In 2009, to protect threatened salmon and steelhead under CWA and ESA, EPA and National Marine Fisheries Service (NMFS) recommended limits on the use of chlorpyrifos in California, Idaho, Oregon and Washington and requested that manufacturers voluntarily add buffer zones, application limits and fish toxicity to the standard labeling requirements for all chlorpyrifos-based products. Manufacturers rejected the request. In February 2013 in Dow AgroSciences vs NMFS, the Fourth Circuit Court of Appeals vacated EPA's order for these labeling requirements. In August 2014, in the settlement of a suit brought by environmental and fisheries advocacy groups against EPA in the U.S. District Court for the Western District of Washington, EPA agreed to re-instate no-spray stream buffer zones in California, Oregon and Washington, restricting aerial spraying (300 ft.) and ground-based applications (60 ft.) near salmon populations. These buffers will remain until EPA makes a permanent decision in consultation with NMFS.