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0016:J5 2002] THE lAST GREEN lAGOON 961 that the action would either jeopardize the species or adversely affect the species'. habitat, then the Secretroy of the Interior must suggest "reasonable and prudent alternatives" to the action that would avoid violating Section 7.350 One result of consultation could be a determination that only the release of additional flows will adequately protect the listed species .and their habitat. Such a result would be a smashing victory for the environmental organizations. But this is not the only possible, pr even the most likely outcome. Consultation would prompt a search for "reasonable and prudent alternatives" to protect the listed species.351 With respect to the listed species that are residents or transients of the Lower Colorado River region in the United States, alternatives might include habitat modification programs along the U.S. reach of the river. However, with respect to those species that are not found within the United States, the search for a reasonable and prudent alternative could prove extraordinarily difficult. particularly in an administration unhappy with the recent broad application of the ESA,352 the Secretary might very well propose alternatives short of invalidating the new Surplus Criteria. While the Secretary's rulipg would be subject to judicial review, "[s]cores of opinions establish the principle that courts are not to substitute their judgment for that of an agency in reviewing [Section. 7] decisions that involve substantial agency expertise. "353 Defenders of Wildlife may succeed in requiring agencies to satisfy the procedural step of consultation. However, it will probably fail to coerce a change in the Surplus Criteria. The suit also underlines other potential dangers associated with a forced approach under the ESA. While the ESA has proven to be a powerful tool for environmental protection in other contexts, the Act itself has come under increasing attack precisely because of its effectiveness in stopping environmentally harmful projects.354 When the economic and political pressures associated with a given. project have been sufficient, Congress has been willing to simply exempt a project from the ESA. A 350. See 16 D.S.C. ~ 1536(b)(3)(A) (1994). 351. Id 352. See Mitch Tobin, Bush Administration Believes Owl Habitat Victory to Lead to Law's Changes, ARIz. DAlLY STAR, Nov. 9, 2001, available at 2001 WL 30265472. 353. Mary Christina Wood, Reclaiming the Natural Rivers: 111e Endangered Species Act as Applied to Endangered River Ecosystems, 40 ARIz. L. REv. 197, 255 (199$). 354. See generally Frederico M. Cheever, An Introduction to the Prohibition Against Takings in Section 9 oj the Endangered Species Act of 1973: Learning to Uve with a Powerful Species Protection Law, 62 U. COLO. L. REv. 109 (1991).