through sand to coarse loess and then to normal fine loess. As the ice sheet retreated the wind in any given place would gradually become less violent. As the ice continued to retreat the area where loess was deposited would follow at a distance, and thus each part of the gravel pavement would in turn be covered with the loess. The hypothesis that loess is deposited while the ice is retreating is in accord with many other lines of evidence. For example, it accords with the boreal character of the mammal remains as described above. Again, the advance of vegetation into the barren zone along the front of the ice would be delayed by the strong outblowing winds. The common pioneer plants depend largely on the wind for the distribution of their seeds, but the glacial winds would carry them away from the ice rather than toward it. The glacial winds discourage the advance of vegetation in another way, for they are drying winds, as are almost all winds blowing from a colder to a warmer region. The fact that remains of trees sometimes occur at the bottom of the loess probably means that the deposition of loess extended into the forests which almost certainly persisted not far from the ice. This seems more likely than that a period of severe aridity before the advance of the ice killed the trees and made a steppe or desert. Penck's chief argument in favor of the formation of loess before the advance of the ice rather than after, is that since loess is lacking upon the youngest drift sheet in Europe it must have been formed before rather than after the last or Wuerm advance of the ice. This breaks down on two counts. First, on the corresponding (Wisconsin) drift sheet in America, loess is present,--in small quantities to be sure, but unmistakably present. Second, there is no reason to assume that conditions were identical at each advance and retreat of the ice. Indeed, the fact that in Europe, as in the United States, nearly all the loess was formed at one time, and only a little is associated with the other ice advances, points clearly against Penck's fundamental assumption that the accumulation of loess was due to the approach of a cold climate.