If they had prepared an application and submitted it then it would have been easy to accuse them of bad-faith negotiations, at least by the Tribes and NOAA. Even if they had applied, NOAA would still have had to act and they were playing catch-up with the steelhead HGMPs.

Kinda obvious that this whole process shows no long-range planning or real commitment to accomplishing anything what with NOAA holding the permit cards and being underfunded and understaffed.