages 12-13 and Section 3.3).

***

Citation: 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

Quotation: “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.
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-29

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.

• 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.”

Response: The Act to Save America’s Forests was not passed and is not currently directing federal 

actions on national forests. The Steamboat Project implements Forest Plan direction, which complies 

with NFMA and MUSYA. Traditional, large-scale clearcutting is not included in the Steamboat Project. 

Harvest in roadless areas is not included. Sensitive riparian areas, watershed influence zones and 

biological sensitive areas (i.e., rare plant habitat, goshawk nest areas) are protected through design 

criteria (DEIS, Appendix C). Even-aged management is a silviculturally appropriate method for managing 

Black Hills ponderosa pine.

***

Citation: Raven, Peter, Ph.D.,from his February 9, 2001 letter to Senator Jean Carnahan

Quotation: “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.”

Response: The Act to Save America’s Forests was not passed and is not currently directing federal 

actions on national forests. The Steamboat Project implements Forest Plan direction, which complies 
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-30

with NFMA and MUSYA. Traditional, large-scale clearcutting is not included in the Steamboat Project. 

Harvest in roadless areas is not included. Sensitive riparian areas, watershed influence zones and 

biological sensitive areas (i.e., rare plant habitat, goshawk nest areas) are protected through design 

criteria (DEIS, Appendix C). Even-aged management is a silviculturally appropriate method for managing 

Black Hills ponderosa pine.

***

Citation: 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

Quotation: “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).”

Response: The DEIS acknowledges the fire hazard posed by untreated activity fuels and includes 

measures to mitigate this hazard (pages 43-44). It acknowledges the role of fire suppression in creating 

the existing conditions in the project area and proposes activities to move toward a more representative 

condition class (pages 12-13, Section 3.3). Also, while fire hazard reduction is one aspect of this project, 

activities are proposed in response to various Forest Plan objectives and public concerns (DEIS pages 14-

23). DEIS conclusions regarding the effects of thinning on fire hazard are based on peer-reviewed 

literature (Agee and Skinner 2005, Agee et al. 2000, Graham and McCaffrey 2004, etc.).

***

Citation: 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://74.125.113.132/search?q=cache:QNy_aih1RxEJ:edennapa.org/thp/roelofstestimony.doc+%22tim

ber+harvest%22+ph.d.+adverse&hl=en&ct=clnk&cd=5&gl=us

Quotation: “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 
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-31

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 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.”

Response: Salmon and steelhead do not occur in the Steamboat project area or the Black Hills National 

Forest. Effects of the Steamboat Project on streams are analyzed in Section 3.8. Effects to select fish 

species are analyzed in Section 3.4.

***

Citation: Rudzitis, Gundars. 1999 “Amenities Increasingly Draw People to the Rural West” Rural 

Development Perspectives, vol. 14, no. 2

http://www.ers.usda.gov/publications/rdp/rdpsept99/rdpsept99b.pdf

Quotation: “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.”

Response: The relevance of the cited article to the Steamboat Project is not clear. The project would 

implement the Forest Plan, which was developed with public input. The range of alternatives and issues 

described in the Steamboat DEIS are based on public input. Public comments reflected a range of 

opinions.

***

Citation: 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

Quotation: “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 
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-32

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 biomass per acre than a natural forest of the same age, but a simplified forest produces a higher volume of 

merchantable timber.

Response: Large-scale clearcutting is not proposed in the Steamboat Project. Patch clearcuts would be 

used to create small openings (less than 10 acres) to increase structural diversity. Forest stands in the 

Black Hills are not harvested until they have reached culmination of mean annual increment (CMAI). 

Compliance with CMAI requirements is documented in Appendix B of the Steamboat DEIS.

***

Citation: 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

Quotation: “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.”

Response: The Healthy Forest Initiative led to the Healthy Forests Restoration Act (HFRA). The 

Steamboat Project does not implement HFRA guidance.

***

Citation: Sierra Club. 2005 “Ending Commercial Logging on Public Lands” 

http://northcarolina.sierraclub.org/pisgah/conservation/ecl.html

Quotation: “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.
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-33

(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.”

Response: National-level direction regarding management of the National Forests is beyond the scope 

of the Steamboat analysis.

***

Citation: 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

Quotation: “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 harvesting. Impacts on integrated 

watershed behavior are assessed through disturbed sediment budgets and lake sediments.”

Response: Effects on soil and water resources in the Steamboat project area are analyzed in Section 3.8 

of the DEIS.

***

Citation: 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

Quotation: “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.”

Response: The Steamboat DEIS acknowledges the fire hazard posed by untreated activity fuels and 

includes measures to mitigate this hazard (pages 43-44, Section 3.3). It acknowledges the role of fire 

suppression in creating the existing conditions in the project area and proposes activities to move 
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-34

toward a more representative condition class (pages 12-13, Section 3.3). Fire suppression is required by 

the Forest Plan and is beyond the scope of the Steamboat project. The Steamboat Project is not 

implementing HFRA (HR 1904) authorities.

***

Citation: 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

Quotation: “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. 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.”

Response: This commentary does not provide new scientific information. The Steamboat DEIS 

acknowledges the fire hazard posed by untreated activity fuels and includes measures to mitigate this 

hazard (pages 43-44, Section 3.3). It acknowledges the role of fire suppression in creating the existing 

conditions in the project area and proposes activities to move toward a more representative condition 

class (pages 12-13, Section 3.3). The DEIS recognizes the benefits of wildland fire (Section 3.3).

***

Citation: Taxpayers for Common Sense. “From the Ashes: Reducing the Harmful Effects and Rising Costs 

of Western Wildfires” Washington DC , Dec. 2000

http://www.ourforests.org/fact/ashes.pdf

Quotation: “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)
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-35

“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)

Response: This paper supports Taxpayers for Common Sense's Forest Service Budget Reform Campaign 

and takes issue with nationwide Forest Service programs. These are beyond the scope of the Steamboat 

analysis. DEIS conclusions regarding the effects of thinning on fire hazard are based on peer-reviewed 

literature (Agee and Skinner 2005, Agee et al. 2000, Graham and McCaffrey 2004, etc.). The DEIS 

acknowledges the fire hazard posed by untreated activity fuels and includes measures to mitigate this 

hazard (pages 43-44, Section 3.3). It acknowledges the role of fire suppression in creating the existing 

conditions in the project area and proposes activities to move toward a more representative condition 

class (12-13, Section 3.3).

***

Citation: 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

Quotation: “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.”

Response: DEIS conclusions regarding the effects of thinning on fire hazard are based on peer-reviewed 

literature (Agee and Skinner 2005, Agee et al. 2000, Graham and McCaffrey 2004, etc.). The DEIS 

acknowledges the fire hazard posed by untreated activity fuels and includes measures to mitigate this 

hazard (pages 43-44, Section 3.3).

***

Citation: 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://ceres.ca.gov/snep/pubs/web/PDF/v1_ch04.pdf

Quotation: "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)

Response: DEIS conclusions regarding the effects of thinning on fire hazard are based on peer-reviewed 

literature (Agee and Skinner 2005, Agee et al. 2000, Graham and McCaffrey 2004, etc.). The DEIS 

acknowledges the fire hazard posed by untreated activity fuels and includes measures to mitigate this 
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-36

hazard (pages 43-44, Section 3.3).

***

Citation: USDA Forest Service. "Forest Management: A Historical Perspective."

http://www.fs.fed.us/forestmanagement/aboutus/histperspective.shtml

Quotation: "During the post-World War II housing boom, national forests were viewed as a ready 

supply of building material. The increased demand for timber from national forests led to more 

widespread use of commodity-oriented harvesting techniques such clearcutting. Along with the 

increased logging that followed, concern over the environment increased. In the 1960's and 1970's, 

several laws were enacted to protect forests. Additional laws formalized the concept of "multiple-use," 

whereby the uses of timber, forage, and water shared equal footing with wildlife conservation and 

recreation opportunities."

Response: It is not clear how this quote specifically relates to the Steamboat Project. Chapter 3 of the 

DEIS analyzes the effects of the project to several different resource areas (wildlife, botany, soil and 

water, etc.).

***

Citation: 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.

http://www.icbemp.gov/science/vincent.pdf

Quotation: "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 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."

Response: Forest Service policy requires a financial efficiency analysis at the project level. This analysis 

appears in Section 3.14 of the DEIS. Non-market values are not included in this type of analysis but are 

considered in the project decision.

***

Citation: Voss, René “Getting Burned by Logging,” July 2002 The Baltimore Chronicle

http://www.baltimorechronicle.com/firelies_jul02.shtml

Quotation: “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. 
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-37

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.’ “

Response: While fire hazard reduction is one aspect of this project, activities are proposed in response 

to various Forest Plan objectives and public concerns. DEIS conclusions regarding the effects of thinning 

on fire hazard are based on peer-reviewed literature (Agee and Skinner 2005, Agee et al. 2000, Graham 

and McCaffrey 2004, etc.).

***

Citation: 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

Quotation: “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.”

Response: DEIS conclusions regarding the effects of thinning on fire hazard are based on peer-reviewed 

literature (Agee and Skinner 2005, Agee et al. 2000, Graham and McCaffrey 2004, etc.). The DEIS 

acknowledges the fire hazard posed by untreated activity fuels and includes measures to mitigate this 

hazard (pages 43-44, Section 3.3).

***

Citation: 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/

Quotation: “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.”
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-38

Response: The Steamboat DEIS discloses effects on soil health, sensitive wildlife and plant species, 

water quality, invasive species, late succession forest, and fire regime. The analysis found that proposed 

activities could cause both beneficial and detrimental effects, but that implementation of design criteria 

would prevent or minimize negative effects.

***

Citation: 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

Quotation: "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 collapse some of the subsurface pipes, 

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

Response: It is unclear how this is specific to the Steamboat project area. The potential for mass 

movement (i.e., landslides) is analyzed in Section 3.8 of the DEIS. While areas of soils prone to mass 

movement occur in the Steamboat project area, the risk of mass movement is reduced or eliminated 

through implementation of WCPs, BMPs and design criteria.

***

Citation: From an April 16, 2002 letter to President Bush asking him to stop all logging in the national 

forests.

http://www.forestwatch.org/content.php?id=108

Quotation: “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.”
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-39

Response: The Steamboat Project implements Forest Plan direction for management of the Black Hills 

National Forest. The Forest Plan as amended by Phase II was developed with public input, was upheld 

on appeal and was not challenged legally. Likewise, the Steamboat Project was developed with the help 

of public involvement as required by NEPA.

***

Citation: Partridge, Arthur Ph.D., Statement at a Press Conference with Senator Robert Torrice lli

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

Quotation: “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.”

Response: The effects of the proposed activities on soils, watersheds, botanical resources and wildlife 

are disclosed in Chapter 3 of the DEIS. The analysis and methods described within the DEIS are based on 

the best available science.

Response to Scientific Conclusions Paper #4

Citation: Al-jabber, Jabber M. 2003 “Habitat Fragmentation: Effects and Implications”

http://faculty.ksu.edu.sa/a/Documents/Habitat%20Fragmentation%20Effects%20and%20Implication.pd

f

Quotation: “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, 
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-40

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)

Response: Habitat fragmentation was analyzed in the Phase II Amendment FEIS. If a project meets 

Forest Plan direction (as amended by Phase II) for structural stage distribution, fragmentation is not a 

concern. The Steamboat Project would contribute to the Forest-wide structural stage objectives for 

Management Area 5.4. 

The species with the highest level of concern regarding habitat fragmentation in the Black Hills is the 

pine marten. Marten are typically found in dense spruce habitat in the Black Hills. The Steamboat 

project area contains only 138 acres of spruce and no known occurrences of marten.

***

Citation: 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

Quotation: "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."

Response: Geology and soil conditions in the Black Hills are different from those in the Klamath 

Mountains. The potential for mass movement was assessed in Section 3.8 of the Steamboat DEIS. Any 

activities conducted on soils prone to mass movement would be subject to WCPs, BMPs and design 

criteria to reduce or eliminate the risk of mass movement.

***

Citation: “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

Quotation: " ‘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.”

Response: The impact of roads on streams is discussed in Section 3.8 of the Steamboat DEIS. 
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-41

Implementation of WCPs, BMPs and design criteria would greatly reduce or eliminate impacts from new 

road construction. Repair of existing connected disturbed areas (CDAs) would reduce the impact that 

existing roads are having on stream in the project area.

***

Citation: 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

Quotation: “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.”

Response: The impacts of road construction and maintenance on project area streams are analyzed in 

Section 3.8 of the Steamboat DEIS. This section also discusses the potential for mass movement and the 

mitigation measures in place to prevent mass movement from occurring. 

***

Citation: 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 Geophysical Union, San Francisco, CA, December 1996.

http://www.ce.washington.edu/~lxb/poster.html

Quotation: “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.”

Response: Large-scale clearcutting is not proposed in the Steamboat Project. Each action alternative 

includes 190 acres of patch clearcuts. In these units, small open areas (no larger than 10 acres each) 

would be created by removing pine. These patches are not comparable to the large cut-blocks referred 

to in the quote. Impacts to streams as a result of the road network are analyzed in Section 3.8.
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-42

***

Citation: Brister, Daniel. “A Review and Comment on: Forest Service Roads: A Synthesis of Scientific 

Information, 2nd Draft, USDA Forest Service.” December 1998.

http://www.wildlandscpr.org/forest-service-roads-synthesis-scientific-information-socio-economicimpacts

Quotation: “Many of the conclusions and assumptions contained in the Roads Report are based on 

analysis of the positive contributions of roads. Negative socio-economic effects of roads have been, in 

large part, glossed over. The general view expressed in the Roads Report is that overall, roads make a 

positive socio-economic contribution.”

“The Socio-Economic Effects section has been constructed to overwhelmingly support the contention 

that the benefits of roads outweigh the costs. In order to arrive at such a conclusion, however, certain 

important economic costs and concepts have been omitted.”

“A serious problem with the Roads Report is its lack of discussion concerning the economic costs arising 

from the negative ecological effects of roads. Despite overwhelming scientific data linking roads and 

sedimentation (Bennett 1991; Grayson et al. 1993; Lyon 1984; Megahan 1980; McCashion and Rice 

1983; Wade 1998; Williams 1998), the socio-economic costs of mitigating the effects of this 

sedimentation receive no mention in the Roads Report. Such costs are central to and should be 

included in any socio-economic assessment of forest roads.”

“The present road system constitutes a legacy of current and potential sources of damage to aquatic 

and riparian habitats, mostly through sedimentation, and to terrestrial habitats through fragmentation 

and increased access” (Amaranthus et all 1985).”

“The failure of the Report to properly address mitigation costs associated with the ecological effects is a 

serious problem that needs to be addressed in future drafts. Similarly, passive-use values need to be 

taken seriously and considered throughout the Roads Report. In order to rectify these problems, most 

of the Socio-Economic Effects subsections will have to be reworked. Failing to do so, the Roads Report 

will paint an incomplete picture of the costs and benefits associated with the Forest Service’s road 

program.”

Response: The quoted text emphasizes that roads can have negative effects. The DEIS acknowledges 

potential negative effects associated with roads and includes design criteria (Appendix C) to prevent or 

minimize these effects. Potential effects are disclosed in discussions of invasive species (Section 3.6), 

water and soils (Section 3.8), and wildlife and plant species (Sections 3.4 and 3.5).

***

Citation: Bunnell, Fred L. Ph.D., Kelly A. Squires and Isabelle Houde. 2004 “Evaluating effects of largescale 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

Quotation: “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 
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-43

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.”

Response: The quoted text addresses clearcutting, riparian harvesting, landslide risk, and road effects. 

The Steamboat Project does not propose large-scale clearcutting or riparian harvesting. Risk of mass 

movement is discussed in Section 3.8 and mitigation measures are in place to reduce or eliminate the 

risk. The DEIS acknowledges potential negative effects associated with roads and includes design criteria 

(Appendix C) to prevent or minimize these effects. Potential effects on water and soils are disclosed in 

Section 3.8. Potential effects to fish are discussed in Section 3.4 and in the Wildlife and Fisheries 

Specialist Report.

***

Citation: Burns, James W., “Some Effects of Logging and Associated Road Construction on Northern 

California Streams.” Transactions of theAmerican Fisheries Society, Volume 1, Number 1, January 1972.

http://www.fs.fed.us/psw/publications/4351/Burns72.pdf

Quotation: “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.”

Response: Effects to wildlife and fisheries are discussed in Section 3.4 of the DEIS and in the Wildlife 

and Fisheries Specialist Report.

***

Citation: Buttenfield, Barbara P. Ph.D. and David R. Cameron “Scale Effects and Attribute Resolution in 

Ecological Modeling” A paper presented at 4th International Conference on Integrating GIS and 

Environmental Modeling Banff, Alberta, Canada, September 2 – 8, 2000

http://www.colorado.edu/research/cires/banff/pubpapers/158/

Quotation: “In the temporal analysis, from 1950 to 1993, logging and road building in the study area 
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-44

clearly modified landscape patterns. Increased landscape fragmentation is evident in measures of

smaller mean patch and core areas, reduced patch size variability, increased patch and edge density, 

and higher edge contrast.”

Response: It is not clear, in either time or space, how this relates directly to the Steamboat Project. 

Habitat fragmentation was analyzed in the Phase II Amendment FEIS. If a project meets Forest Plan 

direction (as amended by Phase II) for structural stage distribution, fragmentation is not a concern. The 

Steamboat Project would contribute to the Forest-wide structural stage objectives for Management 

Area 5.4.

***

Citation: deMaynadier, Phillip G. and Malcolm L. Hunter, Jr. “Road Effects on Amphibian Movements in 

a Forested Landscape” 

http://www.magicalliance.org/Fragmentation/road_effects_on_amphibian_moveme.htm

Quotation: “The total area of land converted to road surface and shoulder clearance for permanent 

logging roads can represent a significant loss of former habitat in densely roaded regions. In this study, 

six acres of forest habitat were lost for every linear mile of road. Stewards of natural areas and 

managed forests who are concerned about the potential impacts of secondary roads on sensitive 

species should construct fewer and narrower roads with little or no edge clearance.”

Response: The effects of road construction on wildlife habitat are discussed in Section 3.4 of the 

Steamboat DEIS.

***

Citation: 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%20Dombeck%27

s%20Remarks%20to%20Forest%20Service%20Employees%20and%20.htm

Quotation: “Roads often cause serious ecological impacts. There are few more irreparable marks we 

can leave on the land than to build a road.”

Response: The DEIS acknowledges potential negative effects associated with roads and includes design 

criteria (Appendix C) to prevent or minimize these effects. Potential effects are disclosed in discussions 

of invasive species (Section 3.6), water and soils (Section 3.8), and wildlife and plant species (Sections 

3.4 and 3.5).

***

Citation: EPA entry into the Federal Register: March 3, 2000 (Volume 65, Number 43) Page 11675, 

“National Forest System Road Management.”

http://www.epa.gov/fedrgstr/EPA-GENERAL/2000/March/Day-03/g5002.htm

Quotation: “Few marks on the land are more lasting than roads.”
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-45

“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 humancaused fires.”

Response: The DEIS acknowledges potential negative effects associated with roads and includes design 

criteria (Appendix C) to prevent or minimize these effects. Potential effects are disclosed in discussions 

of invasive species (Section 3.6), water and soils (Section 3.8), and wildlife and plant species (Sections 

3.4 and 3.5).

***

Citation: “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

Quotation: “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.”

Response: The DEIS acknowledges potential negative effects associated with roads and includes design 

criteria (Appendix C) to prevent or minimize these effects. Potential effects are disclosed in discussions 

of invasive species (Section 3.6), water and soils (Section 3.8), and wildlife and plant species (Sections 

3.4 and 3.5).

***

Citation: 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&journalCo

de=ecolsys.1

Quotation: “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 
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-46

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.”

Response: The DEIS acknowledges potential negative effects associated with roads and includes design 

criteria (Appendix C) to prevent or minimize these effects. Potential effects are disclosed in discussions 

of invasive species (Section 3.6), water and soils (Section 3.8), and wildlife and plant species (Sections 

3.4 and 3.5).

***

Citation: 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

Quotation: “Questions to consider: Roads dramatically alter forest ecosystems

U.. 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)

Response: The DEIS acknowledges potential negative effects associated with roads and includes design 

criteria (Appendix C) to prevent or minimize these effects. Potential effects are disclosed in discussions 

of invasive species (Section 3.6), water and soils (Section 3.8), and wildlife and plant species (Sections 

3.4 and 3.5). Alternative D was developed in response to the issue of new road construction. 

Alternative D does not include any new roads.

***

Citation: 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/

Quotation: “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.”

Response: The Steamboat project area does not include any designated roadless areas.

***

Citation: Furniss, Michael J., Michael Love Ph.D. and Sam A. Flanagan “Diversion Potential at RoadStream Crossings.” USDA Forest Service. 9777 1814—SDTDC. December 1997.

http://www.stream.fs.fed.us/water-road/w-r-pdf/diversionpntl.pdf
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-47

Quotation: “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.”

Response: The DEIS acknowledges potential negative effects associated with roads and includes design 

criteria (Appendix C) to prevent or minimize these effects. Potential effects are disclosed in discussions 

of invasive species (Section 3.6), water and soils (Section 3.8), and wildlife and plant species (Sections 

3.4 and 3.5). 

***

Citation: 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/

Quotation: “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.”

Response: The DEIS acknowledges potential negative effects associated with roads and includes design 

criteria (Appendix C) to prevent or minimize these effects. Potential effects are disclosed in discussions 

of invasive species (Section 3.6), water and soils (Section 3.8), and wildlife and plant species (Sections 

3.4 and 3.5). 

***

Citation: 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 
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-48

publication unknown]: International Erosion Control Association: 301-310.

http://www.srs.fs.usda.gov/pubs/ja/ja_grace011.pdf

Quotation: “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).

Response: The DEIS acknowledges potential negative effects associated with roads and includes design 

criteria (Appendix C) to prevent or minimize these effects. Potential effects are disclosed in discussions 

of invasive species (Section 3.6), water and soils (Section 3.8), and wildlife and plant species (Sections 

3.4 and 3.5).

***

Citation: 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

Quotation: “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.”

Response: The DEIS acknowledges potential negative effects associated with roads and includes design 

criteria (Appendix C) to prevent or minimize these effects. Potential effects are disclosed in discussions 

of invasive species (Section 3.6), water and soils (Section 3.8), and wildlife and plant species (Sections 

3.4 and 3.5).

***

Citation: 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

Quotation: “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.”

Response: The quoted text is from a technical report specific to the Interior Columbia Basin. Its specific 
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-49

relevance to the Black Hills or Steamboat project area are unclear. Treatments proposed in the 

Steamboat project area would reduce surface fuel loading and stand density. The proposed road 

network provides greater access to the Forest in the event of a fire, allowing firefighters to reach the fire 

more quickly.

***

Citation: 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

Quotation: “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.”

Response: It is unclear how a study conducted in deciduous forest of the southern Appalachian 

Mountains applies to the coniferous forest of the Black Hills. The DEIS acknowledges potential negative 

effects associated with roads and includes design criteria (Appendix C) to prevent or minimize these 

effects. Potential effects are disclosed in discussions of invasive species (Section 3.6), water and soils 

(Section 3.8), and wildlife and plant species (Sections 3.4 and 3.5).

***

Citation: 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

Quotation: “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.”

Response: The DEIS acknowledges potential negative effects associated with roads and includes design 

criteria (Appendix C) to prevent or minimize these effects. Potential effects are disclosed in discussions 
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-50

of invasive species (Section 3.6), water and soils (Section 3.8), and wildlife and plant species (Sections 

3.4 and 3.5).

***

Citation: Ivins, Molly Creators Syndicate, August 3 1997 08 03

http://www.creators.com/opinion/molly-ivins/molly-ivins-august-3-1997-08-03.html

Quotation: “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 boardfeet of lumber in that stand. Try to find a price like that at Home Depot.”

Response: The DEIS acknowledges potential negative effects associated with roads and includes design 

criteria (Appendix C) to prevent or minimize these effects. Potential effects are disclosed in discussions 

of invasive species (Section 3.6), water and soils (Section 3.8), and wildlife and plant species (Sections 

3.4 and 3.5). The assertions that the Forest Service subsidizes overseas companies or is a branch of the 

logging industry is opinion and outside the scope of the Steamboat Project.

***

Citation: 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

Quotation: “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.”

Response: The DEIS acknowledges potential negative effects associated with roads and includes design 

criteria (Appendix C) to prevent or minimize these effects. Potential effects are disclosed in discussions 
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-51

of invasive species (Section 3.6), water and soils (Section 3.8), and wildlife and plant species (Sections 

3.4 and 3.5).

***

Citation: 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

Quotation: “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).”

Response: The first phrase of the quote is “In the Pacific Northwest”. It is unclear how or if this 

information applies to the Black Hills. Regardless, the DEIS acknowledges potential negative effects 

associated with roads and includes design criteria (Appendix C) to prevent or minimize these effects. 

Potential effects are disclosed in discussions of invasive species (Section 3.6), water and soils (Section 

3.8), and wildlife and plant species (Sections 3.4 and 3.5).

***

Citation: 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

Quotation: “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.”

Response: The DEIS acknowledges potential negative effects associated with roads and includes design 

criteria (Appendix C) to prevent or minimize these effects. Potential effects are disclosed in discussions 

of invasive species (Section 3.6), water and soils (Section 3.8), and wildlife and plant species (Sections 

3.4 and 3.5).

***

Citation: 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-Bluesfor-Songbirds.aspx

Quotation: “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 
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-52

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.”

Response: Habitat fragmentation was analyzed in the Phase II Amendment FEIS. If a project meets 

Forest Plan direction (as amended by Phase II) for structural stage distribution, fragmentation is not a 

concern. The Steamboat Project would contribute to the Forest-wide structural stage objectives for 

Management Area 5.4. 

The species with the highest level of concern regarding habitat fragmentation in the Black Hills is the 

pine marten. Marten are typically found in dense spruce habitat in the Black Hills. The Steamboat 

project area contains only 138 acres of spruce and no known occurrences of marten.

***

Citation: 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

Quotation: “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.”

Response: The DEIS acknowledges potential negative effects associated with roads and includes design 

criteria (Appendix C) to prevent or minimize these effects. Potential effects are disclosed in discussions 

of invasive species (Section 3.6), water and soils (Section 3.8), and wildlife and plant species (Sections 

3.4 and 3.5).

Habitat fragmentation was analyzed in the Phase II Amendment FEIS. If a project meets Forest Plan 
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-53

direction (as amended by Phase II) for structural stage distribution, fragmentation is not a concern. The 

Steamboat Project would contribute to the Forest-wide structural stage objectives for Management 

Area 5.4. 

***

Citation: 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

Quotation: “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).”

Response: The DEIS acknowledges potential negative effects associated with roads and includes design 

criteria (Appendix C) to prevent or minimize these effects. Potential effects are disclosed in discussions 

of invasive species (Section 3.6), water and soils (Section 3.8), and wildlife and plant species (Sections 

3.4 and 3.5).

***

Citation: 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

Quotation: “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.”
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-54

Response: The Squaw Creek watershed is not located in the Steamboat project area or in the Black Hills; 

data specific to Squaw Creek can not be extrapolated to the Steamboat Project. The DEIS acknowledges 

potential negative effects associated with roads and includes design criteria (Appendix C) to prevent or 

minimize these effects. Potential effects are disclosed in discussions of invasive species (Section 3.6), 

water and soils (Section 3.8), and wildlife and plant species (Sections 3.4 and 3.5).

***

Citation: 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

Quotation: “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)

Response: The DEIS acknowledges potential negative effects associated with roads and includes design 

criteria (Appendix C) to prevent or minimize these effects. Potential effects are disclosed in discussions 

of invasive species (Section 3.6), water and soils (Section 3.8), and wildlife and plant species (Sections 

3.4 and 3.5).

***

Citation: 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

Quotation: “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.”

Response: This information is specific to northwestern California and has not clear connection to the 

Black Hills or the Steamboat project area. The DEIS acknowledges potential negative effects associated 

with roads and includes design criteria (Appendix C) to prevent or minimize these effects. Potential 

effects are disclosed in discussions of invasive species (Section 3.6), water and soils (Section 3.8), and 

wildlife and plant species (Sections 3.4 and 3.5).

***

Citation: 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
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-55

Quotation: “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).”

Response: The DEIS acknowledges potential negative effects associated with roads and includes design 

criteria (Appendix C) to prevent or minimize these effects. Potential effects are disclosed in discussions 

of invasive species (Section 3.6), water and soils (Section 3.8), and wildlife and plant species (Sections 

3.4 and 3.5).

***

Citation: 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/

Quotation: “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.”

Response: The DEIS acknowledges potential negative effects associated with roads and includes design 

criteria (Appendix C) to prevent or minimize these effects. Potential effects are disclosed in discussions 

of invasive species (Section 3.6), water and soils (Section 3.8), and wildlife and plant species (Sections 

3.4 and 3.5).

***

Citation: 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

Quotation: “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)

Response: Grizzly bears are not found in the Black Hills.

***
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-56

Citation: 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

Quotation: “Erosion from forest roads can be a large source of sediment in watersheds managed for 

timber production.”

Response: The DEIS acknowledges potential negative effects associated with roads and includes design 

criteria (Appendix C) to prevent or minimize these effects. Potential effects are disclosed in discussions 

of invasive species (Section 3.6), water and soils (Section 3.8), and wildlife and plant species (Sections 

3.4 and 3.5).

***

Citation: 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

Quotation: “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.”

Response: The DEIS acknowledges potential negative effects associated with roads and includes design 

criteria (Appendix C) to prevent or minimize these effects. Potential effects are disclosed in discussions 

of invasive species (Section 3.6), water and soils (Section 3.8), and wildlife and plant species (Sections 

3.4 and 3.5).

***

Citation: 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

Quotation: “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.”
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-57

“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 belowcost 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 laborintensive, and providing income to the many laid off loggers, timber sale planners, and road engineers –

for noble jobs, rather than jobs of destruction!”

Response: The DEIS acknowledges potential negative effects associated with roads and includes design 

criteria (Appendix C) to prevent or minimize these effects. Potential effects are disclosed in discussions 

of invasive species (Section 3.6), water and soils (Section 3.8), and wildlife and plant species (Sections 

3.4 and 3.5).

***

Citation: 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

Quotation: “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.”

Response: Ovenbirds are not found in the Black Hills.

***

Citation: 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

Quotation: “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 
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-58

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.”

Response: The DEIS acknowledges potential negative effects associated with roads and includes design 

criteria (Appendix C) to prevent or minimize these effects. Potential effects are disclosed in discussions 

of invasive species (Section 3.6), water and soils (Section 3.8), and wildlife and plant species (Sections 

3.4 and 3.5).

***

Citation: 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

Quotation: “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.”

Response: The DEIS acknowledges potential negative effects associated with roads and includes design 

criteria (Appendix C) to prevent or minimize these effects. Potential effects are disclosed in discussions 

of invasive species (Section 3.6), water and soils (Section 3.8), and wildlife and plant species (Sections 

3.4 and 3.5).

***

Citation: 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

Quotation: “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 
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-59

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 roadrelated landsliding is the most visible forestry-related erosional impact in many areas.”

Response: The DEIS acknowledges potential negative effects associated with roads and includes design 

criteria (Appendix C) to prevent or minimize these effects. Potential effects are disclosed in discussions 

of invasive species (Section 3.6), water and soils (Section 3.8), and wildlife and plant species (Sections 

3.4 and 3.5).

***

Citation: 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

Quotation: “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.”

Response: The DEIS acknowledges potential negative effects associated with roads and includes design 

criteria (Appendix C) to prevent or minimize these effects. Potential effects are disclosed in discussions 

of invasive species (Section 3.6), water and soils (Section 3.8), and wildlife and plant species (Sections 

3.4 and 3.5).

***

Citation: 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

Quotation: “Sediment eroded from gravel roads can be a major component of the sediment budget in 

streams in this region (Van Lear, et al, 1995).”

Response: The DEIS acknowledges potential negative effects associated with roads and includes design 

criteria (Appendix C) to prevent or minimize these effects. Potential effects are disclosed in discussions 

of invasive species (Section 3.6), water and soils (Section 3.8), and wildlife and plant species (Sections 

3.4 and 3.5).
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-60

***

Citation: 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

Quotation: “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 elkroads 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).”

Response: The Steamboat project area is entirely comprised of Management Area 5.4 (Big Game Winter 

Range). Effects to elk were analyzed and are presented in Section 3.4 of the DEIS as well as in the 

Wildlife and Fisheries Specialist Report.

***

Citation: 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

Quotation: “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.”

Response: Grizzly bears are not found in the Black Hills. Impacts of roads to other wildlife species are 

documented in Section 3.4 of the DEIS and in the Wildlife and Fisheries Specialist Report.
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-61

***

Citation: 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

Quotation: “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)

Response: The DEIS acknowledges potential negative effects associated with roads and includes design 

criteria (Appendix C) to prevent or minimize these effects. Potential effects are disclosed in discussions 

of invasive species (Section 3.6), water and soils (Section 3.8), and wildlife and plant species (Sections 

3.4 and 3.5).

***

Citation: 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

Quotation: “Roads are often the major source of soil erosion from forested lands (Patric 1976).”

“Generally, soil loss is greatest during and immediately after construction.”

Response: The DEIS acknowledges potential negative effects associated with roads and includes design 

criteria (Appendix C) to prevent or minimize these effects. Potential effects are disclosed in discussions 

of invasive species (Section 3.6), water and soils (Section 3.8), and wildlife and plant species (Sections 

3.4 and 3.5).

***

Citation: 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

Quotation: “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 
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-62

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.”

Response: Impacts to wildlife species, including select bird species, are summarized in Section 3.4 of the 

Steamboat DEIS and discussed in more detail in the Wildlife and Fisheries Specialist Report and 

Biological Evaluation.

***

Citation: 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

Quotation: “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.”

Response: The DEIS acknowledges potential negative effects associated with roads and includes design 

criteria (Appendix C) to prevent or minimize these effects. Potential effects are disclosed in discussions 

of invasive species (Section 3.6), water and soils (Section 3.8), and wildlife and plant species (Sections 

3.4 and 3.5).

***

Citation: 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/2004EffectsofRoadsonWil 
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-63

dlifeandHabitats.pdf

Quotation: “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.”

Response: The DEIS acknowledges potential negative effects associated with roads and includes design 

criteria (Appendix C) to prevent or minimize these effects. Potential effects are disclosed in discussions 

of invasive species (Section 3.6), water and soils (Section 3.8), and wildlife and plant species (Sections 

3.4 and 3.5).

***

Citation: 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

Quotation: “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 
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-64

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.”

Response: The DEIS acknowledges potential negative effects associated with roads and includes design 

criteria (Appendix C) to prevent or minimize these effects. Potential effects are disclosed in discussions 

of invasive species (Section 3.6), water and soils (Section 3.8), and wildlife and plant species (Sections 

3.4 and 3.5).

***

Citation: 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/commentletters/Rogue%20River%20Siskiyou%20TMP%20DEIS.pdf

Quotation: “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)

Response: The DEIS acknowledges potential negative effects associated with roads and includes design 

criteria (Appendix C) to prevent or minimize these effects. Potential effects are disclosed in discussions 

of invasive species (Section 3.6), water and soils (Section 3.8), and wildlife and plant species (Sections 

3.4 and 3.5).

***

Citation: Wuerthner, George 2008 “Ecological Differences between Logging and Wildfire”

http://wuerthner.blogspot.com/2008/12/ecological-differences-between-logging.html

Quotation: “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 
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-65

logging equipment can become vectors for the dispersal of weeds.”

Response: The DEIS acknowledges potential negative effects associated with roads and includes design 

criteria (Appendix C) to prevent or minimize these effects. Potential effects are disclosed in discussions 

of invasive species (Section 3.6), water and soils (Section 3.8), and wildlife and plant species (Sections 

3.4 and 3.5).

***

Citation: Zimmerman, E.A. and P.F. Wilbur “A Forest Divided” New Roxbury Land Trust newsletter, 2004

http://www.ourbetternature.org/forestfrag.htm

Quotation: “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.”

Response: Habitat fragmentation was analyzed in the Phase II Amendment FEIS. If a project meets 

Forest Plan direction (as amended by Phase II) for structural stage distribution, fragmentation is not a 

concern. The Steamboat Project would contribute to the Forest-wide structural stage objectives for 

Management Area 5.4. 

The species with the highest level of concern regarding habitat fragmentation in the Black Hills is the 

pine marten. Marten are typically found in dense spruce habitat in the Black Hills. The Steamboat 

project area contains only 138 acres of spruce and no known occurrences of marten.

The DEIS acknowledges potential negative effects associated with roads and includes design criteria 

(Appendix C) to prevent or minimize these effects. Potential effects are disclosed in discussions of 

invasive species (Section 3.6), water and soils (Section 3.8), and wildlife and plant species (Sections 3.4 

and 3.5).

Response to Scientific Conclusions Paper #8

Citation: Campbell, John L. Ph.D, Dan C. Donato, Joe B. Fontaine J. Boone Kauffman Ph.D., Beverly E. 

Law Ph.D., and Doug Robinson "Biscuit Fire Study." Oregon State University Department of Forest 

Science Terrestrial Ecosystem Research and Regional Analysis. 2003.

http://zircote.forestry.oregonstate.edu/terra/biscuit.htm

Quotation: "Recently burned areas represent an important type of habitat that many species of animals 

have evolved to utilize. Snags (standing dead trees) provide critical nesting and foraging habitat for 

birds and small mammals, and as they decay and fall, create additional habitat for small mammals and 

terrestrial amphibians as coarse woody debris.”

Response: The DEIS recognizes the value of snag habitat present in burned areas (Section 3.4 and the 
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-66

Wildlife and Fisheries Specialist Report). Design criteria would minimize the loss of snags during project 

activities (Appendix C).

***

Citation: Canadian Wildlife Service’s review notes Sent to Robin Sharples, Environmental Assessment 

Coordinator, Government of the Yukon, Forest Management Branch. June 13, 2005 regarding the

post-fire plans for the Barney Lake and False Canyon Creek fires.

http://www.emr.gov.yk.ca/pdf/barney_and_false_environment_canada.pdf

Quotation: "Lindenmayer et al. (2004), note that "To many ecologists, natural disturbances are key 

ecosystem processes rather than ecological disasters that require human repair".”

Response: The DEIS does not dispute the quoted text. It is acknowledged that disturbances such as 

wildfires and beetle outbreaks are natural processes that will never be eliminated. The DEIS does not 

imply that totally eliminating these processes from the ecosystem is the goal of the proposed 

management actions.

***

Citation: Chronicle Staff, “Yellowstone fires have potential to grow much larger” 

BozemanDailyChronicle.com, September 24, 2009

http://bozemandailychronicle.com/articles/2009/09/25/news/70fires.txt

Quotation: “Yellowstone is a ‘fire-adapted ecosystem,’ which means wildfire helps maintain the health 

of the area’s wildlife and vegetation. Most park fires are caused by lightning and, whenever possible, 

monitored and managed, but not necessarily extinguished.”

Response: It is not clear how this quote regarding Yellowstone National Park relates directly to the 

Steamboat Project.

***

Citation: Congressional Research Service Report “Forest Fire/Wildfire Protection” February 14, 2005

http://www.coloradofirecamp.com/congressional_research/forest-fire-wildfire-effects.htm

Quotation: “Animals, as well as plants, can benefit from fire. Some individual animals may be killed, 

especially by catastrophic fires, but populations and communities are rarely threatened. Many species 

are attracted to burned areas following fires — some even during or immediately after the fire. Species 

can be attracted by the newly available minerals or the reduced vegetation allowing them to see and 

catch prey. Others are attracted in the weeks to months (even a few years) following, to the new plant 

growth (including fresh and available seeds and berries), for insects and other prey, or for habitat (e.g., 

snags for woodpeckers and other cavity nesters). A few may be highly dependent on fire; the 

endangered Kirtland’s warbler, for example, only nests under young jack pine that was regenerated by 

fire, because only fire-regenerated jack pine stands are dense enough to protect the nestlings from 

predators.”

Response: It is acknowledged that disturbances such as wildfires and beetle outbreaks are natural 
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-67

processes that will never be eliminated. The DEIS does not imply that totally eliminating these 

processes from the ecosystem is the goal of the proposed management actions. The Steamboat Project 

proposes over 10,000 acres of prescribed fire to maintain fire in the ecosystem.

***

Citation: “Dead Trees and Healthy Forests : Is Fire Always Bad?” The Wilderness Society, March 2003

Quotation: “Forested landscapes may be thought of as living “crazy quilts,” with patches formed 

occasionally through the action of natural and human-caused disturbances like fire, windstorms, and 

logging. Prior to the advent of modern logging technology, virtually every North American forest 

experienced occasional renewal through the action of fire. In some places, fire was a frequent visitor, 

killing very few large trees as it burned harmlessly through the forest litter and grass. In most places, 

though, fire burned only occasionally, creating patches of severely burned forest as it raced through the 

canopy under extreme weather conditions. In these patches, old forests were killed, soon to be 

replaced by young, rejuvenated stands. This cycle of forest maturation, death, and replacement was 

critical to maintaining the diversity and vitality of the ecosystem.”

Response: It is acknowledged that disturbances such as wildfires and beetle outbreaks are natural 

processes that will never be eliminated. The DEIS does not imply that totally eliminating these 

processes from the ecosystem is the goal of the proposed management actions. The Steamboat Project 

proposes over 10,000 acres of prescribed fire to maintain fire in the ecosystem.

***

Citation: Duncan, Sally Ph.D. "Postfire Logging: Is it Beneficial to a Forest?" USDA Forest Service. PNW 

Science Findings issue 47. October 2002.

http://www.fs.fed.us/pnw/sciencef/scifi47.pdf

Quotation: “Trees killed by wildfire and left standing take on roles that change the ecological services 

they previously provided as components of a green-tree system. They still offer some shade, which in a 

burned environment can slow the heating of surface waters and the soil surface. They may also provide 

more rapid recruitment of large wood into streams. Decomposing fallen trees provide nutrients, 

shelter, and early structure for a rejuvenating forest floor.”

“Burned forests typically support significantly different bird communities, with many species dependent 

on stand-replacement fires to maintain their populations across the landscape. Usually there’s an 

increase in cavity-nesting, insectivorous birds such as woodpeckers and certain species of flycatchers.”

Response: The DEIS recognizes the value of snag habitat present in burned areas (Section 3.4 and the 

Wildlife and Fisheries Specialist Report). Design criteria would minimize the loss of snags during project 

activities (Appendix C).

***

Citation: “Fighting fire in the forest” CBC News, June 17, 2009

http://www.cbc.ca/canada/story/2009/06/17/f-forest-fires.html
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-68

Quotation: “Since those early days, millions of dollars have been spent on campaigns to prevent forest 

fires. But researchers now know that fire is not necessarily bad. It can be a natural part of a healthy 

grassland or forest ecosystem.

Fire reduces the buildup of dead and decaying leaves, logs and needles that accumulate on the forest 

floor. It reduces or eliminates the overhead forest canopy, increasing the sunlight that stimulates new 

growth from seeds and roots.

Many plants and animals have adapted to fire.

Both lodgepole pine and jack pine have resin-sealed cones that stay on trees for many years. The heat 

of fire melts the resin and the cones pop open. Thousands of seeds then scatter to the ground and grow 

into new stands of pine.

Woodpeckers feast on bark beetles and other insects that colonize in newly burned trees.

And so, 20 years ago, Parks Canada decided that it wouldn't interfere in natural processes such as fire, 

insects and disease unless it had to — that is, unless people or neighbouring lands were threatened.”

Response: It is acknowledged that disturbances such as wildfires and beetle outbreaks are natural 

processes that will never be eliminated. The DEIS does not imply that totally eliminating these 

processes from the ecosystem is the goal of the proposed management actions. The Steamboat Project 

proposes over 10,000 acres of prescribed fire to maintain fire in the ecosystem.

***

Citation: “Forest Fires” The Environmental Literacy Council, 2008

http://www.enviroliteracy.org/article.php/46.html

Quotation: “Wildfires are a natural occurrence and serve important ecosystem functions. Forest 

landscapes are dynamic and change in response to variations in climate and to disturbances from 

natural sources, such as fires caused by lightning strikes. Many tree species have evolved to take 

advantage of fire, and periodic burns can contribute to overall forest health. Fires typically move 

through burning lower branches and clearing dead wood from the forest floor which kick-starts 

regeneration by providing ideal growing conditions. It also improves floor habitat for many species that 

prefer relatively open spaces.”

Response: It is acknowledged that disturbances such as wildfires and beetle outbreaks are natural 

processes that will never be eliminated. The DEIS does not imply that totally eliminating these 

processes from the ecosystem is the goal of the proposed management actions. The Steamboat Project 

proposes over 10,000 acres of prescribed fire to maintain fire in the ecosystem.

***

Citation: “Forest Fire/Wildfire Protection” CRS Report for Congress, February 14, 2005

http://www.coloradofirecamp.com/congressional_research/forest-fire-wildfire-effects.htm

Quotation: “Animals, as well as plants, can benefit from fire. Some individual animals may be killed, 
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Appendix F – Response to Scientific Conclusion Papers F-69

especially by catastrophic fires, but populations and communities are rarely threatened. Many species 

are attracted to burned areas following fires — some even during or immediately after the fire. Species 

can be attracted by the newly available minerals or the reduced vegetation allowing them to see and 

catch prey. Others are attracted in the weeks to months (even a few years) following, to the new plant 

growth (including fresh and available seeds and berries), for insects and other prey, or for habitat (e.g., 

snags for woodpeckers and other cavity nesters). A few may be highly dependent on fire; the 

endangered Kirtland’s warbler, for example, only nests under young jack pine that was regenerated by 

fire, because only fire-regenerated jack pine stands are dense enough to protect the nestlings from 

predators.

In summary, many of the ecological benefits of wildfire that have become more widely recognized over 

the past 30 years are generally associated with light surface fires in frequent-fire ecosystems. This is 

clearly one of the justifications given for fuel treatments. Damage is likely to be greater from stand 

replacement fires, especially in frequent-fire ecosystems, but even crown fires produce benefits in some 

situations (e.g., for the jack pine regeneration needed for successful Kirtland’s warbler nesting).”

Response: It is acknowledged that disturbances such as wildfires and beetle outbreaks are natural 

processes that will never be eliminated. The DEIS does not imply that totally eliminating these 

processes from the ecosystem is the goal of the proposed management actions. The Steamboat Project 

proposes over 10,000 acres of prescribed fire to maintain fire in the ecosystem.

***

Citation: Franklin, Jerry F. Ph.D. and James K. Agee Ph.D. "Forging a Science-Based National Forest Fire 

Policy." Issues in Science and Technology Fall 2003.

http://inr.oregonstate.edu/download/forging_a_science_based_national_forest_fire_policy.pdf

Quotation: "Natural forest disturbances, including fire, kill trees but remove very little of the total 

organic matter. Combustion rarely consumes more than 10 to 15 percent of the organic matter, even in 

stand-replacement fires, and often much less. Consequently, much of the forest remains in the form of 

live trees, standing dead trees, and logs on the ground. Also, many plants and animals typically survive 

such disturbances. This includes living trees, individually and in patches."

"These surviving elements are biological legacies passed from the pre-disturbance ecosystem to the 

regenerating ecosystem that comes after. Biological legacies are crucial for ecological recovery. They 

may serve as lifeboats for many species, provide seed and other inocula, and enrich the structure of the 

regenerated forest. Large old trees, snags, and logs are critical wildlife habitat and, once removed, take 

a very long time to replace."

Response: It is acknowledged that disturbances such as wildfires and beetle outbreaks are natural 

processes that will never be eliminated. The DEIS does not imply that totally eliminating these 

processes from the ecosystem is the goal of the proposed management actions. The Steamboat Project 

proposes over 10,000 acres of prescribed fire to maintain fire in the ecosystem.

***

Citation: Gorte, Ross W. Ph.D. from a CRS report for Congress, January 18, 2006

http://www.ncseonline.org/nle/crsreports/06Feb/RL30755.pdf
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Appendix F – Response to Scientific Conclusion Papers F-70

Quotation: “Research had documented that, in some situations, wildfires brought ecological benefits to 

the burned areas — aiding regeneration of native flora, improving the habitat of native fauna, and 

reducing infestations of pests and of exotic and invasive species.” (pg 2)

Response: It is acknowledged that disturbances such as wildfires and beetle outbreaks are natural 

processes that will never be eliminated. The DEIS does not imply that totally eliminating these 

processes from the ecosystem is the goal of the proposed management actions. The Steamboat Project 

proposes over 10,000 acres of prescribed fire to maintain fire in the ecosystem.

***

Citation: Gregory, Lisa Dale Ph.D. “Wildland Fire Use: An Essential Fire Management Tool”

A Wilderness Society Policy and Science Brief December 2004

http://wilderness.org/Library/Documents/upload/ScienceBrief-WildlandFireUseEssentialTool.pdf

Quotation: “Ecologists and fire experts unanimously agree that fire has served an essential role in 

certain ecosystems for millennia. The ecological benefits of fire include: the creation of critical wildlife 

habitat in standing dead trees, increased nutrients and productivity in soil systems when burned 

material decomposes, improved conditions for surviving old growth trees when a surface fire moves 

through a system, and the regeneration of some fire dependent trees like lodgepole pine (Pinus 

contorta). Fire also increases availability of other fundamental building blocks of ecosystems such as 

moisture and sunshine by opening up the canopy and returning nutrients to the soil. Natural fire cycles 

maintain the diversity of habitats available to all the species in the ecosystem, from wildlife to 

wildflowers to fungi.”

Response: It is acknowledged that disturbances such as wildfires and beetle outbreaks are natural 

processes that will never be eliminated. The DEIS does not imply that totally eliminating these 

processes from the ecosystem is the goal of the proposed management actions. The Steamboat Project 

proposes over 10,000 acres of prescribed fire to maintain fire in the ecosystem.

***

Citation: Haney, Alan Ph.D. Introduction to the keynote presentation of the 8th annual Wisconsin 

Association of Lifelong Learning conference University of Wisconsin Stevens Point, October 25, 2007

http://www.uwsp.edu/conted/wall/conference.aspx

Quotation: “In 2007, we are witnessing one of the "worst" wildfire years in recent history, as measured 

in acres burned, suppression costs, and loss of property. We tend to view loss of property or timber 

value, and aesthetics. This perspective was greatly promoted by the U.S. Forest Service and the highly 

successful Smokey the Bear campaign that continues, albeit much reduced. When examined from a 

more objective, ecological perspective, the benefits of wildfire greatly exceed the negatives. This 

illustrated presentation examines the ecology of wildfire and presents the case that our anthropocentric 

perspective often clouds a more balanced understanding of nature where even bears are benefactors of 

fire.”

Response: It is acknowledged that disturbances such as wildfires and beetle outbreaks are natural 

processes that will never be eliminated. The DEIS does not imply that totally eliminating these 
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-71

processes from the ecosystem is the goal of the proposed management actions. The Steamboat Project 

proposes over 10,000 acres of prescribed fire to maintain fire in the ecosystem.

***

Citation: Hanson, Chad Ph.D. February 2, 2010 “New Report Debunks Myth of ‘Catastrophic Wildfire’ “

http://johnmuirproject.org/documents/Myth%20of%20Catastrophic%20Wildfire%20Media%20Release.

pdf

Quotation: “We do not need to be afraid of the effects of wildland fire in our forests. Fire is doing 

important and beneficial ecological work,” said the report’s author, Dr. Chad Hanson, a forest and fire 

ecologist and Director of the John Muir Project. “It may seem counterintuitive, but the scientific 

evidence is telling us that some of the very best and richest wildlife habitat in western U.S. forests 

occurs where fire kills most or all of the trees. These areas are relatively rare on the landscape, and the 

many wildlife species that depend upon the habitat created by high-intensity fire are threatened by fire 

suppression and post-fire logging.”

Response: It is acknowledged that disturbances such as wildfires and beetle outbreaks are natural 

processes that will never be eliminated. The DEIS does not imply that totally eliminating these 

processes from the ecosystem is the goal of the proposed management actions. The Steamboat Project 

proposes over 10,000 acres of prescribed fire to maintain fire in the ecosystem. Post-fire logging is not 

proposed in the Steamboat project area.

***

Citation: Hutto, Richard L. Ph.D. “The Ecology of Severely Burned Forests” Counterpunch, July 19 / 20, 

2008

http://www.counterpunch.org/hutto07192008.html

Quotation: “As summer wildfire season begins in earnest throughout much of the West, it's important 

for the public and policymakers to recognize the important role that severely burned forests play in 

maintaining wildlife populations and healthy forests. Severely burned forests are neither "destroyed" 

nor "lifeless."

From my perspective as an ecologist, I have become aware of one of nature's best-kept secrets - there 

are some plant and animal species that one is hard-pressed to see anywhere outside a severely burned 

forest.”

“An appreciation of the biological uniqueness of severely burned forests is important because if we 

value and want to maintain the full variety of organisms with which we share this Earth, we must begin 

to recognize the healthy nature of severely burned forests. We must also begin to recognize that those 

are the very forests targeted for postfire logging activity. Unfortunately, postfire logging removes the 

very element - dense stands of dead trees - upon which many fire-dependent species depend for nest 

sites and food resources.”

Response: It is acknowledged that disturbances such as wildfires and beetle outbreaks are natural 

processes that will never be eliminated. The DEIS does not imply that totally eliminating these 

processes from the ecosystem is the goal of the proposed management actions. The Steamboat Project 
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Appendix F – Response to Scientific Conclusion Papers F-72

proposes over 10,000 acres of prescribed fire to maintain fire in the ecosystem. Post-fire logging is not 

proposed in the Steamboat project area.

***

Citation: Karr, James R. Ph.D., "Nature doesn't Benefit from Logging Fire-Damaged Lands". Op-Ed

Tacoma News Tribune. December 8, 2005.

http://www.thenewstribune.com/opinion/othervoices/story/5379671p-4864728c.ht

Quotation: "Trees in a burned landscape, both dead and alive, continue to provide homes for wildlife 

after a fire and form the building blocks of new forests."

Response: The DEIS recognizes the value of snag habitat present in burned areas (Section 3.4 and the 

Wildlife and Fisheries Specialist Report). Design criteria would minimize the loss of snags during project 

activities (Appendix C).

***

Citation: Mark, Jason “Mission Impossible” Earth Island Journal, winter 2009

http://www.earthisland.org/journal/index.php/eij/article/mission_impossible/

Quotation: “For Pyne and many others who study wildfires, the conventional understanding of 

firefighting has led us to the misguided conclusion that this is a struggle we can win. In much of the 

West, fire is an ordinary part of the landscape, a feature as essential to many ecosystems as rivers and 

grasses. Periodic fires are nothing more than regular disturbances; it is us who have made them into 

disasters.”

Response: It is acknowledged that disturbances such as wildfires and beetle outbreaks are natural 

processes that will never be eliminated. The DEIS does not imply that totally eliminating these 

processes from the ecosystem is the goal of the proposed management actions. The Steamboat Project 

proposes over 10,000 acres of prescribed fire to maintain fire in the ecosystem.

***

Citation: Marks, Raissa Fish and Wildlife Habitat Management Leaflet number 37 Published by the 

Natural Resources Conservation Service, USDA, April 2006

ftp://ftp-fc.sc.egov.usda.gov/NHQ/ecs/Wild/ImportofDisturbInHabMgt.pdf

Quotation: “Fire releases nutrients and uncovers bare soil. The blackened, bare soil warms quickly, 

which stimulates soil microbial activity, nutrient cycling, and plant growth. In forests, fire opens up part 

of the canopy to sunlight, which allows sun-loving plant species to recolonize the site.”

“Following fires, plant communities go through successional changes. Many native wildlife species and 

popular game species, such as bobwhite quail, white-tailed deer, and wild turkey, are dependent on 

periodic fire to create and maintain suitable habitat. Surface fires can stimulate the growth of 

herbaceous foods for deer, elk, moose, and hares, and can enhance berry production for black bears and 

other wildlife. Small mammal populations generally increase in response to new vegetation growth, 
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Appendix F – Response to Scientific Conclusion Papers F-73

providing a food source for carnivores. Fire can also reduce internal and external parasites on wildlife.” 

(pg. 2)

“natural disturbance such as fires, floods, and herbivory are critical in maintaining valuable ecosystem 

functions and creating and restoring wildlife habitat.” (pg. 7)

Response: It is acknowledged that disturbances such as wildfires and beetle outbreaks are natural 

processes that will never be eliminated. The DEIS does not imply that totally eliminating these 

processes from the ecosystem is the goal of the proposed management actions. The Steamboat Project 

proposes over 10,000 acres of prescribed fire to maintain fire in the ecosystem.

***

Citation: Martinez, Lori “Applications of Tree-Ring Dating” Laboratory of Tree-Ring Research at the 

University of Arizona February, 2000

http://www.ltrr.arizona.edu/lorim/apps.html

Quotation: "During recent decades, ecologists have learned that forest fires were a pervasive 

phenomenon in practically all forests of the world, even the rainforests. Humans have severely 

disrupted the natural pattern of fire across the landscape, especially during the last 100 years. 

Therefore, if forests are to be returned to their more 'natural' state, fire will have to be reintroduced."

Response: It is acknowledged that disturbances such as wildfires and beetle outbreaks are natural 

processes that will never be eliminated. The DEIS does not imply that totally eliminating these 

processes from the ecosystem is the goal of the proposed management actions. The Steamboat Project 

proposes over 10,000 acres of prescribed fire to maintain fire in the ecosystem.

***

Citation: Nappi, Antoine Ph.D., Pierre Drapeau Ph.D., Jean-François Giroux Ph.D. and Jean-Pierre Savard 

Ph.D. “Snag use by foraging black-backed woodpeckers (Picoides articus) in a recently burned eastern 

boreal forest.”

The Auk 120(2): 505-511. 2003.

http://www.borealcanada.ca/research_arc_hot_e.cfm

Quotation: "Contrary to what you may think, a forest fire does not reduce everything to a lifeless ash. 

Instead, it leaves behind a landscape of blackened trees interspersed with remnants of green, intact 

forest. Post-fire specialists such as wood-boring insects quickly colonize the dead trees (snags), 

attracting an array of woodpeckers."

"Identifying the ecological value of a post-fire structure and the characteristics that make it attractive to 

wildlife is important.”

Response: It is acknowledged that disturbances such as wildfires and beetle outbreaks are natural 

processes that will never be eliminated. The DEIS does not imply that totally eliminating these 

processes from the ecosystem is the goal of the proposed management actions. The Steamboat Project 

proposes over 10,000 acres of prescribed fire to maintain fire in the ecosystem.
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-74

The DEIS recognizes the value of snag habitat present in burned areas (Section 3.4 and the Wildlife and 

Fisheries Specialist Report). Design criteria would minimize the loss of snags during project activities 

(Appendix C).

***

Citation: Noss, Reed F. Ph.D., Jerry F. Franklin Ph.D., William Baker, Ph.D., Tania Schoennagel, Ph.D., and 

Peter B. Moyle, Ph.D. “Ecological Science Relevant to Management Policies for Fire-prone Forests of the 

Western United States” Society for Conservation Biology, February 24, 2006

http://www.nifc.gov/fuels/downloads/planning/EcologicalScience.pdf

Quotation: “Trees that survive the fire for even a short period of time are critical as seed sources and as 

habitat that will sustain many elements of biodiversity both above and below ground. The dead wood, 

including large snags and logs, is second only to live trees in overall ecological importance.”

Response: The DEIS recognizes the value of snag habitat present in burned areas (Section 3.4 and the 

Wildlife and Fisheries Specialist Report). Design criteria would minimize the loss of snags during project 

activities (Appendix C).

***

Citation: Reice, Seth, Ph.D. from a press conference with Senator Robert Torricelli, April 28, 1998,

http://www.saveamericasforests.org/news/ScientistsStatement.htm

Quotation: “Disturbances, from windthrown trees to fires, are natural in forests and are essential for 

forest ecosystem well being. For example, fire is a disturbance in forests, but it is also beneficial. While 

disturbances kill some individuals, they also open up ecological living space for recolonization by many 

previously excluded species.”

“Without fire, natural succession is upset. In a forest where fire has been unnaturally suppressed for 

many years (50 or more), fire intolerant trees grow unchecked, suppressing and outcompeting the 

normally dominant fire resistant trees. Overall biodiversity is reduced. As the tree diversity declines, 

the habitat becomes unsuitable for a large portion of the forest species. Animal species are lost, since 

the animals use the fire tolerant variety of tree species for food, shelter and nest sites.”

Response: It is acknowledged that disturbances such as wildfires and beetle outbreaks are natural 

processes that will never be eliminated. The DEIS does not imply that totally eliminating these 

processes from the ecosystem is the goal of the proposed management actions. The Steamboat Project 

proposes over 10,000 acres of prescribed fire to maintain fire in the ecosystem.

***

Citation: “Rising from the ashes: Forest fires give way to new growth” Science Buzz, May 2007 

(supported by the National Science Foundation)

http://www.sciencebuzz.org/blog/rising_from_the_ashes_forest_fires_give_way_to_new_growth

Quotation: “As a rule of thumb, timber experts say that any particular chunk of ground in the forest 

should be touched by intense fire every 50 to 100 years.
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Appendix F – Response to Scientific Conclusion Papers F-75

But the power of the fire is just the first step in forest regrowth. Weather patterns in the affected area 

over the nest year will play a big role in how the new forests develop. A summer of drought could kill 

the newly released seeds and short-circuit any new growth. That could give new species of trees a 

chance to grow in the area. Normal rains mixed with the nutrients left on the ground from the fire could 

be a great booster shot to getting the seeds off to a flying start.

Other natural benefits can be seen from fires. For instance, the once-rare black-backed woodpecker is 

now a regular site in the BWCA with the abundance of dead trees from recent smaller fires and the 1999 

wind blow down of trees. New shrubs and ground vegetation is appealing to different kinds of wildlife 

to snack on.”

Response: It is acknowledged that disturbances such as wildfires and beetle outbreaks are natural 

processes that will never be eliminated. The DEIS does not imply that totally eliminating these 

processes from the ecosystem is the goal of the proposed management actions. The Steamboat Project 

proposes over 10,000 acres of prescribed fire to maintain fire in the ecosystem.

***

Citation: “Rotting Wood and how it affects the Environment” MamasHealth.com

http://www.mamashealth.com/saveearth

Quotation: “Rotting logs are a very common feature of wild ecosystems. Rotting logs recycles nutrients 

back into the soil and provides a healthy habitat for a wide range of insects, plants, and animals. Rotting 

log provides homes for small mammals, insects, worms, and spiders. The rich, organic soil provides a 

unique habitat for fungi, tree seedlings, wildflowers, mosses, and ferns.”

Response: It is unclear how this relates directly to the Steamboat Project. The Steamboat Project 

would meet Forest Plan objectives for coarse woody debris (DEIS, page 18).

***

Citation: Schneider, Gary “Dead trees (they're still full of life!)” 2008 Macphail Woods Ecological 

Forestry Project

http://www.macphailwoods.org/wildlife/deadtrees.html

Quotation: “More and more woodlot owners are taking a broader view of their forests. They look for 

values other than the immediate return on wood harvested. These values include other forest 

products such as ground hemlock and mushrooms; carbon storage; water purification; leaving a legacy 

for their children; and healthy wildlife populations.

Wildlife trees (dead or dying trees used for nesting, feeding, denning and roosting) go through several 

stages that can start with ants tunneling into the rotting centre to flycatchers perching on the bare 

branches. For cavity-nesting birds they are critical habitat. Some species excavate cavities for their 

nests, while others take over and enlarge existing holes. Many of these birds in turn help the forest, 

eating insects which can damage trees.”
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Appendix F – Response to Scientific Conclusion Papers F-76

Response: The DEIS recognizes the value of snag habitat present in burned areas (Section 3.4 and the 

Wildlife and Fisheries Specialist Report). Design criteria would minimize the loss of snags during project 

activities (Appendix C).

***

Citation: Smith, Jane Kapler, ed. "Wildland Fire in Ecosystems: Effects of Fire on Fauna" USDA Forest 

Service Rocky Mountain Research Station. General Technical Report RMRS-GTR-42-volume 1. January 

2000.

http://nps.gov/fire/download/fir_eco_wildlandfireJan2000.pdf

Quotation: "Species that breed exclusively in the first 30 years after fire may be difficult to maintain in 

the ecosystem without fire. Fire exclusion and post-fire salvage of dead trees after fire may reduce 

populations of these species over large geographic areas."

Response: It is acknowledged that disturbances such as wildfires and beetle outbreaks are natural 

processes that will never be eliminated. The DEIS does not imply that totally eliminating these 

processes from the ecosystem is the goal of the proposed management actions. The Steamboat Project 

proposes over 10,000 acres of prescribed fire to maintain fire in the ecosystem. Post-fire logging is not 

proposed in the Steamboat project area.

***

Citation: Tanner, G.W. Ph.D., W.R. Marion Ph.D., and J.J. Mullahey Ph.D. “Understanding Fire: Nature's 

Land Management Tool” A Florida Cooperative Extension Service publication, July, 1991

http://edis.ifas.ufl.edu/UW124

Quotation: “Ecological benefits of fire:

• Promotes flowering of herbaceous species and fruit production of woody species.

• Improves nutritional quality of plants for both wild and domestic animals.

• Enhances nutrient cycling of some elements and elevates soil pH.

• Maintains required habitat conditions for fire-adapted plant and animal species.

• Results in a more heterogenous and diverse habitat--if natural fires are patchy--leaving pockets 

of unburned areas.

Prohibits wildfire conditions from developing (i.e., vast accumulation of highly-flammable, dead 

vegetation.)”

Response: It is acknowledged that disturbances such as wildfires and beetle outbreaks are natural 

processes that will never be eliminated. The DEIS does not imply that totally eliminating these 

processes from the ecosystem is the goal of the proposed management actions. The Steamboat Project 

proposes over 10,000 acres of prescribed fire to maintain fire in the ecosystem. 
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-77

***

Citation: Thomas, Jack Ward Ph.D., US Forest Service Chief "Dead Wood: From Forester’s Bane to 

Environmental Boon". Keynote address at the symposium on ecology and management of deadwood in 

western forests, Reno, Nevada. 1999.

http://www.fs.fed.us/psw/publications/documents/gtr-181/003_Thomas.pdf

Quotation: "In retrospect, it is amazing that forest managers did not realize that dead wood was a 

critical habitat component for vertebrate and invertebrate wildlife and for the forest itself."

Response: The DEIS recognizes the value of snag habitat present in burned areas (Section 3.4 and the 

Wildlife and Fisheries Specialist Report). Design criteria would minimize the loss of snags during project 

activities (Appendix C). The Steamboat Project would meet Forest Plan objectives for maintaining 

coarse woody debris (DEIS, page 18).

***

Citation: Vernetti, Toni “Are You Wildfire Aware?” June 07, 2005

http://www.googobits.com/articles/p0-547-are-you-wildfire-aware.html

Quotation: “Wildfires have been a natural part of our environment since time began. Under the right 

circumstances these wildfires can be beneficial to an ecosystem.”

“Wildfires consume vegetation that would otherwise become overgrown, creating ideal conditions for a 

catastrophic wildfire. Wildfires allow more open spaces for new and different kinds of vegetation to 

grow and receive sunlight. This, in turn, provides fresh nutrients and shelter for forest plants and 

animals. Wildfires also keep our forests healthy by consuming harmful insects and diseases.”

Response: It is acknowledged that disturbances such as wildfires and beetle outbreaks are natural 

processes that will never be eliminated. The DEIS does not imply that totally eliminating these 

processes from the ecosystem is the goal of the proposed management actions. The Steamboat Project 

proposes over 10,000 acres of prescribed fire to maintain fire in the ecosystem. 

***

Citation: Voss, René, Ph.D. “Getting Burned by Logging,” July 2002 The Baltimore Chronicle

http://www.baltimorechronicle.com/firelies_jul02.shtml

Quotation: "Fire is an essential, natural and necessary part of Western forest ecology. Many species of 

trees can only reproduce after fires occur. Wildland fires burn underbrush and return important 

nutrients to the soil."

Response: It is acknowledged that disturbances such as wildfires and beetle outbreaks are natural 

processes that will never be eliminated. The DEIS does not imply that totally eliminating these 

processes from the ecosystem is the goal of the proposed management actions. The Steamboat Project 

proposes over 10,000 acres of prescribed fire to maintain fire in the ecosystem.

***
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-78

Citation: “Why Does the City Leave Dead Trees” June, 2007

http://troymi.gov/ParksRec/Trees/DeadTrees.asp

Quotation: “Scientists believe a scattering of dead trees goes far beyond looks. Dead trees support 

birds that actually decrease populations of harmful insects. Studies by Cooperative Extension Service 

have demonstrated that a large population of forest birds appreciably reduces problems for tree owners 

caused by insects and small mammals. An example is the woodpecker. It can hold down bark beetles 

and can control as much as 65% of emerging pine beetles. All ash trees dying from emerald ash borer 

show aggressive signs of feeding woodpeckers.

Dead branches serve as necessary perches for hawks, owls and similar birds of prey. Birds that play and 

important role in the control of mice, gophers and rabbits that wreak havoc with our landscapes, lawns 

and gardens.

To that end, as the City goes through its parks and natural areas, removing dead trees, we will leave 

some standing. Additionally, in unobtrusive areas, we intended to leave piles of branches and the 

occasional log. All this in the hope that the diversity of wildlife in Troy's urban forest will flourish and, in 

so doing improve the quality of our lives as well.”

Response: The DEIS recognizes the value of snag habitat present in burned areas (Section 3.4 and the 

Wildlife and Fisheries Specialist Report). Design criteria would minimize the loss of snags during project 

activities (Appendix C).

***

Citation: “Wildfire in British Columbia” BC Forest Facts, September 2003

http://www.llbc.leg.bc.ca/public/PubDocs/bcdocs/364421/wildfire_bc.pdf

Quotation: “Wildfire is a natural part of most ecosystems across British Columbia. It helps to renew the 

forest, maintain the diversity of plant and animal life, and keep insects and disease in check. It opens up 

dense forest to allow the growth of shrubs and grasses, creating browse for deer, moose, elk and other 

animals. It releases nutrients locked in slowly decaying logs.”

Response: It is acknowledged that disturbances such as wildfires and beetle outbreaks are natural 

processes that will never be eliminated. The DEIS does not imply that totally eliminating these 

processes from the ecosystem is the goal of the proposed management actions. The Steamboat Project 

proposes over 10,000 acres of prescribed fire to maintain fire in the ecosystem.

***

Citation: Woodford, Riley “Regeneration Following Fire Creates Fertile Habitat for Wildlife” Alaska Fish 

and Wildlife News, August 2003

http://www.wildlife.alaska.gov/index.cfm?adfg=wildlife_news.view_article&issue_id=5&articles_id=60

Quotation: “ "People are bombarded with the negative aspects of fire," Paragi said. "You hear terms 

like 'destroyed thousands of acres of forest,' and the thought of destruction gets embedded in the public 

mind. But fire is a natural part of the ecosystem and it is actually very important." “
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-79

“Fire opens up the forest canopy and allows sunlight to reach the ground, stimulating the organisms that 

decompose organic matter and make nutrients available to plants. Fire burns off the insulating layer of 

moss and duff, allowing sunlight to further warm the soil. The ash can release nutrients back into the 

soil and change soil chemistry, promoting plants growth.”

Response: It is acknowledged that disturbances such as wildfires and beetle outbreaks are natural 

processes that will never be eliminated. The DEIS does not imply that totally eliminating these 

processes from the ecosystem is the goal of the proposed management actions. The Steamboat Project 

proposes over 10,000 acres of prescribed fire to maintain fire in the ecosystem.

***

Citation: Wuerthner, George. “Logging, thinning would not curtail wildfires” The Register - Guard 

(Eugene Ore.), December 26, 2008

http://wuerthner.blogspot.com/2008/12/logging-thinning-would-not-curtail.html

Quotation: “Healthy ecosystems burn, and often burn by the tens of millions of acres. The spate of 

large wildfires we are experiencing now are not “abnormal” or an indication of “unhealthy” forest. 

Rather, we are seeing the natural response of a healthy forest ecosystem.

Given that wildfire was so common for thousands of years, it is not surprising that recent research 

shows that wildfires, particularly severe wildfires, increase biodiversity.

If anything, we probably need more wildfire, not less. With global warming we will probably get it, as 

vegetative communities adapt to new climatic realities.”

Response: It is acknowledged that disturbances such as wildfires and beetle outbreaks are natural 

processes that will never be eliminated. The DEIS does not imply that totally eliminating these 

processes from the ecosystem is the goal of the proposed management actions. The Steamboat Project 

proposes over 10,000 acres of prescribed fire to maintain fire in the ecosystem.

Response to Scientific Conclusions Paper #9

The individual quotes in this scientific conclusions paper will not be replied to individually because all of 

them relate to the use of herbicides containing glycophosate, and specifically to Roundup, which is 

produced by Monsanto. Roundup is not used on the Northern Hills Ranger District, nor is any other 

herbicide containing glycophosate. Several different herbicides are used depending on location (upland, 

near streams, etc.) and the species of noxious weed being targeted. 

Regardless, the specific brand/type of herbicide used is outside the scope of the Steamboat Project. 

Herbicide use on the Forest is directed by the Black Hills National Forest Noxious Weed Management 

Plan and was analyzed in during the 1997 revision of the Forest Plan and the subsequent 2005 Phase II 

Amendment. The analysis within the Steamboat DEIS merely acknowledges that occurrences of noxious 

weeds will likely result from project activities and that those occurrences will be treated; it does not 

specify how they will be treated.
Steamboat Project Final Environmental Impact Statement

Appendix F – Response to Scientific Conclusion Papers F-80

Response to Scientific Conclusions Paper #10

The individual quotes in this scientific conclusions paper will not be replied to individually because all of

them are related to the spread of noxious weeds through livestock grazing. The potential for noxious 

weed spread is discussed in the Steamboat DEIS in Section 3.6. This discussion focuses on the spread of 

noxious weeds as a result of the activities specific to the Steamboat Project (i.e., road 

management/construction and timber harvest). 

Livestock grazing, and its associated impacts on the allotments in the Steamboat project area, is an 

activity that was analyzed under the 1997 Livestock Grazing Environmental Assessment. The level of 

grazing will not be affected by the Steamboat Project. The analysis in the Livestock Grazing EA is still 

applicable and this activity is therefore outside the scope of the Steamboat Project.

Response to Scientific Conclusions Paper #11

This paper, which focuses on research conducted by Dr. Jack Cohen, is addressed in Appendix E 

(response to Comment 3.8).

Response to Scientific Conclusions Paper #13

This paper, which includes results from various public polls, is addressed in Appendix E (response to 

Comment 3.4).

Response to Scientific Conclusions Paper #15

This paper contains a series of quotes, many from USDA or Forest Service officials, expressing the need 

for the consideration of best available science when developing projects on public lands. The 

Steamboat Project does not refute this claim and was analyzed using the best available science. All 

references used during the analysis of the project are listed in the EIS (Chapter 5) and all analysis was 

conducted by professionals with education and experience in their field. No evidence is offered that the 

science used by the USFS in developing the Steamboat Project is not the best available science. All 

contrary science offered in the comments on the Steamboat DEIS is addressed in Appendix E or 

Appendix F of the FEIS.

Response to Scientific Conclusions Paper #18

As with Paper #9, this paper deals exclusively with the dangers of herbicides, primarily focusing on 

Roundup and other herbicides containing glyphosate. See “Response to Scientific Conclusions Paper #9” 

above.