Unfortunately yes. In 2007 the Sierra Club successfully sued the Forest Service to prevent them from creating a Categorical Exclusion (CE) to NEPA for controlled burns (the technical term is "fuel reduction"). The CE would have allowed the forest service to conduct burns without having to perform a full EIS (the median time for which is 3.5 years). See: caselaw.findlaw.com/court/us… John Muir project helped to claw back the full scope of Categorial Exclusions from the 2018 Omnibus Bill as well (though some easement did make it through). In 2021 the outgoing Trump BLM was served with the following notice of intent to sue by the Center for Biological Diversity for their fuel reduction plan in the Great Basin: biologicaldiversity.org/prog… BLM backed away from the plan after the transition. These are specific cases, but the cumulative outcome is that CA state agencies don't even try it because they know they'll be sued.