Pursuant to a 2007 lawsuit, the National Marine and Fisheries Service (NMFS) issued a Biological Opinion requiring FEMA to develop reasonable and prudent alternatives (RPAs) to its current floodplain regulations and implement changes to the National Flood Insurance Program (NFIP) to address takings of Endangered-Species Act (ESA)-listed species in Oregon. The first stage of FEMA’s compliance plan began with Pre-Implementation Compliance Measures (PICMs).