Comment Analysis · Docket FS-2025-0001

FS-2025-0001-609546

Opposes rescissionA0 noneSubstance 8/24Posted October 7, 2026 On Regulations.gov

In short: The comment documents that the DEIS acknowledges soil erosion risks from removing roadless protections, which threatens the surface water supply for Yachats, Oregon, and cites university research indicating that new roads increase wildfire ignition likelihood by four times.

Scored directly — The comment's whole text was scored on its own.

Scorecard

Each dimension is scored 0–3; the eight sum to the substance score out of 24.

  • Specific placeNames a specific location — from a region down to an exact creek, trail, road, or map reference.
  • Local knowledgeDraws on a first-hand connection to the place — visits, sustained activity, occupation, or a professional role.
  • EA analysisEngages the agency's environmental analysis directly.
  • Analytical gapIdentifies something the analysis fails to address.
  • EvidenceBacks claims with specific facts, data, or research.
  • RequestMakes a specific, actionable request of the agency.
  • AlternativeProposes a different course of action.
  • LegalCites statutes, regulations, or legal obligations.

How hard it is to set aside

A0 none: Counted, not answered.

Still open to the agency

  • Alternative already eliminated The agency says it considered and eliminated the alternative the comment proposes, with a reason. Cannot be defeated from the comment text alone.
  • Already addressed The agency says its analysis already covers the point. Defeated when the comment cites the law itself: there is no analysis to cite against a statutory claim.
  • Deferred to a later decision The agency says the point belongs to a later, site-specific decision. Cannot be defeated from the comment text alone.
  • Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
  • Not required The agency says the analysis the comment asks for is not required. Cannot be defeated from the comment text alone.
  • Preference noted The agency notes the comment as a statement of preference and takes no action on it. Cannot be defeated from the comment text alone.
  • No cause and effect shown The agency says the comment asserts a harm without showing how the action causes it. Defeated when the comment shows the mechanism.
  • Outside the scope The agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.
  • Certified not substantive The agency certifies the comment raises nothing substantive. Defeated when the comment alleges illegality, which is substantive by the definition the certification runs on.

Topics

  • Water Quality Quantity
    • “Yachats relies on surface water from Reedy Creek and Salmon Creek”
    • “removing roadless protections will risk soil erosion”
    • “Sediment will flow into those very creeks that supply our water”
    • “without fresh water flowing out of our faucets”
  • Forest Management Wildfire
    • “Increased logging and the accompanying roads will only increase the potential for fires”
    • “New roads will make our forests more vulnerable--not less--to wildfires”
    • “fires are four times more likely to be started near roads”
  • Environmental Protection Biodiversity
    • “loss of habitat for many species”
    • “degradation of our forests”
    • “increased potential for landslides”

What it names

National Forests
Siuslaw National Forest

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapEvidenceRequestAlternativeLegal

As a resident of Yachats, Oregon, I am deeply troubled by the proposed changes to the Roadless Act and urge you to reverse course and leave it as is. We need a permanent roadless rule. Increased logging and the accompanying roads will only increase the potential for fires that could devastate our nearby forests and potential endanger our homes. New roads will make our forests more vulnerable--not less--to wildfires. The University of Oregon and Oregon State University scientists have researched this vital issue and they have concluded that fires are four times more likely to be started near roads due to increased vehicle traffic. Yachats relies on surface water from Reedy Creek and Salmon Creek, tributaries of the Yachats River. This flows directly out of the Siuslaw National Forest. Your own DEIS acknowledges the likelihood that removing roadless protections will risk soil erosion. Sediment will flow into those very creeks that supply our water. The Yachats treatment plant will struggle to filter our water and we might end up without fresh water flowing out of our faucets. Our community, like so many others in our beautiful state of Oregon, will see degradation of our forests, increased potential for landslides that can cut us off entirely (like the area near Siletz on Highway 229 that will take years to address), and loss of habitat for many species. I strongly oppose these changes.

Keep learning. Keep speaking up.The Roadless Rule depends on public engagement. Share what you've learned.

© 2026 roadless.org - Defending America's Last Wild Forests

Privacy Policy|Questions or concerns? noroads@roadless.org|Follow us: @defendroadless