60-Day Notice of Intent to Sue: Violations of the Endangered Species Act Failure to Designate Critical Habitat for Distinct Population Segments of Humpback Whales

This letter serves as a sixty-day notice of intent to sue NOAA Fisheries over violations of Section 4 of the Endangered Species Act, on behalf of the Center for Biological Diversity, Turtle Island Restoration Network, and the Wishtoyo Chumash Foundation. Specifically, NOAA Fisheries failed to designate critical habitat for the Mexico, Central America, and Western North Pacific distinct population segments of the humpback whale under the ESA. NOAA Fisheries' failures deprive these imperiled species of important protections and put them at further risk of extinction. This letter is provided pursuant to the 60-day notice requirement of the citizen suit provision of the ESA, to the extent that such a notice is deemed necessary by a court.