 As Manila mayor, Atienza in 2003 enraged environmentalists when he ordered the closure of the Arroceros Forest Park to give way to the building of an education office and a teacher's dormitory, sparking a lawsuit.The Kalikasan People's Network said that Atienza had no moral authority to be at the helm of the DENR because he had "neither had sterling qualifications nor a clean track record of protecting the environment as former Manila Mayor.