Attorney General Bonta Submits Comment Letter Strongly Urging the Trump Administration to Withdraw Its Illegal Proposal to Rescind the Public Lands Rule

OAKLAND - Co-leading a multistate coalition of six attorneys general, California Attorney General Rob Bonta filed a comment letter opposing the U.S. Department of the Interior's proposal to rescind the Bureau of Land Management (BLM)'s Conservation and Landscape Health Rule (Public Lands Rule), a landmark regulation that clarifies that conservation is a "use" of federal public lands on equal footing with mining, drilling, timber, and grazing across 245 million acres of public lands nationwide. importantly, the Public Lands Rule created formal leasing frameworks that allow BLM to lease land for conservation, restoration, and climate change mitigation purposes. Additionally, The Rule prioritizes designation of "areas of critical environmental concern" (ACECs) and provides for greater stakeholder engagement, including Tribal consultation, on management decisions on all BLM-managed lands. The Rule provides necessary tools for BLM to address the pernicious impacts of climate change on public lands across the United States. In the comment letter, the coalition highlights how the rescission of the Rule would not only be unlawful but would leave millions of acres more vulnerable to degradation, habitat loss, and worsening impacts from climate change.

"In this race to the bottom to dismantle climate and environmental progress, the Trump Administration is in first place. This time, they're attempting to recklessly rollback the Public Lands Rule that would illegally weaken vital protections, paving the way for exploitation of America's shared lands and undermining decades of conservation advancements," said Attorney General Bonta. "These public lands belong to all of us. California residents rely on healthy and resilient BLM lands to provide clean air and water for communities, habitat for wildlife, support our livelihoods, and provide recreational opportunities. The Administration must withdraw this illegal proposal immediately."

BLM is responsible for managing 245 million acres of public land including approximately 15 million acres of public land in California, under its "multiple-use and sustained yield" mandate established by the Federal Land Policy and Management Act of 1976 (FLPMA). BLM-managed lands in California are the ancestral homelands of Indigenous peoples and Tribal nations and supports a wide variety of historic and cultural resources. These public lands span remarkably diverse ecosystems, including forest, desert, coastal, mountainous, and grassland environments throughout the state. BLM-managed land in California also includes valuable and fragile resources in the California desert.

As of 2024, BLM had designated 233 ACECs in California, spanning 6,494,215 acres. The list includes:

• North Amargosa ACEC in Inyo County was designated to protect listed species, like the Amargosa vole. The Amargosa River contains an outstanding suite of rare and imperiled species found nowhere else on earth.
• Sacramento River Bend ACEC in Tehama County spans 20,558 acres and contains vernal pools, resulting from millions of years of soil and mineral layer formation, which contain abundant plants that attract pollinator species critical to agricultural productivity. This ACEC also contains wetlands, which act as natural water purifiers that filter pollutants and improve the water quality of California's Sacramento River and its tributaries. This ACEC offers over 17 miles of public river access and trails for hiking, biking, fishing, and horseback riding.
• Kaweah ACEC in Tulare County protects a grove of ancient Giant Sequoia trees, which sequester carbon and help combat climate change. The iconic trees, plus the extensive trail system, are popular tourist attractions.

Last month, the BLM issued a proposed recission, arguing that the rule is "unnecessary and violates existing statutory requirements," and precludes "productive uses" which BLM narrowly identifies as grazing, mining, and energy development.

In the comment letter, the multistate coalition explains that:

• Eliminating BLM's ability to lease lands for conservation is removing a tool to address widespread degradation of public lands. This will impede BLM from achieving FLPMA's mandate that BLM manage its lands for sustained resource yield for future generations.
• If finalized, the rescission would jeopardize public health and economic output to states. Public lands tourism benefits states in the form of jobs and new business development. In 2021, recreation on BLM-managed lands supported $11 billion in national economic output and 76,000 jobs. In 2023, outdoor activities contributed $81.5 billion to California's economy. The outdoor recreation industry generated about 545,500 California jobs that year, growing to about 2.9% of the state's total employment.
• The proposed rule is arbitrary and capricious, contrary to law, and violates the Administrative Procedure Act, the Federal Land Policy and Management Act, and the National Environmental Policy Act.
• Conservation is necessary to ensure that our natural resources - and the communities and economies that depend upon them - are sustained for future generations. FLPMA's multiple use mandate is a balancing act, not a license to deplete.

Attorney General Bonta and the Attorney General of Oregon co-lead a coalition including the attorneys general of Colorado, New Mexico, Vermont, and Washington.

A copy of the letter can be found here.