Attorney General Bonta Defends Cornerstone of U.S. Forest Conservation

OAKLAND — California Attorney General Rob Bonta co-led a coalition of 17 attorneys general in submitting a comment letter opposing the Trump Administration’s proposed rule to rescind the 2001 Roadless Area Conservation Rule (Roadless Rule) and the accompanying draft Environmental Impact Statement (EIS). If adopted, the United States Forest Service’s (USFS) proposal would remove vital forest protections and open nearly 45 million acres of national forest lands to road construction, timber harvesting, mining, and oil and gas development in some of the last protected stretches of forests nationwide. The proposed rule, which follows USFS’s notice of intent to propose the changes last year, is the latest chapter in the Trump Administration’s efforts to reduce protections for National Forests, including the Roadless Rule. In the letter, Attorney General Bonta and the coalition argue that the proposed rule and draft EIS do not meet the legal requirements of the Administrative Procedure Act (APA), National Environmental Policy Act (NEPA), and National Forest Management Act and would fragment vulnerable ecosystems, jeopardize clean water sources, threaten plant and wildlife habitat, and undermine efforts to mitigate the effects of climate change. 

“Our Golden State is home to some of the most pristine and diverse ecosystems in the nation. We will not stand by and allow the federal government to subject our National Forests to commercial exploitation,” said Attorney General Rob Bonta. “Time and time again, the Trump Administration has demonstrated a willingness to devastate our environment and public lands for the sake of short-term economic gain. But the evidence is clear: roadbuilding and logging increase risks of wildfire, destroy habitat, and disrupt clean water resources. California greatly cares about protecting our forests and ensuring they are preserved for future generations. We are strongly urging this Administration to abandon its course of action.” 

"This reckless proposal threatens millions of acres of our public lands," said California Secretary for Natural Resources Wade Crowfoot. "For 25 years, the Roadless Rule has helped protect California's clean water, wildlife habitat, recreational backcountry, and some of our most treasured public lands. Repealing it would put those protections at risk when we need them most."

The Roadless Rule was established in 2001 to prohibit road construction, reconstruction, and commercial logging in designated “roadless areas” of National Forests to preserve their ecological integrity, shield wildlife habitat, protect watersheds, and maintain opportunities for recreation. Among the primary nationwide drivers of the Roadless Rule were the desire to prevent further fragmentation of the few remaining roadless areas, and the concern that case-by-case local decisions would comprehensively and cumulatively have a large impact on biodiversity by increasing habitat fragmentation.

In June 2025, in response to President Trump’s Executive Order 14225, “Immediate Expansion of American Timber Production,” the USFS announced its intent to rescind this rule. The proposed rule changes would open 4.4 million acres of National Forests in California to potential new roadbuilding, road reconstruction and logging, as well as other industrial uses such as mining, oil, and gas development. This would affect sensitive waterways, recreational areas, and wildlife habitat in all 20 National Forests in California with significant roadless areas. 

In the comment letter, Attorney General Bonta and the coalition urge the USFS to rescind its proposal, and assert that, among other things: 

• The proposed rule is contrary to the National Forest Management Act of 1976 and the APA, as it would change land and resource management plans within each National Forest without undergoing the required plan amendment or revision process. 
• The proposed rule is arbitrary and capricious and in violation of the APA because the agency fails to justify its change in policy, does not provide a reasoned basis for rescinding the prohibitions of road construction and reconstruction, and fails to make the necessary connection between the rescission of the Roadless Rule and the need for increased wildfire management.
• The proposed rule fails to address legitimate reliance interests in the Roadless Rule, as states rely on the rule to provide clean affordable water, protect aquatic life, promote recreation, and meet conservation and climate goals, among other things.
• The draft EIS from the agency does not comply with NEPA or the APA because the agency’s statement of purpose and need is unreasonably narrow, unlawfully limits the consideration of a range of reasonable alternatives, and departs from previous agency positions without a reasonable explanation.
• The proposal directly violates NEPA, as it fails to sufficiently consider the reasonably foreseeable impacts of the rule change on human environments as well as the economic impacts on small businesses. 

In sending this letter, Attorney General Bonta, alongside Washington Attorney General Nicholas Brown and Oregon Attorney General Dan Rayfield, co-led the attorneys general of Arizona, Connecticut, Illinois, Maine, Maryland, Massachusetts, Michigan, Minnesota, New Mexico, New York, North Carolina, Rhode Island, Vermont, and Wisconsin.

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