MEMORANDUM OPINION AND ORDER
SULLIVAN, District Judge.
This action challenges the validity of two administrative regulations promulgated by the Department of the Interior ("DOI"), the U.S. Fish and Wildlife Service ("FWS"), the Department of Commerce ("DOC"), and the National Marine Fisheries Service ("NMFS") (collectively, "the Services"): the so-called "No Surprises Rule," 63 Fed.Reg. 8,859 (Feb. 23, 1998) (codified at 50 C.F.R. §§ 17...
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