Comment Analysis · Docket FS-2025-0001

FS-2025-0001-401710

Supports rescissionA3 weakSubstance 12/24Owed an answerPosted September 14, 2026 On Regulations.gov

In short: The comment establishes that the commenter is a livestock grazing permittee on the Sycamore allotment in the Verde River watershed who relies on National Forest System roads for permit administration, and documents the specific risk that rescinding the roadless rule without a funded maintenance plan will exacerbate the $6.9 billion deferred maintenance backlog, thereby degrading the working infrastructure required for grazing operations.

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

A3 weak: Substantive, but easier to set aside.

Owed an answer on Analytical gap.

Standard dismissals it defeats

Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
Outside the scope The agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.

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.
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.
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

Governance Policy Process
- “not opposed to local, project-level decision-making replacing a blanket national rule”
- “flexibility could serve ranching interests better than a one-size-fits-all prohibition”
- “permittees are treated as cooperating stakeholders”
- “commit, in guidance implementing any rescission”
Resource Development Extraction
- “livestock grazing permittee”
- “manage my permit — moving and gathering cattle”
- “existing routes needed to administer active grazing permits remain open”
- “working infrastructure, not incidental use”
Economic Impact Fiscal
- “$6.9 billion deferred maintenance backlog”
- “flexibility without funding is not flexibility, it's deferred cost”
- “paired with a real maintenance funding commitment”
- “no maintenance budget behind that added use”

What it names

National Forests: Prescott National Forest

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapEvidence

I am submitting this comment as a livestock grazing permittee on the Sycamore allotment, Prescott National Forest, in the Verde River watershed. I depend directly on National Forest System roads to manage my permit — moving and gathering cattle, maintaining stock tanks and other water developments, checking and repairing fence, and meeting the terms of my grazing permit. I ask that as this rule making moves forward, and as any resulting forest-plan or project-level decisions are made, the agency keep two things squarely in view. 1. Protect ranching access and infrastructure explicitly. Returning roadless-area decisions to individual forest plans and project-level review, as this proposal does, should not put existing ranching access at risk. The roads and routes permittees currently rely on to administer their allotments — including in inventoried roadless areas — are working infrastructure, not incidental use. I ask that the Forest Service commit, in guidance implementing any rescission, that (a) existing routes needed to administer active grazing permits remain open and maintainable without new procedural barriers, (b) permittees are treated as cooperating stakeholders — not just members of the general public — in any forest-plan-level roads analysis that follows this rule change, and (c) maintenance or reconstruction of a road needed to reach a stock tank, water development, or allotment boundary is not treated the same as new road construction for other purposes. 2. Don't open more roads than the agency can maintain. The proposed rule itself acknowledges a $6.9 billion deferred maintenance backlog for Forest Service roads and bridges. That backlog is not an abstraction where I ranch — roads I already depend on are washed out, rutted, or impassable because there has never been funding to maintain them properly. Rescinding the roadless rule without a funded maintenance plan risks making this worse, not better: every mile of new road opened for recreational access (OHV routes, dispersed camping spurs, etc.) is a mile added to a system the agency has already shown it cannot keep up. Recreational traffic accelerates wear on shared routes — the same roads ranchers use to move cattle and equipment — and when there's no maintenance budget behind that added use, degradation compounds and eventually falls back on permittees to work around washed-out or unmaintained roads just to do routine allotment work. I am not opposed to local, project-level decision-making replacing a blanket national rule — in principle, that flexibility could serve ranching interests better than a one-size-fits-all prohibition. But flexibility without funding is not flexibility, it's deferred cost shifted onto the roads people already use. I ask that any decision to open new roads in former roadless areas — particularly for recreation — be paired with a real maintenance funding commitment, and that expanding the road network not be prioritized ahead of maintaining the routes that grazing operations, and other working uses of the forest, already depend on.