Complaint for Failure to Act on Petition to List Alaska Chinook Salmon Under the ESA

Plaintiff Wild Fish Conservancy (the “Conservancy”) brings this action under the Endangered Species Act (“ESA”), 16 U.S.C. §§ 1531–1544, against Defendants the United States Department of Commerce; Howard Lutnick, in his official capacity as the Secretary of Commerce; the National Marine Fisheries Service; and Eugenio Piñeiro Soler, in his official capacity as the Assistant Administrator for Fisheries (collectively, “the Service”), for failing to take statutorily required action on the Conservancy’s Petition to Designate EvolutionarilySignificant Units and List Alaska Chinook Salmon (Oncorhynchus tshawytscha) under the ESA (“Petition”). See 16 U.S.C. § 1533(b)(3)(B). Compliance with the statutory mandate is necessary to ensure the continued survival and recovery of Alaska Chinook salmon.