Technically is maybe a bit off. The NOF process was designed to appear to comply with APA process. Appear is the word that is the crux. Reality is the NOF process never met legal standards nor was it intended to but it was intended to appear it did. As time went on and things changed it simply ended up farther from compliance and just got way to obvious and was challenged. The only time WDFW changes is when a judge says " you shall ".