1 Trinidad, in Del Norte and Humboldt Counties, have levels of domoic acid 2 that exceed the action threshold. 3 170. As a precaution to avoid poisoning humans with domoic acid, the State of Oregon 4 delayed the opening of the Dungeness crab season at the beginning of the 2015–16, 2016–17, 5 and 2017–18 commercial Dungeness crab seasons: a. 6 until nearly five weeks after the normal season opening date. 7 b. 8 In 2016–17, the commercial crabbing season was delayed by approximately 9 one month. After being open for approximately one month, the season was 10 interrupted when domoic acid was again identified in crab at levels 11 exceeding the action threshold. In response, ODFW and ODA curtailed the 12 fishery in several ways, including by closing large areas of the ocean to 13 crabbing and by issuing mandatory evisceration orders, which prohibit crab 14 wholesalers from purveying live crabs or any crab product containing the 15 crab viscera. c. 16 In 2017–18, the statewide commercial crab season was again delayed over 17 six weeks in response to domoic acid contamination. ODFW and ODA also 18 imposed mandatory evisceration orders for certain times and areas. d. 19 As of this writing, the 2018 Oregon recreational crab fishery (which 20 operates on a different schedule than the commercial fishery) is closed from 21 Cape Blanco to the Oregon/California border due to high levels of domoic 22 acid in crab. 23 171. Additional domoic acid-induced Dungeness crab fishery closures will occur in the 24 future, with increasing frequency and severity, and with concomitant impacts on and injuries to 25 Plaintiff and west coast fishing families, communities and businesses. 26 SHER EDLING LLP In 2015–16, the entire coast of Oregon was closed to commercial crabbing 172. Due to domoic acid contamination and the resultant crab fishery closures, 27 commercial fishermen were deprived of valuable opportunities to fish for Dungeness crab during 28 substantial portions of the 2015–16, 2016–17, and 2017–18 crab seasons, and will be deprived of COMPLAINT 74