Interesting point of view but a little simplistic to zero in on numbers. While their objective does seem to be harvest the process used to get to the harvest numbers surrounding NOF ( which does not comply with the APA requirements ) would appear to be a primary target also.

I would agree that it is a big hill to climb as courts have traditionally given wide leeway to government agencies and money plays into it. WDFW depends on the fact that legal actions cost a ton of money and the old rope a dope is their preferred response. Burn up the litigants legal funds and settle and then do not follow the settlement is the tactics of choice for WDFW. As one who had to utilize the courts to get WDFW to comply with law how they do business is forever in the gray areas of law.