As to WDFW being in compliance or not with ESA? The simple answer is that technically they are as they have been granted by NMFS a grace period to submit their proposal under 4d. Until that grace period is officially and lawfully ended by NMFS or other legal action then their compliance with ESA is valid. Doesn't matter what they've done to date as long as that grace period is in place. And that my friends is the Law!