Interesting question if this program has an approved HGMP or not. I can find no record of NOAA approving one even though NOAA through their Manchester Research Station is one of the responsible organizations for this program along with WDFW, Long Live the Kings and the US Fish & Wildlife Service. NOAA also provides partial funding for the project for rearing at Manchester along with monitoring and evaluation, which also requires a permit.

Let's get some more lawyers on this. Looks like there could be lots more people and agencies to be sued.