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be done by committee members. Therefore, it appears that a large number of exemption applications would be highly disruptive. Moreover, the entire endangered species process can potentially cause significant delays, even though Congress did place time limits on each step. Adding up the time limits given in the Amendments shows that the time of in- ception of a project to the rendering of the biological opinion could take up to 9 months. If an exemption is applied for, it would take an additional year. Thus, almost 2 years must pass before there can be an "irreversible commitment of resources." This means that little work can be done on the project until after the endangered species problem is resolved. For several reasons the actual delay could be greater than these 21 months. First, of course, 1S the possibility of judicial review. Second, in the legislation fixing these time limits there is no "or else," and therefore no sanction for missing a deadline. Many deadlines in other federal legisla- tion are routinely missed by operating agencies. Third, the applicant is financially responsible for the mitigation or enhancement measures that the Coonnittee may require, and the Coonnittee must have assurances that the funds are available and that such measures will be completed before the exemption can be granted. For federal agencies with development responsibility, this means that the funds for mitigation and enhancement measures must be authorized and appropriated by Congress. Of possibly greater significance than the exemption process were changes made concerning the listing of species. First, where practicable, a critical habitat must be designated at the same time a new species is listed. For foreign speC1es, obviously, this is not practicable, but the Congress clearly intended the great majority of domestic species to fall under this requirement. The failure to designate critical habitat must be justified when the regulation is proposed. Second, in designating critical habitat, the Secretary must con- sider economic impact, and he must apply a benefit-cost test to any area unless he determines that its exclusion from critical habitat will result in the extinction of the species. Third, the Amendments limit to 2 years the time between proposal and promulgation of a regulation to list a new species. If no regulation is promulgated within this period, the proposal must be with- drawn, not to be reproposed unless new information is available. Fourth, a review of the status of all listed species is required every 5 years. Finally, 20