I would like to pick your respective brains regarding the sequence of events for what happens after a salmonid population is listed as threatened or endangered under the ESA with respect to creation of HGMP’s.

As I understand it if a population is listed there is a 60 day cooling off period before 4D rules are created and go through the federal registry and public input. Then after the 4D rules are formulated and in place the action agency (ODFW) running the hatchery program is to create and submit the required HGMP.

Question:
What is the timeframe that an action agency has to create the HGMP before they are considered out of compliance?

Question:
Can they be sued the day after the 4D rules are in place for not having a completed HGMP?

Question:
With respect to the Oregon Coastal Coho that are now not listed but are proposed to be, will NOAA have to create new 4D rules and how long will that take?

Question:
How does NOAA enforce the Creation of HGMPs?

Question;
Internet searches show that action agencies do not have to create and submit an HGMP for a hatchery program after a new listing until there is a change in the hatchery program operation, but if that were true and no changes were ever made then an HGMP would never have to be made? Correct?

Best regards

POS Clerk