overturning Chevron didn't by itself overturn any regs where it was applied. Those would have be pursued under APA case by case in the future. I don't think overturning Chevron was nearly the big deal it's being made out to be. One recent Admin lost most of their APA challenges (like nearly 80%) even with Chevron in their pocket. You either make your decisions APA proof or you don't. I think there is more pressure on Congress now to say what they mean when they pass something; otherwise they risk being meaningless. And it makes the fed govt even more like steering a barge, not a race car FWIW, I required monitoring similar to what NMFS did but I didn't make them pay. I let them handle it any way they wanted, they were just liable for doing it...which is what NMFS should have done. They were wrong and got their butt handed to them. The statute of limitations thing was easy as well. The injury occurs when it occurs as the rules continue to be applied.