Plaintiffs are four trade groups representing fishermen who fish near San Nicolas Island. They ask the Court to hold unlawful and set aside action of the Fish and Wildlife Service (“FWS”) which, among other things, eliminated a regulation immunizing fishermen who accidentally harm California sea otters in this area. Intervenor- Defendants are seven non-profit organizations that share an affinity for marine mustelids. On November 11, 2016, Plaintiffs filed a motion for summary judgment. On December 16, 2016, the FWS and Intervenor-Defendants filed cross-motions.