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434 J. G. Sidle Table 2. Number of endangered (E) and threatened (T) species in the United States and the number with critical habitat designations at the end of 1986. Number T/ Number F1 with CH with CH Total Mammals Birds Reptiles Amphibians Fishes Snails Clams Crustaceans Insects Plants Total 6/1 5/0 15/6 3/2 26/14 5/0 0/0 1/0 7/4 27/11 95/38 41/12 (29%) 79/9 (II %) 28/12 (43%) 8/3 (37%) 70/33 (47%) 8/0 24/0 5/1 (20%) 14/5 (36%) 143/22 (15%) 420/97 (23%) 35/11 74/9 13/6 5/1 44/19 3/0 24/0 4/1 7/1 116/11 325/59 location of the species, and is considering the taxon in its management and planning (50 Federal Register 33731). A similar reasoning was given for seven listed birds on Guam and US Pacific possessions (49 Federal Register 33881). The FWS stated that should any p0- tential adverse effects develop, the involved agencies could be informed by means other than a CHD. Nearly aU of the known habitat for the threatened Dismal Swamp southeastern shrew (Sorex lungirostris ft- shen) lies within the Great Dismal Swamp NWR. Be- cause of this land protection and continued refuge management strategies beneficial to the shrew, CHD would provide no additional benefits. Proposed CHD for the listed Key Largo woodrat (Neotoma floridana smalh) and the Key Largo cotton mouse (Peromyscus gossypinus allapaticola) was withdrawn, partly because there had occurred subsequent to listing public land acquisition of habitat and other land planning efforts for the species (51 Federal Register 5746). The above examples are recent reasonings for not designating CH. The new reasoning indicates that, if federal agencies are protecting the species, a CHD would not be beneficial to the species. On the other hand, if the FWS, for example, believes that there will be many federal projects in a listed species habitat, CHD may better inform federal agencies of species needs (Sheppard 1980). Section 7 of the ESA directs that all "federal agencies . . . utilize their authorities in furtherance of the purposes of this Act by carrying out programs for the conversation of endangered species and threat- ened species. . . ." It is diffICUlt to evaluate the level of federal agency lack of cooperation necessary in order to determine that CHD is beneficial. Final rules con- taining CHDs do not indicate why CHD is prudent 'and beneficial. The government must only indicate why a CHD is not prudent because the ESA requires CHD for each listed species. The grizzly bear is a threatened species that state and federal agencies are aware of and are trying to manage. There is an interagency grizzly bear study team, a recovery plan, several conservation programs, and numerous guidelines (Weaver 1985). Presumably, this means that a CHD is unnecessary. For years, how- ever, others have argued that CHD is necessary, claiming that the government has allowed political pressure and its own timidity to block CHD as exem- plified by the government's withdrawal of proposed grizzly CHD in 1976 (Craighead 1979, Craighead 1985). Other circumstances probably have contributed to forestalling other CHDs. Sheppard (1980) discusses the often negative perception that a CHD can en- gender, especially if private land is designated. CHD is often perceived by some as a taking without just com- pensation. Landowners sometimes fear that listing and CHD will result in the loss of their property or re- stricted use of that property. This is a continuing mis- understanding that needs to be addressed. Many pro- posed listings without CHD also have generated sub- stantial opposition. There is no CHD for some species because their habitat changes over a wide area. For the wood stork (Mycteria americana), changing hydrological conditions cause continuing changes in the bird's feeding and rookery areas. The black-capped vireo (Vireo atrica- frillus) occurs in scattered small areas and its habitat may vary over time due to plant succession. Listed fish species offer examples of the need for some CHDs. Although river-dwelling clams do not have CHD, many fish do. One reason, which could also be applied to clams, for fish CHDs is concern over disruptive activities in fish CH, especially those activi- ties in upstream segments of a watershed not included in the CHD that might impact a species and its CH further downstream. For example, 10 kIn of Citico Creek in Tennessee is the CHD for the smoky madtom (N oturus baileyi), and the fish apparently is re- stricted to this creek segment (49 Federal Register 39123). Potential threats to the species and its CH in- clude logging activities, road and bridge construction and maintenance, mineral exploration and mining, and other projects in the Citico Creek watershed, but far from the CHD. Besides keeping other federal agencies abreast of a species CH through memos, phone calls, and so on, there is another alternative to CHD. Instead of desig- nating CH, essential habitat has been identified in re- covery plans for some species without CHD. For ex-