See In re Am. Rivers & Idaho Rivers United, 372 F.3d 413, 418 (D.C. Cir.

2004) (agency must

respond to a petition filed under its own rules); Indep. Mining Co. v. Babbitt, 105 F.3d 502,
507 n. 6 (9th Cor. 1997) (“[A]t some level, the government has a general, non-discretionary
duty to process the applications” provided for by statute.).