Scientific Peer-Review in the Endangered Species Act

Testimony of Dr. Deborah M. Brosnan

Sustainable Ecosystems Institute

May 9, 2001

Good morning. I am Deborah Brosnan, President and founder of the Sustainable Ecosystems Institute (SEI). The institute is a public-benefit non-profit organization, that provides impartial scientific support for conservation. We are rigorously non-partisan, and seek science-based, cooperative solutions that benefit both the environment and the human communities that depend on it. Currently over 300 scientists work with the institute to provide support to government, the private sector and citizen groups. Our work ranges from fundamental research to mediation, and the integration of science with policy.

Since our inception in 1992, the institute has worked to strengthen scientific principles and methods integral to the application of the Endangered Species Act. The ESA remains a key piece of the nation’s environmental laws. In common with many other scientists, we support legislation that protects the biodiversity that, ultimately, supports us.

In recent years, there has been extensive comment and critique of management under ESA. These critiques come from every side of the debate, but contain some themes that are common to all points of view. All parties, for instance, agree that the role of science needs to be enhanced. There are many calls for a wider and more effective use of independent and impartial scientific analysis. Of course, the Fish and Wildlife and National Marine Fishery Services (USFWS and NMFS) have committed to the use of scientific excellence, and indeed employ many fine scientists. However they would probably be the first to acknowledge the need for more resources, and better integration of their efforts with the nation’s other scientific resources. This is a point of view shared across the political spectrum.

Central to the idea of improving ESA science is the concept of peer review. Peer review is the scientific equivalent of quality control – it is our profession’s method of ensuring that analyses are carried out appropriately, that the best data are used, and that the conclusions drawn are appropriate. Peer review is a normal scientific process, for which there are long-established protocols, and which is widely applied to decisions about scientific publication and funding. However more practical applications, for instance to management of resources, are less frequent. The Magnusson Act is an example of an explicit application of peer review to an important conservation issue.

It is already the policy of NMFS and UWFWS that important decisions, such as listing actions, are subject to external peer review. However the widespread calls for increased use of peer review, as outlined in my accompanying table, testify to the general feeling that a more systematic and open process is desirable. At least 63 organizations, groups or individuals have separately called for inclusion of peer review into ESA revisions. The information in the table is revealing: resource user groups call for review of listing actions, while environmental organizations call for review of Habitat Conservation Plans and Recovery Plans. Essentially, each group wants to have impartial review of actions affecting their particular concerns. They are united in their common belief that an independent review would lead to better decisions and more effective management.

Perhaps these different groups all believe that their views on resource management would prevail following peer review. If so, they are mistaken. Science is value neutral. It can sometimes appear to favor one political point of view, sometimes another, though in fact it favors none. Scientific peer review can however be of great use in ensuring that good science is appropriately incorporated into management actions, in making decisions transparent, in ensuring that a fair and reasonable process is followed, and in making better decisions for natural resources. If the different groups want to see that conservation decisions are based on the best science, then peer review can indeed help. There is nothing to fear about the idea of peer review; however I will also argue that it is important to have a well thought out, and systematic process.

In the past few months, SEI has begun a pilot process to assist the Fish and Wildlife Service with peer review. This is a pro-bono effort by our scientists, and supports the Service’s existing policies and processes. Regional offices have been encouraged by the Service’s Director to use SEI’s assistance in finding and enlisting outside reviews. We have organized the National Network for Conservation Science, consisting of 300 volunteers, who provide help to the Service. Network participants are faculty at major universities and other experts, including 6 members of the National Academy of Sciences.

It is early days in this experiment, but we can provide some information on success rates. In the accompanying graphic I show that the Service has diligently sought out peer reviewers on their recent regulatory actions – often without recourse to SEI help. Sometimes they have been successful in obtaining reviews, as in the case of listing of the Alabama Sturgeon and other issues. Sometimes, however, the Service has sought reviews, but has not been successful in getting cooperation from the independent scientists. For instance, on Critical Habitat of the Arkansas Shiner, the Desert Bighorn and the California Gnatcatcher, all affecting large areas of habitat, no review was received from any of the 17 scientists approached by the Service. SEI usually has higher success rates in our program for the Service and other reviews. Typically we obtain 96% response rates.

I believe the elevated response rates are explained by several factors. Firstly, we have provided an infrastructure that allows the effective engagement of interested scientists, and ensures that such scientists are willing and able to respond, within the limited timeframes of agency actions. Secondly, as practicing scientists, we ‘speak the same language’ as the reviewers, and can explain our needs effectively. There is a substantial difference between the cultures of academia and regulatory agencies, so that the needs of one are not apparent to the other. Thirdly, we provide rewards to reviewers, either financial or professional, that encourages their response. Fourthly we act as a buffer to protect the integrity of the scientist and science. We look forward to further development of this review program with the Service, and believe that innovative, cooperative programs could meet many of the goals of all interested parties.

Peer review is not however a panacea. As I have previously outlined in an article for the National Academy (attached) simple extension of the academic model of peer review to applied management decisions can lead to significant problems. Peer review itself needs to be reexamined and carefully designed in order for it to be effective. Some examples: peer review in public decision making cannot be anonymous as in academia; the standard of proof criterion is different in the different contexts; decisions have to be made even when science is incomplete, or we will face ‘paralysis by analysis’. Because the science is used in a non-academic and management arena, it is important to maintain the integrity of the science and scientists. Scientists should not be asked to become managers or to defend a manager’s preferred option.

The lessons we have learned so far have been useful. Working within existing policies of the regulatory agencies, peer review can indeed contribute to effective management. Academic models of review, and existing infrastructures are however insufficient to the task. With the USFWS and our other partners we have begun a process to build the necessary structures - improvements are definitely possible, and resources will be needed. We estimate that a national program to provide peer review would cost between 3 to 5 million dollars annually (of course as a non-profit we cost a lot less than a federal agency would.) Peer review is a serious and professional undertaking. An ad hoc or poorly thought-out approach will lead to frustration. However, if properly implemented, peer review can contribute much to the ESA and other natural resources decisions.

Sustainable Ecosystems Institute

Examples of Calls for Peer Review under The Endangered Species Act

Organization	Where is Peer Review Desired?				How to Implement Peer Review?	Who Pays For It?
	General Peer Review	Listing	HCP	Other
Ecological Society of American Ad Hoc Committee on Endangered Species	X	No	X
9 Current and Past Presidents of Ecological Societies				Recovery Plans
Society of American Foresters		X
Society for Integrative and Comparative Biology	X		X		Independent Scientist Panel	Federal Government
Wildlife Society		X		Recovery Plans
Senator Ashcroft		X
Senator Lieberman		X		Recovery Plans
Congressman Steve Largent	X	X
National Governor’s Association	X
Western Governor’s Association	X				Independent experts chosen by USFWS and the states	Task force to find funding
Southern Governor’s Association	X	X
Governor Marc Racicot (MT)		X			Scientific review and cost/benefit analysis	Government task force finds a way to fund the process
State of Washington	X		X		Independent Scientific Review Board appointed by the Governor
Association of California Water Agencies		X			Scientific review and cost/benefit analysis	Federal Government
NW Power Planning Council	X				Independent Scientific Review Team appointed by NWPPC (Chair) and NMFS (Regional Director)	Council
National Association of Conservation Districts		X	X		Independent review from industry and university scientists on critical habitat	National Land and Conservation Fund. Listing petitioners if frivolous petition
American Public Power Association	X
Audubon, Greenpeace, National Wildlife Federation, Environmental Information Center (in joint communication)	X		X		Independent Scientific Review	Imply Federal Government
California Native Plant Society		X	X		Science Advisory Panel	Imply Government
Defenders of Wildlife	X		X		Call for scientific and community review
Environmental Protection Information Center			X
Forests Forever		Opposed
National Wildlife Federation			X
New Jersey Audubon			X			Applicant
NW Ecosystem Alliance			X		Critical Habitat
Natural Resource Defense Council			X		Independent Oversight Committee	Imply Government
SW Center for Biological Diversity	X				National Academy of Science Nominations	Federal taxes, permit fees, damages from E.S.A. lawsuits
Pacific Coast Federation of Fishermen’s Associations	X				Opposed to stake-holder representation
American Farm Bureau Federation	X	X	X
Farm Bureau	X
Fairy Shrimp Study Group (California businesses and farmers)		X
American Angus Association		X			National Academy of Sciences
Cattlemen’s Association		X
Cattlemen on the Hill		X		Critical Habitat	Blind panel, including natural resource user groups, states, and land grant colleges
American Sheep Industry Association		X				Local Government
National Association of Wheat Growers		X
California Women for Agriculture		X			Independent review
American Water Works Association	X
American Society of Civil Engineers	X
American Road and Transportation Builders Association	X
Inland Rivers, Ports, Terminals, Inc. BOD		X			Panel of scientific review
King County Navigation Bar			X		Independent Recovery
Building Owners and Managers Association		X	X		Scientists and affected community
International Council of Shopping Centers	X
Utah Association of Realtors	X
American Forest and Paper Association	X				Independent review cost benefit analysis
Pulp and Paperworkers Resource Council		X		Recovery
Boise Cascade Corporation		X			Scientific, economic and social review	Federal Government
NW Forest Resource Council	X		X		Double-blind peer review. Want affected party representation	Federal Government
Club 20	X				Independent cost/benefit analysis	Imply Federal Government
Family Business First		X
Family Business Fund		X
National Grange of the Order of Patrons of Husbandry	X	X
Multiple Grange, Forestry, Industry Associations	X				Public Input
National Endangered Species Act Coalition	X	X	X		National Academy of Sciences nominates scientists	Federal and State Government
James McClure to NESARC	X	X	X	Habitat Designations	Peer scientists and affected parties	Federal Government
National Wilderness Institute		X				Imply Federal Government
Cattle ranchers and environmental coalition in New Mexico	X				Scientific and public input
People for the USA!				Data
L.A. Times	X
National Jewish Community Relations Advisory Council	X	X			Scientific review	Federal Government
Church of the Brethren		Opposed
California Environmental Dialogue	X				Permanent program with standing committees	Government
Meridian Institute Workshop	X	X	X		Societies and services with database of experts	Services HCP applicants

SEI is a scientific organization dedicated to cooperative problem-solving

Prepared by Dr. Deborah M. Brosnan

President, Sustainable Ecosystems Institute

0605 SW Taylors Ferry Rd.

Portland, Oregon 97219

503-246-5008 www.sei.org

DEBORAH M. BROSNAN

Can Peer Review Help Resolve Natural Resource Conflicts?

Yes, but the system used must be far different from the traditional academic model.

Congress, businesses, environmental organizations, and religious groups are all calling for peer review systems to resolve conflicts over the protection of this nation's natural resources. A recent opinion poll found that 88 percent of Americans support the use of peer review in the application of the Endangered Species Act (ESA). The rising interest in peer review is the result of widespread unhappiness with natural resource policies, including ESA listing decisions and the establishment of ESA-sanctioned Habitat Conservation Plans (HCPs). The many interest groups believe that scientific peer review will support their particular viewpoints. The obvious problem is that they can't all be right.

A more important problem is that peer review as traditionally applied to examine scientific research is inadequate for supporting decisions about managing species, lands, and other natural resources. It does not take into account the complex political, social, and economic factors that must be factored into natural resource decisions.

Peer review can provide a basis for improving natural resource decisions, for reconsidering past decisions, and for settling disagreements. But to function effectively, the review system needs to be much different from the one used widely in academia today. In the meantime, traditional peer review is being applied on an ad hoc basis to important endangered species and habitat conservation issues, leading to contentious outcomes. In the rush to implement a popular policy, we are setting a precedent that is only institutionalizing our confusion.

Everyone wants it

It is heartening that all sides want independent peer review; it seems that everyone acknowledges that better decisionmaking is needed. A survey by the Sustainable Ecosystems Institute found that at least 60 farming, ranching, logging, industrial, ecological, wildlife, religious, and governors organizations are calling for scientific review in the application of the ESA. This includes reviews of HCPs, which are agreements between government agencies and private landowners that govern the degree to which those owners can develop, log, or farm land where endangered species live.

Why are so many diverse groups eager to embrace peer review? There is widespread distrust of the regulatory agencies involved in ESA and dissatisfaction with their administration of the act. Many groups believe that agencies are making the wrong decisions. Disagreements among interested parties often end up in litigation, where judges, not scientists, make rulings on scientific merit. Most decisions to list species in the West, including those involving the northern spotted owl, marbled murrelet, and bull trout, have been made after lawsuits. Similarly, one approved HCP--the Fort Morgan Paradise Joint Venture project in Alabama, which would have affected the endangered Alabama beach mouse--was successfully challenged in court on the basis of inadequate science.

Many organizations see science as a way of reducing litigation. After all, judges are not scientists or land managers and are apt to make the wrong technical decision. Court actions are costly. Any means of reducing vulnerability to lawsuits is roundly favored.

There are striking differences in opinion as to where peer review is needed. Simply put, each group favors review of actions that it finds unpalatable. Development groups want fewer species listings and therefore demand review of listing decisions. Some professional and environmental societies oppose peer review of listings because they will unnecessarily delay much-needed conservation measures. Environmental groups are concerned about habitat loss under HCPs and want them independently reviewed.

Regardless of their perspective, most groups want less litigation, less agency control, and greater objectivity. Many also see peer review as a tool for overturning wrong decisions. Regulatory agencies want to reduce vulnerability to litigation and develop greater public support. Agency staff, frequently doing a difficult task with inadequate resources, would prefer to have a strong system to rely on. It is always better to have a chance to do it right than to do it over.

The lure of hasty implementation

The move to implement some form of peer review is already under way. For example, the Magnuson Stevens Fisheries Conservation and Management Act calls for peer review in arbitrating disagreements over fisheries harvest levels. The U.S. Forest Service now calls for science consistency checks to review decisions about forest management. Unfortunately, the rush to implement random forms of peer review has created many ad hoc and ill-conceived methodologies.

Enthusiasm for peer review is so high that it is now central to efforts to reform ESA. In 1997, the Senate introduced the Endangered Species Recovery Act, which would have required peer review and designated the National Academy of Sciences (NAS) to oversee the review process. But few academy members or the scientists who serve on NAS committees have made their careers in applied science or have worked in an area in which legal and regulatory decisions are paramount. The bill was shot down, but the governors of the western states have asked the Senate to reintroduce similar legislation in 2000. Whether or not legislation is taken up, it is clear that Congress wants better science behind natural resource decisions and sees peer review as the way to achieve it.

Most legislative and agency measures calling for peer review, however, do not describe how it should be structured, other than to say that it should be carried out by independent scientists. Yet an ill-conceived review process will just compound the problems. Furthermore, there is a tacit assumption that the pure academic model will be used. Although it is appealing to think that this system would work as well for management and policy decisions as it does for pure research findings, it won't. Traditional peer review cannot be applied as some kind of quality control in a political arena. Indeed, some attempts to use peer review in this way have backfired.

What can go wrong

Development of the management plan for the Tongass National Forest, covering 17 million acres in Alaska, illustrates several problems in applying academic peer review to natural resource management. To make a more science- based decision regarding the management and protection of old-growth forests and associated wildlife species, the Forest Service set up an internal scientific review team that worked with forest managers on the plans. Because of federal laws governing the use of nonagency biologists, the service sent drafts to external reviewers, most of whom were academics. In reviewing the plan and the methodology, the service concluded that science had been effectively incorporated and that managers and scientists had worked well together. Indeed, service officials have portrayed the plan as a watershed event, bringing the service's research and management arms together.

The conclusion of the external review committee was different. It independently issued a statement that was critical of the management proposed in the plan, concluding that, in certain aspects, none of the proposed actions in the plan reflected the reviewers' comments. The committee insisted that "the Service must consider other alternatives that respond more directly to the consistent advice it has received from the scientific community before adopting a plan for the Tongass." The reviewers noted that there were specific management actions that should be carried out immediately to protect critical habitat but that were not part of the plan. These included eliminating road building in certain types of forest and adjusting the ratio of high-quality and low-quality trees that would be cut in order to protect old-growth forests.

The Tongass experience holds several lessons. First, internal and independent reviewers reached opposite conclusions; decisionmakers were left to determine which set of opinions to follow. Whatever the choice, a record of dissent has been established that increases vulnerability to legal challenge and political interference. Second, the independent scientists felt ignored, which again increases the vulnerability of the decisions. Third, the independent scientists made clear management recommendations, believing that science alone should drive management decisions; most managers will disagree with this point of view. Thus, peer review in the Tongass case raised new problems. Confusion of roles and objectives was a major cause of these difficulties.

Enthusiasm for peer review is so high that it is now central to efforts to reform the Endangered Species Act.

A different set of issues has arisen with the use of peer review in establishing two HCPs--one involving grasslands and butterflies in the San Bruno Mountains south of San Francisco, the other involving Pacific Lumber and old-growth forests near Redwood National Park. In both cases, scientific review panels were used from an early stage to guide interpretation of the science. The panels were advisory and scrupulously avoided management recommendations, sometimes to the frustration of decisionmakers. The panels avoided setting levels of acceptable risk and tended to use conservative scientific standards.

Another example comes from the State of Oregon Northwest Forest HCP, now being negotiated to cover 200,000 acres of second-growth forest that is home to spotted owls, murrelets, and salmon. The Oregon Department of Forestry sought reviews of their already-developed plan from 23 independent scientists representing a range of interest groups and expertise. Not surprisingly, diametrically opposed opinions were expressed on several issues. It will now be difficult to apply these reviews without further arbitration.

Hints of more endemic problems come from the Fish and Wildlife Service's use of peer review for listing decisions. Typically, a few reviewers are selected from a group of scientists who are "involved" in the issue. But the service now reports that at best only one in six scientists contacted even replies to the request that they be a reviewer. If they do volunteer, they are often late with their responses or don't respond at all. Two problems are becoming clear: There is no professional or monetary benefit from being a reviewer, and many scientists are wary of becoming caught up in politicized review processes, which can become drawn out and expose them to attacks by interest groups.

Certain actions can determine the effectiveness of a peer review process: how it is structured, who runs it, who the reviewers are, and how they are instructed and rewarded. Lack of attention to details and blanket application of an academic model has already led to problems and will continue to do so.

Clearing the minefield

Peer review has always been a closed system, confined to the scientific community, in which the recommendations of usually anonymous reviewers determine the fate of research proposals or manuscripts. When scientific review is used outside this arena, problems arise because scientists, policymakers, managers, advocacy groups, and the public lack a common culture and language. Few scientists are trained or experienced in how policymakers or managers understand or use science. Scientists may be tempted to comment on management decisions and indeed are often encouraged to do so. However, they are rarely qualified to make such pronouncements. Natural resource managers must make decisions based on many factors, of which science is just one. Inserting academic peer review into a management context creates a minefield that leads to everything from misunderstanding to disaster.

More appropriate applications of peer review can be designed once the major differences between academic and management science are understood. They involve:

Final decisions. Scientists are trained to be critical and cautious and to make only statements that are well supported. Managers must make decisions with whatever information is available. Scientists usually send incomplete work back for further study; managers typically cannot. Managers must also weigh legal concerns, public interest, economics, and other factors that may have little basis in hard data.

"Best available" science. Managers are instructed to use the best available science. Scientists may regard such data as incomplete or inadequate. Reviewers' statements that the evidence in hand does not meet normal scientific standards will be irrelevant to a decisionmaker who lacks alternatives and must by law make a decision.

Competing ideas. In pure science, two competing theories may be equally supported by data, and both may produce publishable work. Management needs to know which is best to apply to the issue in question.

Reviewers as advocates. In academia, it is assumed that a reviewer is impartial and sets aside any personal biases. In management situations, it is assumed that reviews solicited from environmental advocates or development interests will reflect those points of view.

A new model of peer review must account for the complex political, social, and economic factors involved in natural resource decisions.

Speed. Academic reviews are completed at a leisurely pace. This is not acceptable in management situations.

Anonymity and retaliation. Academic reviews are typically anonymous to encourage frankness and discourage professional retaliation. Reviews in management situations usually must be open to promote dialogue. Some scientists will be reluctant to make strong statements if they are subject to public scrutiny.

"Qualified" versus "independent." Often the scientists best qualified to be reviewers of a natural resource issue are already involved in it. Many HCP applicants, for example, do not want "inexperienced" reviewers from the professional societies. They prefer "experienced" scientists who understand the rationale and techniques of an HCP. This sets up a tension between demonstrable independence and depth of understanding.

Language. Managers and decisionmakers may not be familiar with the language of science. Statistical issues are particularly likely to cause confusion.

Reward structure. In academic science, reviews are performed free of charge for the common good and to add to scientific discourse. Hence they are typically given a low priority. In management situations, this will not work. Rewards--financial and otherwise--are necessary for timeliness and simply to encourage reviewers' interest in the first place.

A new model

The troublesome experiences in recent cases such as the Tongass and appreciation of the different roles of academic and management science reviewers point the way to more effective integration of peer review into resource management decisions. The following principles provide a starting point:

§ The goals of peer review in each case must be clearly stated.

§ Clear roles for reviewers must be spelled out.

§ Impartiality must be maintained to establish credibility.

§ A balance must be sought between independence and expertise of reviewers.

§ Training of reviewers may be necessary.

§ A reward structure must be specified.

§ Early involvement of scientists will give better results than will post-hoc evaluations.

Three other lessons are evident. First, because academic scientists are rarely familiar with management, the individual or organization coordinating the review needs to be experienced in both fields. The traditional sources of these "science managers"--academic institutions, professional societies, or regulatory agencies--either lack the necessary experience or are not seen as independent. We need a new system for administering peer review.

Second, a mediator or interpreter who clarifies roles and eliminates misunderstandings can be highly effective. Scientists may need pressing on some points and at other times may need to be dissuaded from trying to be managers. Conversely, managers who lack advanced training in disciplines such as statistics may need help in interpreting scientific statements on issues such as risk. The interpreter can also be a gatekeeper for scientific integrity, ensuring that reviewers do not become advocates, either voluntarily or under pressure.

Third, a panel structure gives more consistently useful results. This is probably the result of panelists discussing issues among themselves. Although panels can produce conflicting opinions, they appear more likely to give unequivocal results than would a set of individual reviews.

There is enthusiasm for science and peer review among most parties involved with ESA and general natural resource management. But there is little consensus on how to make the process succeed. Nationally, we lack the necessary infrastructure for implementing peer review as a useful tool. In each case, environmentalists, developers, and any other regulated parties should be asked to design the appropriate system, because they will then accept its results. This means that advice on forming such groups and oversight of their progress would be needed. Peer review cannot be guided by managers alone nor by scientists alone. We need independent technical groups that have the necessary diverse skills but are seen as impartial.

Whichever route is taken, a better approach to peer review must be created. The rush to impose the old academic model must stop before it creates even more problems. By taking the time to properly devise review systems, we can ensure that the scientific voice is effective, understood, and utilized.

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Deborah M. Brosnan is president of Sustainable Ecosystems Institute (www.sei.org) in Portland, Oregon, which attempts to bridge the gaps between science and policy through cooperation among environmental, business, agency, and scientific interests.

SUSTAINABLE ECOSYSTEMS INSTITUTE

PEER REVIEW SUCCESS: TABLE OF CASES

Case	Action	Agency	Peer Review Success			Comment Period	Contact Person
			Asked	Responded	Success
Alabama Sturgeon, Mobile River	Proposed Rule to List Species	USFWS Region 4	5	5	100%	7 months	Paul Hartfield U.S. Fish and Wildlife Service Jackson, Mississippi 39213 601/965-4900
Anadromous Atlantic Salmon in the Gulf of Maine	Proposed Rule to List Species	USFWS Region 5, NMFS Northeast Region	6	3	50%	5 months	Mary Colligan National Marine Fisheries Service Gloucester, MA 01930 (978/281-9116) or Paul Nickerson Fish and Wildlife Service Hadley, MA 01035 (413/253-8615).
Spectacled Eider, Alaska	Proposed Designation of Critical Habitat	USFWS Region 7	3	3	100%	7 months	Ann G. Rappoport U.S. Fish and Wildlife Service Anchorage, AK 99501 907/271-2787
Bay Checkerspot Butterfly, California	Proposed Designation of Critical Habitat	USFWS Region 1	4	3	75%	3 months	David Wright or Chris Nagano Sacramento Fish and Wildlife Office U.S. Fish and Wildlife Service Sacramento, California 95825 916/414-6600
Morro Shoulderband Snail, California	Proposed Designation of Critical Habitat	USFWS Region 1	3	2	67%	3 months	Diane K. Noda, Ventura Fish and Wildlife Office U.S. Fish and Wildlife Service Ventura, CA 93001 805/644-1766
Zayante Band-Winged Grasshopper, California	Proposed Designation of Critical Habitat	USFWS Region 1	3	2	67%	2 ½ months	Diane K. Noda, Ventura Fish and Wildlife Office U.S. Fish and Wildlife Service Ventura, CA 93001 805/644-1766
San Diego Fairy Shrimp, California	Proposed Designation of Critical Habitat	USFWS Region 1	4	2	50%	2 ½ months	Ken Berg Carlsbad Fish and Wildlife Office U.S. Fish and Wildlife Service Carlsbad, California 92008 760/431-9440
Spikedance and Loach Minnow, New Mexico	Proposed Designation of Critical Habitat	USFWS Region 2	4	2	50%	2 months	Jeffrey A. Humphrey U.S. Fish and Wildlife Service Phoenix, Arizona 85021 602/640-2720.
Tidewater Goby, California	Proposed Designation of Critical Habitat	USFWS Region 1	4	2	50%	4 months	Ken Berg Carlsbad Fish and Wildlife Office U.S. Fish and Wildlife Service Carlsbad, California 92008 760/431-9440
Arroyo Southwestern Toad, California	Proposed Designation of Critical Habitat	USFWS Region 1	5	2	40%	3 months	Diane K. Noda, Ventura Fish and Wildlife Office U.S. Fish and Wildlife Service Ventura, CA 93001 805/644-1766
California Red Legged Frog	Proposed Designation of Critical Habitat	USFWS Region 1	5	2	40%	3 months	Curt McCasland or Stephanie Brady Sacramento Fish and Wildlife Office U.S. Fish and Wildlife Service Sacramento, California 95825 916/414-6600
Alaska-Breeding Population of the Steller's Eider	Proposed Designation of Critical Habitat	USFWS Region 7	6	2	33%	6 months	Ted Swem Endangered Species Branch Northern Alaska Ecological Services Fairbanks, AK, 99701 907/456-0203
Mexican Spotted Owl, New Mexico	Proposed Designation of Critical Habitat	USFWS Region 2	7	2	29%	4 months	Joy Nicholopoulos New Mexico Ecological Services Field Office 505/346-2525
Zapata Bladderpod, Texas	Proposed Designation of Critical Habitat	USFWS Region 2	4	1	25%	4 months	Loretta Pressly Ecological Services Field Office Corpus Christi, Texas 78412 361-994-9005
Arkansas River Shiner	Proposed Designation of Critical Habitat	USFWS Region 4	9	0	0%	4 months	Ken Collins Oklahoma Ecological Services Office Tulsa, Oklahoma 74127-8909 918/581-7458
Peninsular Bighorn Sheep, California	Proposed Designation of Critical Habitat	USFWS Region 1	4	0	0%	3 months	Ken Berg Carlsbad Fish and Wildlife Office U.S. Fish and Wildlife Service Carlsbad, California 92008 760/431-9440
Coastal California Gnatcatcher	Proposed Designation of Critical Habitat	USFWS Region 1	4	0	0%	3 months	Douglas Krofta Carlsbad Fish and Wildlife Office U.S. Fish and Wildlife Service Carlsbad, California, 92008 760/431-9440
Columbia River Channel Deepening	ESA Section 7 Consultation	SEI for Port of Portland, NMFS, ACE, USFWS	7	7	100%	N/A	Dianne Perry Port of Portland Portland OR 503/944-7226
Interior Columbia River Basin Terrestrial Vertebrates, Pacific Northwest	Ecosystem Management Plan	SEI for USDA, Forest Service	3	3	100%	N/A	Martin Raphael, Forest Service Olympia, WA 98512 360/956-2345
San Bruno Habitat Conservation Plan, California	ESA Section 10 Consultation	SEI	2	2	100%	N/A	Roman Gankin San Bruno Habitat Conservation Plan Coordinator
Four California Spineflower Species	Critical Habitat Designation	SEI for USFWS Region 1	2	2	100%	N/A	Connie Rutherford Ventura Fish and Wildlife Office U.S. Fish and Wildlife Service Ventura, CA 93001 805/644-1766
Effects of Temperature on Salmonids of the Pacific Northwest	Literature Review	SEI	5	4	80%	N/A	Kathleen Sullivan Sustainable Ecosystems Institute Portland, OR 97219 503/246-5008

* ACE = US Army Corps of Engineers

NMFS = National Marine Fisheries Service

SEI = Sustainable Ecosystems Institute

USDA = US Department of Agriculture

USFWS = US Fish and Wildlife Service