Review of R. Artley assertion that “Statements by [s]cientists 

[show] that [l]ogging [c]ommercial-sized [t]rees increases 

[w]ildfire [i]ntensity.” 

By: Joel T. King, District Ranger, and John T. Wells, Environmental Coordinator - 

24 December 2008 

On November 19, 2008, Mr. Richard (Dick) Artley submitted the following statement and 

accompanying references via electronic mail regarding the Butcherknife/Slate Fuels Reduction 

proposal: 

“Statements by Scientists showing that Logging Commercial-sized Trees increases 

Wildfire Intensity.” 

Presumably, Mr. Artley sent this statement to express disagreement with the Butcherknife/Slate 

proposal and to include in the record his perspective that use of logging is counterproductive to 

achieving the hazardous fuel reduction objectives established for the project. In support of his 

stated stance, 34 references (with URL addresses) were submitted for Forest Service review. 

We (and other Forest Service representatives who are conducting the planning and analysis for this 

project) printed and read Mr. Artley’s supplied references, looked at the quoted text from each of 

the papers and read the complete content of the papers. Following this review, our thoughts about 

the quotes and each of the papers were summarized and those summaries form the Forest Service’s 

reaction and comment to Mr. Artley’s stated contention. 

Text, as quoted by Mr. Artley, from the 34 references is presented in the order submitted in the email that we received. Following the quoted text and the reference source for the quote, our 

reaction and comment is provided. Each of the references are available for review in hardcopy 

form and are included as part of the record file for this project. 

--------------------------------------- 

1. "Timber harvest, through its effects on forest structure, local microclimate, and 

fuels accumulation, has increased fire severity more than any other recent human 

activity." (pg.62) 

University of California; SNEP Science Team and Special Consultants 

1996 “Sierra Nevada Ecosystem Project: Final Report to Congress” 

Volume 1, Chapter 4 – Fire and Fuels. 

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

While not included as part of Mr. Artley’s citation, we included (as a way to provide context for 

the narrative included in Volume I, Chapter 4) the “Summary [22 pages]” of the entire fourvolume work that makes up the Sierra Nevada Ecosystem Project (SNEP) report. As stated in that 

Page 1 
Summary, congressional language in the Conference Report for Interior and Related Agencies 

1993 Appropriations Act (H.R. 5503), which requested the study, emphasized that “...the report 

was to advise Congress, not to prepare a single plan, a range of options for implementation, or 

preferred alternatives as in an environmental impact statement process required under the National 

Environmental Policy Act [Summary, p.1].” While the report a is a science-based assessment that 

both highlights current knowledge and also presents collective judgments about sustainability into 

the future, the Science Team devoted most of its effort to simply reviewing existing information 

about the Sierra Nevada that was available at the time. 

Inside the Summary, the conclusion cited by Mr. Artley from Volume I, Chapter 4 is repeated on 

page 4. However, further explanation is provided on Summary page 4 to clarify what was meant 

in the lead sentence quoted above: “If not accompanied by adequate reduction of fuels, logging 

(including salvage of dead and dying trees) increases fire hazard by increasing surface dead fuels 

and changing the local microclimate. Fire intensity and expected fire rates thus increase locally 

and in areas adjacent to harvest. However, logging can serve as a tool to help reduce fire hazard 

when slash is adequately treated and treatments are maintained.” Butcherknife/Slate does not 

involve the salvage of dead and dying trees. In addition, it is certainly the stated intent of the 

Butcherknife/Slate proposal to treat activity slash within logged areas and to begin the process of 

reintroducing understory fire into treated stands as a way to maintain lowered fuel quantities. 

--------------------------------------- 

2. “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. 22) 

 

Ingalsbee, Timothy Ph.D. “The wildland fires of 2002 illuminate 

fundamental questions about our relationship to fire.” 

The Oregon Quarterly, Winter 2002 

http://209.85.173.104/search?q=cache:n8ChOBpFT7wJ:www.fireecology.org/research/wildfire_paradox.pdf+%22commercial+logging%22+ineffective+wildfire&hl=en&ct=cln

k&cd=6&gl=us

Clearly, this article is an opinion piece published by the periodical The Oregon Quarterly, which is 

a state and regional magazine published by the University of Oregon (UO). Although Dr. 

Ingalsbee is an instructor in sociology at the UO, and the article presents several intriguing 

“paradoxes,” this commentary certainly cannot be regarded as peer-reviewed science or even a 

science assessment (nor does it purport to be such). As stated on page 21, Dr. Ingalsbee believes 

“flames have followed the ax” because “commercial logging removes the largest, oldest, most fire 

resistant trees while leaving behind the smallest, youngest, most fire susceptible trees.” While a 

relationship between destructive fires and historical logging practices has been demonstrated under 

certain circumstances and at particular times, Dr. Ingalsbee’s primary contention is that logging 

produces especially flammable conditions because “often the slash is never cleaned up at all [page 

21].” We would note that in Butcherknife/Slate our intention is to promptly dispose of loggingcreated debris (activity slash). Moreover, the Butcherknife/Slate proposal specifies retention of the 

largest, oldest, most fire resistant trees on site while removing the smallest, most fire susceptible 

trees. 

Page 2 
--------------------------------------- 

3. “These results suggest that to reduce ignitions, the distances from a structure 

for managing vegetation are much smaller than the lofting distances for firebrands. 

Thus, beyond some relatively short distance from the structure (depending on the 

vegetation and topography), vegetation management has no significant benefit for 

reducing flame generated ignitions. Vegetation management, on the other hand, 

cannot be extensive enough, in a practical sense, to significantly reduce firebrand 

ignitions. Therefore, the structure and its immediate surroundings should be the 

focus for activities intended for improving ignition risk.” 

 

“In high-density residential areas containing highly flammable structures (e.g., 

residences with flammable roofs), vegetation management may not be sufficient to 

prevent widespread fire destruction.” (pg. 92) 

 

Cohen, Jack D. Ph.D. 2003. “Structure Ignition Assessment Model (SIAM)” 

USDA Forest Service Gen. Tech. Rep. PSW-GTR-158. 1995. 

http://www.fs.fed.us/psw/publications/documents/psw_gtr158/psw_gtr158_05_cohen.pdf

These quotations excerpted from Dr. Cohen’s report reflect our current understanding of structure 

ignition and are well known findings among Forest Service fuel managers. Vegetation treatment 

adjacent to homes is part of the emphasis of the Josephine County Integrated Fire Plan (JCIFP). 

The above report, of course, does not address the need to treat a forest landscape for purposes 

complementary to and in addition to managing fire risk. As stated in the Butcherknife/Slate 

Environmental Assessment (EA), objectives beyond just fuels reduction are included in the 

proposal. Moreover, we do not claim to reduce firebrands that could ignite nearby structures. 

--------------------------------------- 

4. “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 

Page 3 
behavior can linger for up to 30 years in the dry forest ecosystems of eastern 

Washington and Oregon.” 

 

Huff, Mark H. Ph.D.; Ottmar, Roger D.; Alvarado, Ernesto Ph.D. 

Vihnanek, Robert E.; Lehmkuhl, John F.; Hessburg, Paul F. Ph.D. 

Everett, Richard L. Ph.D. 1995. “Historical and current forest 

landscapes in eastern Oregon and Washington. Part II: Linking 

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/dspace/bitstream/1957/4706/1/PB96155213.pdf

As noted in this Technical Report, environmental consequences of the type described only apply 

when post-harvest activity fuels remain on site and are not treated. The Butcherknife/Slate 

proposal would treat natural and activity-created fuels to reduce fuel quantities following logging. 

In addition, no regeneration harvest is contemplated as part of the Butcherknife/Slate Proposed 

Action and this is the primary type of timber harvesting that the article reports as having a 

profound effect on potential fire behavior. 

As stated in the above report, too: “Prescribed fire, along with mechanical measures if hazardous 

burning conditions exist, can be used for restoration purposed to regulate stand composition, 

reduce plant competition, and modify fuels to achieve a desired structure. Over time, prescribed 

fires, natural fires, selective tree harvesting, or combinations thereof can be used to maintain 

desired conditions and processes [page 36].” This combination of activities describes the Proposed 

Action for Butcherknife/Slate. 

--------------------------------------- 

5. “Fresh, dry slash of any species makes a high-intensity, unapproachable fire. A 

fire started in dry, fresh slash can become uncontrollable in seconds.” (pg.12) 

 

"It appears significant that many large fires in the western United States have 

burned almost exclusively in slash. Some of these fires have stopped when they 

reached uncut timber; none has come to attention that started in green timber and 

stopped when it reached a slash area." (pg. 14) 

 

G.R. Fahnestock, 1968. "Fire hazard from pre-commercially thinning 

ponderosa pine." Research Paper 57, USDA, Forest Service. 

http://www.fs.fed.us/pnw/pubs/journals/uncaptured/pnw_1968_fahnestock001.pdf

The discussion, calculations and principles presented in this report, which are intended to assist the 

forester in “gauging the fire hazard of slash [p. 1]” following precommercial thinning, are wellunderstood by our fuels managers. As a consequence of the kind of information presented in this 

study (and others), the Butcherknife/Slate proposal includes treatment of activity-generated fuels 

as a connected action. 

Page 4 
--------------------------------------- 

6. “The Peshtigo tragedy served as a deadly warning about what can happen when 

forest health is badly compromised -- in this case, by logging activities. In fact, 

Peshtigo represented the beginning of new fire cycle throughout the Great Lakes 

region that would not be broken for more than 50 years.” 

 

“The removal of large, merchantable trees from forests does not reduce fire risk 

and may, in fact, increase such risk.” 

 

“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. 

Without adequate treatment of small woody material, logging may exacerbate fire 

risk rather than lower it.” 

 

Lyle Laverty, 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

The situation described in Mr. Laverty’s report is addressed by included mitigation measures that 

are to be implemented, should the Butcherknife/Slate proposal be approved. The Peshtigo Fire did 

grow and spread to such tragic proportions in large part because of the availability and wide 

distribution of untreated harvest slash. Activity slash in the Butcherknife/Slate area would be 

treated after logging. 

Moreover, and as recommended in this presidential report, increased efforts are currently needed to 

address ‘the brush, small trees, and downed material that have accumulated in many forests 

because of past management activities, especially a century of suppressing wildland fires, [and 

this] will require significant investments to treat landscapes through thinning and prescribed fire. 

[page 2].” The treatments described in Mr. Laverty’s report are precisely the types that are 

proposed as part of the Butcherknife/Slate project. 

Page 5 
--------------------------------------- 

7. "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." 

 

Quigley, Thomas M.; Haynes, Richard W.; Graham, Russell 

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

Within this GTR, a wide variety of ecosystems are referenced. In this broad context, especially, 

the above statement regarding human-induced fire regime changes (where these changes have 

occurred) captures the primary historical activities related to those now-apparent changes. 

--------------------------------------- 

8. “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.” 

 

Testimony by Lawrence, Nathaniel, NRDC senior attorney 

“Gridlock on the National Forests” before the U.S. House 

of Representatives Subcommittee on Forests and Forest 

Health (Committee on Resources) December 4, 2001. 

http://www.nrdc.org/land/forests/tnl1201.asp

In his testimony, Mr. Lawrence goes on to suggest that forest management be expedited because 

“there is an abundance of small diameter thinning that can be tried in the developed forest matrix 

that has been most modified by past management and thus is most likely to suffer from altered fire 

regimes. If this work is targeted to the specific slopes where dry forests once predominated, 

designed with size limits, conducted with low impact equipment, and subject to long term 

monitoring, we may reduce subsequent fire intensities and will gain the data essential to informed 

decisionmaking in the future [pages un-numbered but about page 3].” 

Page 6 
Within the Butcherknife/Slate area, the forest matrix is developed, the area has been most modified 

by past management and forest stands proposed for treatment are located inside a dry forest type. 

Thus, this area is demonstrably outside of the historical natural fire regime. Project work is 

targeted to the specific slopes where dry forests once predominated, is designed to minimize soil 

compaction and would be subject to long term monitoring. 

---------------------------------------

9. “Some land managers and forest scientists advocate the widespread use of 

silvicultural treatments (of which thinning is the most widely proposed harvestbased fuels reduction method) in western roadless areas to reduce fuel loads and 

tree stocking levels, and thereby decrease the probability of large, intense fires. 

Although thinning within the context of intensive forestry is not new, its efficacy as 

a tool for fire hazard reduction at the landscape scale is controversial, largely 

unsubstantiated, and fundamentally experimental in nature thereby requiring 

caution particularly when applied across large landscapes (FEMAT 1993, Henjum et 

al. 1994, DellaSala et al. 1995, SNEP 1996, USDA Forest Service 2000).” 

 

“There have been only a few empirical studies that have tested the relationship 

between thinning or fuels treatment and fire behavior on even a limited basis. In 

spite of hypothesized benefits, these studies, as well as anecdotal information and 

analysis of recent fires, suggest that thinning treatments have highly variable 

results. In some instances, thinning treatments intended to reduce fire hazard 

appear to have the opposite effect (Huff et al. 1995, van Wagtendonk 1996, 

Weatherspoon 1996). Such treatments may reduce fuel loads, but they also allow 

more solar radiation and wind to reach the forest floor. The net effect is usually 

reduced fuel moisture and increased flammability (Countryman 1955, Agee 1997).” 

 

DellaSala, Dominick A. Ph.D. and Evan Frost. 2001 

“A Comprehensive Strategy for Roadless Area Conservation 

and Fuels Reduction in Priority Areas” 

http://www.kettlerange.org/salvagelogging/DellaSala&Frost_Comprehensive_Strategy.html

While it is true thinning can increase in-stand surface temperatures and wind speeds while 

reducing relative humidity, these environmental effects are highly variable and depend on specific 

prescriptions and topographic positions. The effect varies temporally as well. 

In this article, the authors direct attention to roadless area conservation. The authors recognize that 

conditions on the managed landscape are different from roadless areas: “fire hazard is significantly 

higher in managed portions of the national forests. The elevated likelihood of high-intensity fire in 

managed areas was associated with numerous factors, including increased fuel loads and creation 

of more fire-susceptible stands by (previous) timber harvest, higher probability of human-caused 

ignitions, and dominance of forests characterized by a frequent fire/low intensity fire regime in 

managed landscapes.” Again, information provided supports project objectives because of the 

situational factors described here. 

Page 7 
---------------------------------------

10. “Indiscriminate logging is not a viable solution to reducing wildfire risk. 

Logging can actually increase fire danger by leaving flammable debris on the forest 

floor. Loss of tree canopy lets the sun in, encouraging the growth of brush, 

increases wind speed and air temperature, and decreases the humidity in the 

forest, making fire conditions even worse.” 

Thomas, Craig. “Living with risk: Homeowners face the 

responsibility and challenge of developing defenses against 

wildfires.” Sacramento Bee newspaper, July 1, 2007. 

http://www.sierraforestlegacy.org/NR_InTheNews/SFLIP_2007-07-01_SacramentoBee.php

This statement is simply the reporter paraphrasing known science background information in his 

newspaper article. 

--------------------------------------- 

11. “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.’” 

 

“Now, critics charge that the Bush administration is ignoring that warning. Neil 

Lawrence, a policy analyst with the Natural Resource Defense Council, claims that 

Washington has taken a far more aggressive approach to incorporating 

commercial logging in its wildfire prevention plans. As a result, Lawrence and 

other critics say, the National Fire Plan is becoming a feeding ground for logging 

companies. Moreover, critics claim the administration's strategy, far from 

protecting the lives and homes of those most at risk, could actually increase the 

likelihood of wildfires.” 

 

Okoand Ilan Kayatsky, Dan. “Fight Fire with Logging?” 

Mother Jones, August 1, 2002 

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

This statement is simply the reporter paraphrasing background information or quoting named 

sources in his article written for a popular periodical. 

---------------------------------------

12. “We need to accept that in many areas throughout the region, past forest 

management may have set the stage for fires larger and more intense than have 

occurred in at least the last few hundred years.”

 

Beschta, R.L. Ph.D. et.al, 1995 “Wildfire and Salvage Logging“ 

http://www.saveamericasforests.org/congress/Fire/Beschta-report.htm

Page 8 
While this statement may apply in many current forest situations, Dr. Beschta and his colleagues 

indicate that clearcutting, plantations and failure to adequately reduce activity fuels as the primary 

underlying factors for their conclusion. By and large, this synthesis article aims to offer a 

“scientific framework of principles and practices [in preface]” aimed at salvage logging following 

stand replacement fire. The Butcherknife/Slate proposal does not include post-burn salvage 

logging or clearcutting. 

--------------------------------------- 

13. “Within the fire management community, widespread agreement exists for the 

use of landscape-scale prescribed burning to accomplish this task (reduce fuels 

hazards). However, within the U.S. Forest Service, there has been more of an 

interest in mechanical fuels reduction treatments using commercial thinning for 

fuelbreak construction to lower the risk of crownfires. Proponents argue that using 

commercial thinning to reduce canopy densities would increase firefighter safety 

and prescribed fire efficiency during wildfire suppression, and are necessary 

treatments to prepare for future prescribed burning. However, we suggest that 

theses kind of mechanical treatments create their own fire risks and fuel hazards 

that can potentially cause problems for wildland firefighter safety and prescribed 

fire efficacy.” 

 

“We question the assumption that canopy fuel reduction through commercial 

thinning is necessary or sufficient for reducing wildfire hazards and/or introducing 

prescribed fire. We cite evidence that logging-induced changes in fuel 

composition, vegetation, and microclimate can result in increased rate of fire 

spread, higher fireline intensity, and more severe fire effects. This, in turn, can 

affect firefighter safety and efficiency, and inflate suppression costs. Instead, 

treatment of surface and ladder fuels through prescribed fire combined with 

manual pre-treatments (for example, non-commercial thinning, pruning, and handpiling) can effectively reduce the risk of crownfires, increase firefighter safety, and 

improve ecosystem health. These methods also promise employment 

opportunities for wildland firefighters and other forest workers.” (p. 1) 

 

Fox, Joseph W., Ph.D. and Timothy Ingalsbee, Ph.D. 

“Fuel Reduction for Firefighter Safety.” Published in the 

Proceedings of the International Wildland Fire Safety Summit 

Winthrop, WA, Oct. 26-29, 1998. 

http://www.fire-ecology.org/research/fuel_reduction.htm

On page 5, Dr, Fox and Dr. Ingalsbee state: “To be effective, the program should focus on 

reducing surface fuels and increasing the height to live crown (by pruning or removing brush and 

saplings) as a first priority. A decrease in crown closure by thinning should be a second priority.” 

Butcherknife/Slate would implement both of these priorities, if approved, focusing on the smaller 

trees and reducing surface fuels. 

Page 9 
--------------------------------------- 

14. “Why isn’t it true that ‘the more wood removed the better’? Why should ‘big, 

old’ trees be retained? First, larger-diameter woody materials do not pose a 

significant threat for wildfire ignition or spread. It is largely the finer fuels (a few 

inches and less in diameter) that carry fire. More important, large, old trees 

actually provide protection from fire spread because they are resistant to fire and 

their shade maintains favorable moisture conditions in the understory fuels. Too 

much thinning of the forest canopy can produce more rapid drying of such fuels 

and, thereby, more frequent and severe wildfire risk. Furthermore, big, old trees 

provide critical habitat and maintain key ecosystem functions.” 

Testimony of Norman L. Christensen, Jr., Ph.D., Before 

the Senate Committee on Agriculture, Nutrition and Forestry 

regarding H.R. 1904—the Healthy Forests Restoration Act of 2003 

June 26, 2003 

http://wwwpaztcn.wr.usgs.gov/fire/hr_1904_testimony_christensen.pdf

The Butcherknife/Slate proposal would keep nearly all large old trees on site. As is acknowledged 

in this prepared testimony: “There is general agreement that fuel reduction – by prescribed fire or 

mechanical thinning – is needed in many of these forests [page 1].” Moreover, Dr. Christensen 

suggests several priorities needed for effective hazardous fuel reduction: “They are, in order of 

importance, ground fuels and fine woody debris, ‘ladder’ fuels that carry fires into the canopy, and 

smaller trees where densities are judged to be abnormally high [page 1].” These priorities fit 

harmoniously with the actions proposed for the Butcherknife/Slate fuel treatment project. 

--------------------------------------- 

15. “In eastern Oregon and Washington, Lehmkuhl et al. (1995) and Huff et al. 

(1995) reported a positive correlation between fuel loadings, predicted flame 

lengths and logging. They attributed the increased fire hazard in managed areas to 

slash fuels generated as a by-product of tree removal activities (including 

thinning), and to the creation of dense, early-successional stands via logging that 

have a high fire potential. A post-fire study of the effectiveness of fuels treatments 

– including thinning – on previously non-harvested lands in the Wenatchee 

National Forest, Washington found that harvest treatments likely exacerbated fire 

damage (USDA 1995).” 

 

“Some land managers and forest scientists advocate the widespread use of 

silvicultural treatments (of which thinning is the most widely proposed harvestbased fuels reduction method) in western roadless areas to reduce fuel loads and 

tree stocking levels, and thereby decrease the probability of large, intense fires. 

Although thinning within the context of intensive forestry is not new, its efficacy as 

a tool for fire hazard reduction at the landscape scale is controversial, largely 

unsubstantiated, and fundamentally experimental in nature (Henjum et al. 1994, 

DellaSala et al. 1995, SNEP 1996, FEMAT 1993).” 

 

Page 10 
“In some instances, as noted above, thinning treatments intended to reduce fire 

hazard appear to have the opposite effect (van Wagtendonk 1996, Weatherspoon 

1996, Huff et al.1995). Such treatments may reduce fuel loads, but they also allow 

more solar radiation and wind to reach the forest floor. The net effect is usually 

reduced fuel moisture and increased flammability (Agee 1997, Countryman 1955).” 

 

Frost, Evan 1999. “The Scientific Basis for Managing Fire and 

Fuels in National Forest Roadless Areas” - Appendix G 

http://209.85.173.104/search?q=cache:LaOMIfF8eaoJ:www.landsinfo.org/ecosystem_defense/Resources_

Species_Topics/Fire/Fuels%2520management%2520in%2520RoadlessFrost.doc+%22Ecosystem+management+in+western+interior+forests%22+DellaSala+Olson+Crane+1995&

hl=en&ct=clnk&cd=7&gl=us

The author’s comments are directed at treatment of roadless areas where no previous timber 

harvests have occurred. All fuel reduction actvities proposed for Butcherknife Slate would occur 

in an area adjacent to private residences in forest stands that have been previously managed. No 

logging/mechanical thinning is proposed in undeveloped areas. 

--------------------------------------- 

16. “The notion that commercial logging can prevent wildfires has its believers and 

loud proponents, but this belief does not match up with the scientific evidence or 

history of federal management practices. In fact, it is widely recognized that past 

commercial logging, road-building, livestock grazing and aggressive firefighting 

are the sources for "forest health" problems such as increased insect infestations, 

disease outbreaks, and severe wildfires.”

 

“How can the sources of these problems also be their solution? This internal 

contradiction needs more than propaganda to be resolved. It is time for the timber 

industry and their supporters to heed the facts, not fantasies, and develop forest 

management policies based on science, not politics.” 

 

Ingalsbee, Timothy Ph.D. 2000. “Commercial Logging 

for Wildfire Prevention: Facts Vs Fantasies” 

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

Dr. Ingalsbee presents this opinion compilation listing six “facts” about the use of logging as an 

instrument for “wildfire prevention.” Dr. Ingalsbee further offers several quotes from selected 

science papers, assessments, reports and testimonial texts, presumably to afford supporting 

evidence for his six logging facts. 

While each of the six facts state a perspective that is ostensibly true, the veracity of the statements 

can not be verified in whole or in part for a specific situation because no context for applicable 

environmental, spatial or temporal conditions is defined and no exceptions are provided. For 

example, would Fact 2 (“Commercial logging reduces the ‘overstory’ tree canopy which 

moderates the microclimate of the forest floor [page 1].”) hold true where only understory 

(intermediate) trees of commercial value were cut in a stand and removed, or where 10 overstory 

trees per acre (out of 200 trees/ac) were felled, or where defoliating insects have already weakened 

Page 11 
or killed most overstory trees? For each statement (fact) presented, the universal applicability of 

the fact is at best unclear in all situations that could be supposed. 

Furthermore, we are unclear as to how the stated facts might apply to the Butcherknife/Slate 

proposal. Most of the facts have little applicability to the proposal being considered since harvest 

of commercial-sized trees is but one activity among many that would be implemented to achieve 

project objectives, including fuel hazard reduction. Indeed, no added information is revealed in 

this opinion paper that has not already been presented in the references above. 

 --------------------------------------- 

17. “Logging slash was generally left where it fell creating abnormal fuel loads in 

these dry forests. Thus, the potential for future epidemics of insects and disease 

and more destructive fires was becoming established.” 

 

“Extensive railroad logging throughout the [inland West] region created dangerous 

levels of dry logging slash resulting in extreme fire hazard. For example, in 1931 

on the Boise National Forest, stand-destroying wildfire burned 62,000 acres of 

ponderosa pine/Douglas-fir forest that had previously experienced only surface 

fires for, at the least, 300 years. Observers attributed the intensity of this fire to the 

large volume of slash created by railroad logging in the late 1920s.” 

 

W.W. Covington et. al, 1994. “Historical and anticipated changes 

in forest ecosystems of the inland West of the United States.” 

http://www.haworthpress.com/store/ArticleAbstract.asp?sid=S8X5JWWVNUDC9PX372R6E0C9FDDK9Q5

D&ID=76732

The above quotes refer to timber cutting practices of the 1800’s and early 1900’s – not to current 

management practices. This paper is also geographically oriented to the Inland West and is 

therefore not necessarily representative of southwestern Oregon. Moreover, the authors conclude 

that “... there is still time for remedial actions, both to minimize the negative environmental 

consequences of climatic changes and to capitalize on the positive [page 50].” The Butcherknife/ 

Slate proposal would treat the activity slash and mitigate the fuel hazard, as described in the EA. 

 

--------------------------------------- 

18. “The Forest Service's own fire experts have found that a home's survival rate 

depends almost entirely on its location, its condition and its immediate 

surroundings, not on more commercial logging and roadbuilding in the 

backcountry.” 

 

From a July 18, 2002 letter to Chief Dale Bosworth signed 

by representatives of 148 conservation organizations 

representing over 450,000 average Americans. 

http://www.nativeforest.org/campaigns/public_lands/bosworth_7_18_02.htm

Page 12 
No new science or science data is revealed in this letter, which was written to the Chief of the 

Forest Service in 2002. See our comment provided in #3, above. The Butcherknife/Slate project is 

not located in the backcountry but rather is situated in the wildland urban interface designated by 

the Josephine County Integrated Fire Plan. 

--------------------------------------- 

19. “Recent editorials by timber industry spokespersons are a wildly misleading 

attempt to promote increased logging of western U.S. forests under the guise of 

reducing wildland fires ...” 

Hanson, Chad Ph.D., “Logging Industry Misleads on 

Climate and Forest Fires.” Guest Commentary in New West, 7-11-08 

http://www.newwest.net/topic/article/logging_industry_misleads_on_climate_and_forest_fires/C41/L41/

No new science or information is revealed in the above quote from this guest commentary. This 

statement is simply the author’s assertion of what the “timber industry” was promoting in recent 

opinion pieces he read. Was there an intent or suggestion related to Butcherknife/Slate that we 

have overlooked in your submission of this quote? 

--------------------------------------- 

20. “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.” 

From the June 26 2003 testimony of Mr. Mike Peterson 

to the Senate Agriculture, Nutrition, and Forestry Committee 

concerning the Healthy Forests Restoration Act, HR 1904. 

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

The Butcherknife/Slate project would feature retention of large fire-resistant trees in area stands 

and all treatments would be conducted within the wildland urban interface close to nearby private 

residences. 

--------------------------------------- 

21. “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 fireresilient, most commercially-valuable trees, and left behind dead needles and limbs 

Page 13 
(logging debris called "slash"), along with smaller trees and brush that are less 

commercially valuable but more flammable than mature and old-growth trees. The 

net effect is to increase the amount of available hazardous fuel.” 

 

“Secondly, the removal of large overstory trees also changes the microclimate of 

logged sites, making them hotter, drier, and windier, which increases the intensity 

and rate of spread of wildfires. Third, the creation of densely-stocked even-aged 

plantations of young conifers made sites even more flammable since this produced 

a solid mass of highly combustible conifer needles within easy reach of surface 

flames. These changes in the fuel load, fuel profile, and microclimate make logged 

sites more prone to high-intensity and high-severity wildfires.” 

 

Ingalsbee, Timothy Ph.D. 2005. “A Reporter's Guide to Wildland Fire.” 

Published by the Firefighters United for Safety, Ethics, and 

Ecology (FUSE), January 2005 

http://209.85.173.104/search?q=cache:FuTKT_jqv2oJ:www.fire.unifreiburg.de/media/A%2520Reporters%2520Guide%2520to%2520Wildland%2520Fire.pdf+ph.d.+%22fuels+

reduction%22,+%22commercial+logging%22&hl=en&ct=clnk&cd=19&gl=us

These quotes appear to simply be a restatement of the information and opinions presented by Dr. 

Ingalsbee in papers already reviewed above. We understand Dr. Ingalsbee’s perspectives. 

--------------------------------------- 

22. “The agency’s commercial timber program can contribute to the risk and 

severity of wildfire in the National Forests, yet Congress devotes nearly one-third 

of the Forest Service’s entire budget to this wasteful program.” (pg. 1) 

 

“Do not utilize the commercial timber program to reduce the risk of fire. 

Commercial incentives undercut forest health objectives and can actually increase 

the risk of fire.” (pg. 9) 

 

“Commercial logging, especially of larger, fire-resistant trees, in the National 

Forests is one of several factors contributing to the risk and severity of wildfire.” 

(pg. 19) 

 

“Commercial logging and logging roads open the forest canopy, which can have 

two effects. First, it allows direct sunlight to reach the forest floor, leading to 

increased evaporation and drier forests.5 As a consequence, ground fuels (grass, 

leaves, needles, twigs, etc.) dry out more quickly and become susceptible to fire. 

Second, an open canopy allows more sunlight to reach the understory trees, 

increasing their growth.6 This can lead to weaker, more densely-packed forests.” 

(pgs. 19-20) 

 

“Congress and the Forest Service continue to rely on the commercial logging 

program to do something it will never accomplish – reduce fire risk. The 

commercial logging program is designed to provide trees to private timber 

companies, not to reduce the risk of fire.” (pg. 20) 

Page 14 
 “From the Ashes: Reducing 

the Harmful Effects and Rising Costs of Western Wildfires” 

A Report by Taxpayers for Common Sense. Washington DC, Dec. 2000 

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

This report, written by Jonathan Oppenheimer, is directed at influencing national fire policy and 

represents a formal presentation of the opinions of Taxpayers for Common Sense. As might be 

supposed from the quoted text provided above, Dr. Ingalsbee (as well as several representatives 

from environmental advocacy groups) provided information and input for this report. Again, these 

quotes appear to simply be a restatement of the information and opinions presented by Dr. 

Ingalsbee in papers already reviewed above. We understand Dr. Ingalsbee’s perspectives. 

--------------------------------------- 

23. “Despite what the commercial logging industry and the Bush administration 

claim, these same interests are engaged in a devious attempt to trick the public 

into supporting increased logging in the name of "fuel reduction projects." Those 

pushing this "Healthy" Forest Initiative stress the urgency with which "thinning" 

projects must occur. The reason for the urgency is because they are cynical. They 

know that the window of time for the public to react to their propaganda is short 

and so they must make the most of it while they can. While the health of our public 

forests is pressing and urgent, the real danger is not forest fire. The real danger is 

the lasting damage we will do to our forests if we do not implement a forest policy 

that reflects sound science. Commercial thinning is not the way for us to improve 

forest health; we will lose the integrity of some of the last remaining public forests 

if that is the approach that we chose.” 

 

The increased proximity between homes and forestland has created a situation 

where rural homes are at great risk when fire breaks out. However, studies have 

shown that the most important factor in determining the susceptibility of a home to 

burn is the existence of trees within a close proximity of the home. Statistics show 

that as long as certain fire reduction guidelines are followed at the local level of 

each home, the risk for ignitability during a fire occurrence is very low. Jack D. 

Cohen, a scientist working for the Forest Service has written studies documenting 

the risk reduction of home ignitability. Cohen has concluded that remote thinning 

projects can do little to protect homes from wildfire. Instead, he recommends that 

the only way to reduce the risk is to remove trees near homes. The initiatives 

proposed by Bush do little to encourage these measures. Instead, the focus is 

placed on logging of remote areas that will likely have little effect on the protection 

of homes from fire.” 

 

Bartha, Emily. 2002. “The Real Threat to Our Public Forests? 

Unsound Science & Cynical Scare Tactics” 

http://www.crag.org/content/index.txt

Page 15 
This article is clearly an opinion piece and no new science is revealed in the above quotes. See our 

comment provided in #3 above regarding Dr. Cohen’s Technical Report. 

--------------------------------------- 

24. “The scientific consensus is that large and old trees should generally be 

retained, especially fire-resistant species such as pines. Indeed, from an 

ecological perspective these are absolutely the last trees that should be removed. 

Large and old trees are the most likely to survive a fire and subsequently serve as 

focal points for recovery. Large and old trees are also critical wildlife habitat, in 

part because they are the source of the standing dead trees (snags) and logs where 

animals live. Large old trees are essentially irreplaceable because they take 

centuries to reach that state.” 

 

“Logging as a part of fuel treatment programs is an issue that deserves serious 

consideration by everyone in the forest fire policy debates. On the one hand, 

traditional commercial logging operations are unlikely to improve fuel loadings 

significantly or alter potential fire behavior for the better. Such operations are not 

focused on the key ground and ladder fuels, and they also contribute additional 

ground and ladder fuels in the form of debris called slash.” 

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. 

http://www.issues.org/20.1/franklin.html

The sentences following immediately the text in the second paragraph quoted above continue with: 

“On the other hand, effective fuel removal is expensive when high densities of ground and ladder 

fuels exist, because at least some of them have to be removed, burned, or otherwise treated. 

Project costs can often exceed $1,000 per acre for an initial fuel treatment. Logging of small trees 

will rarely cover even the direct costs of fuel treatments because such trees currently have little 

economic value and are likely to have even less in the future. Hence, subsidizing fuel treatments 

by selling medium-sized trees that need to be removed anyway seems appropriate, given the scale 

of the challenge and the desire to reduce the impact on taxpayers [no page numbers but in 

approximately the middle of the article].” 

In these sentences, then, Dr. Franklin and Dr. Agee describe precisely the rationale behind the 

commercial logging proposed for some treatment stands in the Butcherknife/Slate area. Proposed 

activities would be focused on ground and ladder fuels, and would also treat the slash created by 

logging, but commercial wood harvesting assists with or covers the cost of decreasing existing 

fuels. Without such funding support, the fuel reduction work might remain undone. In all 

treatment situations, however, nearly all large and old trees now present would be retained. 

--------------------------------------- 

25. “It is well known scientifically that "commercial logging actually increases fire 

severity by removing large, fire- resistant trees and leaving behind very small trees 

and flammable "slash debris"--branches, twigs and needles from felled trees. The 

Page 16 
removal of mature trees also decreases the forest canopy, creating hotter, drier 

conditions on the ground. The additional sun exposure encourages the growth of 

flammable brush and weeds. Reduction of flammable underbrush can reduce fire 

severity, and environmental groups have encouraged such projects. However, the 

Bush administration has grossly misused the funds that Congress appropriated for 

brush reduction near homes. In Sierra Nevada national forests last year, more than 

90% of these funds were instead earmarked for preparation of large timber sales 

focused on the removal of mature and old-growth trees miles from the nearest 

town." 

 

"’The Forest Service, Bush administration and anti-environmental members of 

Congress are spreading a great deal of misinformation about wildfire, hoping to 

capitalize on public fire hysteria and minimize public opposition to increased 

logging and roadbuilding in our national forests," said Jake Kreilick of the National 

Forest Protection Alliance based in Missoula, Montana. "With virtually all new 

timber sales couched in terms of 'reducing fuels' or 'restoring forest health,' fire 

hysteria has emerged as the driving force behind the Forest Service's logging 

program and the administration's efforts to 'streamline' our nation's environmental 

laws,’ Kreilick said.” 

 

OVERVIEW & COMMENTARY by Forests.org, July 20, 2002 

http://portland.indymedia.org/en/2002/08/17464.shtml

This commentary, published via the Portland Independent Media Center, is an opinion piece by Dr. 

Glen Barry. It is a perspective on national fire policy under the Bush administration by 

Forests.org. No new science or information is revealed in the above quote from this commentary. 

--------------------------------------- 

26. “President Bush’s “Healthy Forests Initiative” proposes to protect 

communities from wildfire by allowing more commercial logging and bypassing 

certain environmental regulations. However, a panel of forestry experts and 

firefighters recently concluded that logging forests outside the wildland-urban 

interface will do little to protect communities from fire (Walker and Schardt 2002).” 

 

2003. “Forest Fire in the American Southwest. 

Putting the pieces together.” 

A publication of Northern Arizona University 

http://forestfire.nau.edu/wui.htm

This is an opinion article, directed at federal fire policy, hosted by the Science Communication 

Network. The Butcherknife/Slate project is located within the wildland urban interface, as defined 

by the JCIFP. 

--------------------------------------- 

27. “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 

Page 17 
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. 

Brian Leitner, “Logging Companies are Responsible for 

the California Wildfires.” the Democratic Underground, October 30, 2003. 

http://www.democraticunderground.com/articles/03/10/30_logging.html

Within the article, the above quote apparently relates to clearcut logging only. Butcherknife/Slate 

has no proposed clearcut (regeneration) logging units. The article also addresses thinning, but 

defines thinning as “taking the largest, healthiest, and most fire-resistant trees they can find and 

leaving the smaller, more flammable trees behind [page 2].” The Butcherknife/Slate proposal 

would leave the largest, healthiest and most fire-resistant trees within a treated stand, which is the 

intended result of low thinning, the most common form of the various intermediate treatments 

(thinning prescriptions) practiced in the US. The historical partial-cutting results described by Mr. 

Leitner are commonly described as ‘high grading’ and are not the practice of today’s silvicultural 

systems used on public lands. This article is clearly an opinion piece. 

--------------------------------------- 

28. “But decades of well-intentioned efforts to squelch wildfires, selective logging 

that removed the most fire-proof trees for commercial sale and a century of rapid 

development throughout the American West have left millions of public acres and 

thousands of communities at risk.” 

Jon Bonné. “Man’s meddling worsens wildfires. 

MSNBC news 

http://www.msnbc.msn.com/id/3072191/

This quote is taken from a 2002 news story that describes logging practices of the past as a means 

for understanding contemporary forest conditions. Partial-cut (“selective”) logging, which aimed 

to ‘high grade’ the biggest trees and then remove them from a forest stand, has been absent from 

the public forestry tool bag for at least 40 years. The stated purpose of the Butcherknife/Slate 

proposal is to retain large, fire-resistant trees on site wherever possible and safe to do so. 

--------------------------------------- 

29. “Before the Bush Administration and Congress pass sweeping new legislation 

to increase commercial logging under the guise of wildfire prevention, they had 

better first hear from ground-level firefighters who know that taking out big trees 

and leaving behind small trees, brush, and slash does not help, but rather, hinders 

protection of communities, and increases the hazards facing wildland firefighters,” 

said Timothy Ingalsbee, a former fire pro technician for the National Park Service, 

with eight years wildland firefighting experience. Ingalsbee is director of the 

Western Fire Ecology Center for the American Lands Alliance, and advocates on 

Page 18 
behalf of firefighter safety. “It is time for Congress and the Administration to 

prioritize community fire protection over commodity timber production.” 

 

Firefighters proclaim “no destructive forest policies in our name!” 

Published in the Earth Times, September 2002 

http://www.sdearthtimes.com/et0902/et0902s3.html

This quote is apparently from a 2002 “news story” distributed directly by the Western Fire 

Ecology Center (Dr. Ingalsbee’s advocacy organization), prior to the passage of the Healthy 

Forests Restoration Act of 2003 (HFRA, P.L. 108-148). Again, this quote appears to be a 

restatement of the opinions presented by Dr. Ingalsbee in papers already reviewed above. We 

understand Dr. Ingalsbee’s perspectives. 

--------------------------------------- 

30. “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.” 

 

Glen Barry, Ph.D. “Commercial Logging Caused Wildfires” 

Published by the Portland Independent Media Center, August 2002. 

http://portland.indymedia.org/en/2002/08/17464.shtml

This commentary, published via the Portland Independent Media Center, is an opinion piece and is 

from the same web page (and by the same author) as 25, above. It is a perspective on national fire 

policy and the Republican party by Dr. Barry, prior to the passage of the HFRA. Dr. Barry holds a 

Ph.D. in "Land Resources" from the University of Wisconsin-Madison but is not a fire scientist. 

No new science or information is revealed in his commentary. 

--------------------------------------- 

31. “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 largediameter 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.” 

 “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

Page 19 
This commentary, published through Forests.org/Ecological Internet (Dr. Glen Barry’s advocacy 

organizations, where he serves as President), is an opinion piece by Dr. Barry directed at national 

fire policy, prior to the passage of the HFRA. No new science or information is revealed in the 

commentary he authored. We understand Dr. Barry’s perspectives. 

--------------------------------------- 

32. “But the majority of the protesters were angry about Bush’s plans to implement rules 

that would thin our national forests to reduce fire risk. Cascadia Forest Alliance volunteer 

Carrie Taylor said Bush’s plan to log mature and old forests ‘will only increase fire risks 

while providing taxpayer subsidized logs to the timber industry.’” 

 

“According to the Cascadia Forest Alliance, under the Bush proposal, ‘environmental laws 

and citizen involvement will be undermined or suspended so that federal land management 

agencies can increase logging and roadbuilding on public lands, one of the timber industry's 

highest priorities.’” 

 

Jackie Alan Giuliano, Ph.D. “Fire Suppression Bush Style: 

Cut Down the Trees!” Environmental News Service, 2002. 

http://www.ens-newswire.com/

Again, this is a commentary piece and is the author’s opinion, which shares a particular 

perspective and is directed at swaying national fire policy. As acknowledged in his commentary, 

in the paragraph just below the above-quoted paragraphs: “There is general agreement that decades 

of fire suppression in our forests has resulted in an unnatural buildup of dead wood that provides 

an ample fuel source for wildfires [page 3].” It is this fuel buildup, from both dead wood 

accumulation and from increased numbers of living trees, in the dry low elevation forest stands of 

the Butcherknife/Slate area, which proposed activities are designed to address. 

Dr. Giuliano is the author of Healing Our World Weekly Commentary and operates a web blog at: 

http://www.healingourworld.org. Now an “environmental educator,” his Ph.D. is in environmental 

studies from The Union Institute (Cincinnati, Ohio). Dr. Giuliano is not a fire researcher. 

--------------------------------------- 

33. “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.” 

 

Brant Short 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://repositories.cdlib.org/uclalib/egj/vol1/iss19/art3/

Page 20 
As with many of the above narratives, this is a commentary piece and was prepared for the 

Electronic Green Journal by the two authors. This article discusses the fires of the 2002 season 

and provides a specific perspective on the subsequent political debate surrounding federal fire 

policy, the Healthy Forests Initiative (August 2002) and subsequent passage of the HFRA in 

December 2003. As suggested within this article: “There is little doubt that wild fires are getting 

larger, costing more money, and threatening people and their property in record numbers. The 

question of how to respond to the fires demands attention, study, discussion and policy-making, all 

achieved through public discourse [page 12].” Public discourse is certainly one of the purposes of 

the environmental review underway for the Butcherknife/Slate proposal. Both of the authors are 

professors of environmental rhetoric and political communication within the School of 

Communication, Northern Arizona University, Flagstaff. 

--------------------------------------- 

34. “In summary, decades of research and experience regarding forest 

management and fire hazard in western Forests have taught us that 

1. ‘Logging’ does not reduce fire hazard, on the contrary, it can often increase 

fire hazard through generation of activity fuels and through reductions of 

forest health.” (pg. 4) 

 

Emily B. Roberson, Ph.D., Senior Policy Analyst, California 

Native Plant Society, From an August 12, 2002 letter to 

Chief Bosworth. 

 hhtp://www.plantsocieties.org/PDFs/Fire%20letter%20CNPS%208.02%20letterhead.pdf

This letter offers the official position of the California Native Plant Society (CNPS) and is directed 

at “poor policy conclusions [page 1]” regarding national fire policy, in the opinion of CNPS. As 

stated by Dr. Roberson, however: “CNPS is neither in favor of or opposed to logging per se [page 

2].” She goes on to explain in her letter that “... it is important to recognize that there are many 

types of forest management practices which are sometimes or always called ‘logging.’ Thinning 

of small understory trees, commercial logging of large trees, selective logging, clear cutting, 

logging of plantations, and logging in late seral forests and roadless areas may all be called 

‘logging,’ but have very different effects on resources and on fire hazard (Graham et al., 1999). 

Timber harvest also has very different impacts on fire hazard depending on the age and health of 

the forest being logged. As noted above, CNPS is not opposed to ‘logging’ in general, but we do 

oppose timber harvest where it is dangerous or ecologically harmful [page 3].” In conclusion, 

CNPS recognizes as point 2 (just below point 1 that is quoted above) that: “Reduction of fire 

hazard, through appropriate and safe combinations of mechanical removal of small diameter fuels 

and prescribed burning, should be the highest management priority where lives and property are at 

risk from fire, particularly in the urban wildland interface [page 4].” These are exactly the kinds of 

treatments included in the proposal under consideration for the Butcherknife/Slate project. 

Page 21 
Page 22 

--------------------------------------- 

In Conclusion 

After reading the 34 articles submitted by Mr. Artley, we find little or no evidence or support for 

the assertion that scientists have shown that “logging commercial-sized trees increases wildfire 

intensity.” Indeed, from the information reviewed, there is an overall appreciation that mechanical 

treatments (including cutting of commercial-sized trees) is an appropriate action to reduce fire 

hazard, especially when logging slash and excess woody debris is treated to decrease fuel 

quantities. No evidence, from peer-reviewed research completed by fire scientists, was presented 

that suggests that proposed treatments or objectives defined for the Butcherknife/Slate project are 

contrary to the body of data available regarding fuel treatments in the wildland urban interface.