Embracing a strategy familiar to the Key Deer and the Conch Republic, the Plaintiffs now allege that FEMA's administration of the National Flood Insurance Program encourages development in the Delta, which adversely affects four species listed as threatened or endangered under the Endangered Species Act (“ESA”): the delta smelt, the Sacramento River winter-run Chinook salmon, the Central Valley spring-run Chinook salmon, and the Central Valley steelhead… [read post]