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between the baseline and recovery scenarios. The Act draws a distinction between economic impacts arising from the listing of the endangered species and those arising from the designation of critical habitat. Only the latter are to be considered in the fmal determination of the critical habitat. After critical habitat is proposed, and an economic analysis is conducted, an exclusion process is conducted in which the economic impacts of designating critical habitat are evaluated. The Act directs the Secretary of the Interior to consider economic and other relevant impacts based upon biological and economic findings in determining whether to exclude proposed areas from the designated critical habitat,. In this process, the USFWS may exclude areas from critical habitat designation when the benefits (economic impacts avoided) of such exclusion outweigh the benefits (species preservation) of specifying the such area as part of the critical habitat. In many cases it is difficult to distinguish between economic impacts attributable to listing a species as threatened or endangered and the economic impacts associated with designating critical habitat for that species. Technically, listing impacts are those associated with protecting individual members of a species from harm, while critical habitat impacts are those associated with protecting the species' habitat from harm. A plan to drain a pond filled with endangered fish, however, would harm both individual species members and their habitat, thus posing the dilemma of how to allocate the impacts of not draining the pond to listing versus critical habitat designation. Because it is difficult to separate the impacts of listing from the impacts of critical habitat designation, the standard approach is to estimate the combined impacts of both and then judgmentally allocate a proportion of total impacts to each cause. 15 The rationale for the allocation method used in the Colorado River and Virgin River studies revolves around the 15 This approach was used in the critical habitat study for the northern spotted owl (Schamberger et al. 1992), and to our knowledge all critical habitat studies that have taken place since then. 23