• Executive Summary
• Introduction
• Recovery
• Regulatory Assurances to Landowners
• Public Participation
• Sound Science
• Prevention
• Ecosystem Planning
• Funding
• Members of the Task Force

Executive Summary

In 1983, Congress amended the Endangered Species Act (ESA) to allow states, local governments, and private landowners to apply for permits to take endangered and threatened species in the course of otherwise lawful land use activities. To obtain such a permit, an applicant must submit a Habitat Conservation Plan (HCP) that outlines activities an applicant will undertake to "minimize and mitigate" the impacts of the permitted take on the listed species covered by the permit.

Prior to 1992, fewer than a dozen HCPs had been approved by the Fish & Wildlife Service. Since then, more than 200 HCPs have been approved, and more than 200 are presently in development. Some of these plans cover more than 150,000 acres and many will last for up to 100 years.

Concerned by the proliferation and scope of Habitat Conservation Plans, as well as other types of agreements such as Safe Harbor and Candidate Conservation Agreements, the National Audubon Society formed a task force to examine the growing number of Habitat Conservation Plans and the policies that underlie the HCP program. This Task Force, made up of experienced Audubon chapter leaders, field staff, and national policy staff, met regularly for six months to review specific HCPs, the long term conservation implications of current HCP policies, and other issues related to the HCP program.

The Task Force focused on seven issue areas in its evaluation of the HCP program: 1) Recovery; 2) Regulatory Assurances to Landowners; 3) Public Participation; 4) Sound Science; 5) Prevention; 6) Ecosystem Planning; and 7) Funding.

The collective opinion of the Task Force is that the HCP program, as currently implemented, does not support the overall goals of the Endangered Species Act. However, the members of the Task Force believe that a number of improvements, outlined in this report, will help to ensure that HCPs support the conservation of declining birds, other wildlife, and their habitats.

In summary, the Task Force believes that HCPs should include: conservation measures that are consistent with the recovery of species covered by the permit; measures to prevent future listings of covered unlisted species; maximum public participation in their development and implementation; and the best available scientific information, with a commitment to gather more information and adjust management accordingly. The Task Force believes that "No Surprises" assurances should not be available for all plans, but rather only for plans that meet high standards for species conservation. Safe Harbor agreements must include more conservation safeguards than are currently required. And overall, all aspects of the HCP program, and related programs such as recovery planning, must receive more, and more consistent, funding.

Introduction

In 1983, Congress amended the Endangered Species Act (ESA) to allow a limited exception to its general prohibition on take of listed species on private or non-federal land. The ESA authorizes states, local governments, and private landowners to apply for an Incidental Take Permit for otherwise lawful activities that may harm listed species or their habitats. To obtain a permit an applicant must submit a Habitat Conservation Plan (HCP) that outlines activities that the applicant will undertake to "minimize and mitigate the impact of the permitted take on the listed species."

The first HCP, for San Bruno Mountain in Northern California, was approved in 1983. By 1992, only about a dozen Incidental Take Permits had been granted. According to the Fish and Wildlife Service, 211 Incidental Take Permits had been issued as of January 31, 1997, with another 200 permits/plans in various stages of development. Of those plans, approximately 25 exceed 10,000 acres, 25 exceed 100,000 acres, and 18 exceed 500,000 acres. These plans may last for forty years or more, and many contain a "No Surprises" provision that excuses the landowner from any obligation to pay for additional mitigation that may be necessary to insure a listed species' survival and recovery.

The National Audubon Society is concerned by the proliferation of Habitat Conservation Plans, particularly without an accompanying examination of their actual impact on species and their habitats. Other types of agreements such as Safe Harbors and Prelisting Conservation Agreements are also affecting large areas of the landscape and setting conservation practices for many years to come.

Earlier this year Audubon formed a task force to examine the growing number of Habitat Conservation Plans and the policies that underlie the HCP program. This task force, made up of experienced Audubon chapter leaders, field staff, and national ESA campaign staff met regularly for six months to review specific HCPs, the long term conservation implications of current HCP policies, and other issues related to the HCP program.

In developing our recommendations for improvements in HCP policies and procedures, the HCP Task Force reviewed the overall policies of the U.S. Fish and Wildlife Service (FWS) and National Marine Fisheries Service (NMFS), the positions taken by environmental organizations, scientists and scientific organizations, and industry representatives regarding HCPs, and the terms of individual HCPs. In addition, we drew upon our collective experience with individual HCPs and the overall HCP program.

The collective opinion of the group is that the HCP program, as currently formulated, does not support the overall goals of the Endangered Species Act. However, we believe that a number of improvements, outlined below, would help to ensure that HCPs support the conservation of declining birds, other wildlife, and their habitats.

Recovery

The standards for approval of HCPs do not require that a plan contribute to the recovery of listed species included in the underlying Incidental Take Permit. The ESA requires only that HCPs "minimize and mitigate" the impacts of permitted take of listed species. In addition, FWS and NMFS must ensure that the Incidental Take Permit and HCP are not likely to jeopardize the continued existence of the listed species or result in destruction or modification of its critical habitat. As HCPs grow larger and more widespread, significant portions of a single species' range may be subject to HCPs, thereby reducing its chances for recovery and delisting. For highly endemic species and species without recovery plans (about 40 percent of those listed), HCPs may become de facto recovery plans.

In light of the low approval standards now in place for HCPs, the HCP Task Force recommends the following changes and safeguards:

• HCPs should not be permitted until a recovery plan is in place; however, a regional ecosystem-level plan that complies with the criteria set forth in Section VI, below, may go forward without recovery plans for all listed species. If a species has a draft recovery plan, HCPs could be developed for a percentage of existing habitat--perhaps five to ten percent. This will encourage landowners to support funding and development of recovery plans.
• An HCP should not substitute for a recovery plan or for the designation of critical habitat for a species. Recovery plans should include biological criteria for use in HCPs, and should include an assessment of potential plans within a species' critical habitat and their potential cumulative impact on the species.
• HCPs should be required to contribute to recovery objectives in existing recovery plans.
• HCPs should include species-specific criteria for measuring biological success, habitat benchmarks, and timelines for target species to meet particular goals to ensure that individual species are moving towards recovery. Such plans should also include a scientifically justified baseline for all listed species to ensure their progress towards recovery.
• HCP should be as specific as possible in describing the types of activities to be permitted, and regional multi-species plans that include municipal governments as parties should include a decisionmaking process to ensure that the impact of future, as yet unplanned, activities are consistent with the recovery of listed species and the conservation of unlisted species covered by the plan.
• The Services must assess the cumulative effects of HCPs on an individual listed species' recovery, and must ensure against cumulative deleterious effects from incremental habitat losses. In assessing the components of a plan, an agency should assume the worst case scenario for risky or unproved components of the plan, and should approve, disapprove, or modify the plan accordingly.

Regulatory Assurances to Landowners

A. Safe Harbor Agreements

Under a Safe Harbor Agreement, a landowner is encouraged to maintain and/or modify habitat in order to attract endangered or threatened species to his or her property, but may abandon the modifications and develop the property upon termination of the agreement without penalty. If the property has a baseline population of a listed species, the landowner is required to maintain that population following termination of the agreement. Although we are generally supportive of the concept of Safe Harbor agreements, the HCP Task Force recommends that the following safeguards be added to the Safe Harbor program:

• The Safe Harbor program must establish a scientifically credible process for determining the baseline population of enrolled property. The baseline must be based on reliable survey techniques and scientific interpretation. Uncertainties must be resolved in favor of the species and greater protection.
• At the termination of a Safe Harbor agreement, a landowner wishing to develop or otherwise destroy habitat may do so unless to do so would jeopardize the survival or recovery of a listed species.
• If it can be shown that a landowner has acted to reduce his baseline population of a species prior to applying for a Safe Harbor agreement, the landowner should not be eligible to participate in the program.
• Criteria must be established to ensure that Safe Harbor is appropriate for a particular species and its habitat needs. Species vary widely in their ability to move from one habitat area to another and Safe Harbors may not be appropriate for species with highly specialized habitat needs or for endemic species with restricted ranges.
• Rules for participating landowners should ensure that as properties drop out of the program, equivalent new properties are added. In the current program, the amount of habitat enrolled is not guaranteed, nor is its replacement assured if a landowner decides to drop out of the program.
• Safe Harbor agreements should not be permitted in conjunction with an Incidental Take Permit. We strongly believe that Safe Harbor agreements are a reward for doing more than is required by the Act: landowners should not be permitted to reduce their baseline population of a species and then provide only temporary habitat for new individuals attracted to their property.
• Criteria should be added to ensure that land subject to Safe Harbor agreements does not become a "biological sink" for listed species. The "biological sink" problem is as follows: a landowner creates habitat for a listed species; the species is attracted to the temporary new habitat and abandons old habitat; the old habitat, now unoccupied, is developed; and then the Safe Harbor habitat is developed, leaving the species worse off than before.
• Safe Harbor should be maintained as a separate program and not used in conjunction with other successful habitat conservation/restoration programs such as Partners for Wildlife and the Conservation Reserve Program. These programs are extremely popular with landowners in most parts of the country without the added incentive of a Safe Harbor agreement. These programs are working without any guarantees regarding ESA enforcement, and are providing benefits to other, unlisted, wildlife that should not be lost through linkage with the Safe Harbors program.

B. No Surprises

On August 11, 1994 Secretary of Interior Bruce Babbitt issued a joint FWS/NMFS "No Surprises" policy, without opportunity for public comment. Under this policy a landowner participating in an HCP is assured that no additional land use restrictions or financial obligations will be required for species covered by a properly functioning HCP except under extraordinary circumstances. The policy further assures a permit holder that the primary responsibility for dealing with those extraordinary circumstances rests with the federal government -- the permit holder will not be required to commit additional land or funding or submit to further restrictions on development.

The HCP Task Force believes that the "No Surprises" policy does not reflect ecological reality and that this policy rejects the best scientific knowledge and judgment of our era. Every ecosystem of which we are aware changes over time: in species composition and abundance, in structural complexity, in nutrient dynamics, in genetic composition and virtually every other parameter we could choose to study and measure. The very name "No Surprises" is misleading--the natural world is full of surprises. The policy should be renamed; we concur with the recent suggestion of a group of seven nationally recognized conservation scientists in a meeting at Stanford University that it be renamed the "Fair Assurances" policy.

HCPs are inevitably developed and authorized under conditions of substantial uncertainty and may ultimately prove inadequate to conserve threatened and endangered species. Unless HCPs can be amended and improved when necessary, habitat and species will not be protected or recovered to sustainable population levels as required by the Endangered Species Act. Despite these realities, we also believe that the public at large should bear some of the costs of necessary revisions to HCPs. As a policy matter, the recovery goals of the ESA should not be met solely through mitigation agreements with private parties who have in good faith agreed to, and complied with, the terms of a habitat conservation plan.

We do not support the current formulation and application of the "No Surprises" policy. Without funding, better monitoring requirements, better science, and goals that are consistent with a species' recovery, plans should not include such blanket future assurances to landowners. Without the following changes, the HCP Task Force does not support the "No Surprises" policy:

• There must be an adequate, assured funding source to cover the costs of rectifying a failed HCP that includes contributions from the landowner and is not subject to the vagaries of the Congressional appropriations process. Section VII includes several suggested mechanisms for achieving this goal.
• HCPs with "No Surprises" assurances must contain long-term biological monitoring provisions for all species covered by the plan and a system for reporting on plan progress. New scientific information derived from the monitoring program must be incorporated into an adaptive management strategy which may necessitate changes to the terms and conditions of the HCP. "No Surprises" should not mean no responsibility.
• "No Surprises" should not be an automatic element of an HCP. Regulatory assurances should be a reward for a plan that makes a solid contribution to protection of listed species and to preventing further decline of unlisted species.
• The strength of "No Surprises" assurances should vary according to the levels of protection afforded under the plan, the plan's contribution towards a species' recovery, and the length of the plan (longer plans should get lower levels of assurances).
• "No Surprises" assurances should only be extended to those listed species for which the plan articulates species-specific conservation goals that will further recovery of the species in a regional or ecosystem context, rather than in a local, piece-meal fashion.
• If unlisted species are to be included in a plan's "No Surprises" assurances, the plan should be based on the best data available on that species and the landowner must commit to gather more data and adapt his or her plan in light of this new data and in light of new scientific knowledge. The plan should confer a clear benefit on an unlisted species if it is to be subject to "No Surprises."
• HCPs, particularly the increasing number that cover significant acreage, will impact wildlife, water, and other public trust resources for many years to come. Independent scientific experts and the interested public must be given maximum opportunity to participate in the development of an HCP if it is to include long-term "No Surprises" assurances.

Public Participation

In contrast with many other provisions of the Endangered Species Act, the process of developing an HCP is primarily conducted away from the public eye, with a limited opportunity for public comment given at the end of the developmental process. Whether the applicant is a public entity, such as a county or city government, or a private landowner, the ESA requires little public participation in the development of an HCP. Applicants proposing large, complex HCPs also must comply with the requirements of the National Environmental Policy Act (NEPA), which mandates some public participation and accountability. Joint FWS/NMFS policy "encourages" applicants to allow greater levels of participation in the development of a plan. And when a permit applicant is a public entity, often greater public access is required by state or local law.

The current system lacks both predictability--levels of participation vary greatly from one plan to another--and accountability to citizens interested in the protection of wildlife. The HCP Task Force believes that the following changes would greatly improve public accountability of, and public support for, individual HCPs and the overall HCP program.

• All applicants should be required to hold or allow regular public briefings regarding a developing HCP. These briefings should begin as soon as permit and plan negotiations and consultations with FWS or NMFS begin.
• Citizens should be encouraged to submit suggestions for plan development to FWS or NMFS. These suggestions should be part of the permanent record for the HCP and included in any final NEPA document. The Services should be required to respond in a substantive manner to comments and suggestions made by citizens.
• HCPs should contain clear, enforceable standards for the conservation of covered species, and interested citizens should be able to bring a lawsuit for the enforcement of these terms.
• Private Incidental Take Permit applicants should be given some incentive to allow greater public participation (including steering committees and working groups). Incentives could include: financial assistance for HCP planning; expedited plan review and approval; or a loss or reduction of "No Surprises" eligibility.
• Applicants for Incidental Take Permits must be required to allow maximum participation in plan development by independent scientific experts and the interested public if they wish to receive long-term regulatory assurances.
• The ESA or Service regulations should require that notice of permit applications be mailed to members of the public who have previously indicated an interest in permit issuance. The Federal Register is not easily available to many interested groups and individuals: lack of knowledge hampers the ability of interested citizens to participate in habitat conservation planning. A possible model is the approach of the Army Corps of Engineers: local Corps offices will send notification of pending Clean Water Act permits within a limited area to interested citizens.
• FWS and NMFS should be required or encouraged to maintain an online database of permit documents. The Services could easily require that applicants submit HCP documents on computer disk for inclusion in this database. Currently interested citizens often have difficulty obtaining copies of permit application documents, and copying costs may be prohibitively expensive. In addition, we support the trend towards combining documents such as the EIS and HCP to reduce the volume of information that the public must review.
• The National Environmental Policy Act must continue to apply to permit applications. Under current law, NEPA provides a significant opportunity for public participation in HCP development which must not be abandoned or limited. The Services have recently acted to exempt "low-effect" HCPs from NEPA review and to require only environmental assessments for most HCPs. We are concerned that these new regulations may undermine the broad policy goals of NEPA and urge that the Services apply them only in the narrowest of circumstances.
• Applicants for Incidental Take Permits that will entail large scale regional planning processes, must be required to allow maximum participation by the interested public, perhaps patterned after the stakeholder process that led to the San Diego Multispecies Conservation Plan.

Sound Science

The hallmark of the ESA is its emphasis on science as the basis for listing decisions and other actions to conserve species and their habitats. However, a disturbing number of HCPs are based upon questionable or risky scientific assumptions. In some cases, the planning process has ignored or dismissed the recommendations of scientific panels. And in nearly all cases, there has been little to no independent scientific evaluation of HCPs.

A group of nine nationally-recognized conservation scientists recently met at Stanford University and issued a white paper discussing some of the trends in conservation of listed and declining species ("Stanford White Paper"). The scientists noted that "many recent HCPs have been developed without adequate scientific guidance and there is growing criticism from the scientific community that HCPs have the potential to become habitat give-aways that contribute to, rather than alleviate, threats to listed species and their habitats."

Accordingly, the HCP Task Force recommends the following to improve the scientific basis for HCPs:

• The Services should develop a set of minimum level biological criteria for all HCPs. These criteria should be developed by a neutral scientific body with solid credentials.
• The Biological Resources Division of the U.S. Geological Survey and the National Academy of Sciences should be encouraged to fund basic ecosystem and species research for use in HCPs.
• HCPs must contain measurable criteria for biological success, and a method for demonstrating that the plan is working as designed for all covered species.
• At the outset, plans must examine baseline species data for the planning area in a regional context.
• We support a process for peer review of HCPs by independent, individual scientific experts to give these plans greater credibility and increase their chances for success. Peer review should be conducted according to the rules developed by the National Academy of Sciences, and participants should receive compensation from a fund set up by the government--not from the permit applicant. Potential reviewers should be drawn from a reliable database that includes experts on a variety of ecosystems and specific species.
• The conservation community and the Services need to encourage greater involvement of scientific experts, particularly academic scientists, in HCPs.
• The HCP development process must provide a role for scientific experts employed by environmental organizations, community groups, and other stakeholder organizations, and provide better access to scientific information to these scientists and to stakeholder groups.
• Each plan must include a monitoring strategy that is consistent with other strategies for the species (such as its recovery plan or other conservation agreements). At minimum, monitoring and adaptive management strategies must be founded in baseline standards and not used to defer critical decision-making that may lead to irreversible decisions.
• Plans should not be permitted to substitute species research for real conservation and mitigation of impacts.

Prevention

The trend among HCPs is towards large-scale, multi-species plans that cover both listed and unlisted species or even entire ecosystems. In addition to the growing number of HCPs that include unlisted species, FWS has recently announced its intention to begin offering the option of candidate conservation agreements to private landowners--previously these agreements were only available to other federal agencies and to state or local governments. As the trend towards inclusion of unlisted, declining species in conservation plans continues, more and more habitat for these declining species will be included in these plans. This trend provides an opportunity to work with non-federal landowners to halt the decline of species and prevent future listings, but also poses a threat to these species, as the conservation standards and biological basis for inclusion of unlisted species in many current plans is not high. Also, the application of "No Surprises" assurances to unlisted species, particularly where biological information is lacking, may undermine efforts to conserve a species if it is eventually listed under the ESA.

The Stanford White Paper made the following recommendation: "Because prelisting agreements should benefit species, we recommend an enhanced level of attention and critical review of the biological circumstances under consideration in proposed prelisting agreements." This argument applies equally to unlisted species included in HCPs.

We make the following recommendations for improvements in HCPs and other conservation plans to ensure that they become a tool for preventing the further decline of unlisted species:

• Planners should use the best data available on unlisted species, and the landowner must commit to gather more data on unlisted species and adjust management of the covered land accordingly if these species are to be included in a plan's covered species list and be subject to "No Surprises" assurances.
• HCPs must show a clear benefit to an unlisted species, not merely a mitigation of impacts, if the species is included in the covered species list and is subject to "No Surprises" assurances.
• HCPs and other prelisting arrangements should not be used as a substitute for listing. If listing is biologically warranted, then the species should be listed.
• The Biological Resources Division of the U.S. Geological Survey should renew its commitment to ecosystem inventory and mapping to gather data needed in tracking declining species and developing HCPs that will prevent their listing.

Ecosystem Planning

The trend among HCPs is away from small-scale single species plans and towards larger, landscape level plans that cover multiple species across large sections of an imperiled ecosystem. We agree that this approach holds promise, and that what is needed to save listed species and prevent future listings is to conserve large contiguous tracts of land that are representative of entire ecosystems. However, we believe that certain safeguards are needed until we are certain that scientific knowledge has reached a higher level of certainty regarding these methods. In addition to the safeguards that we believe should be in place for all HCPs, large ecosystem-level plans should include the following:

• Large ecosystem-level plans should begin with a written and binding agreement among the parties that sets forth a process for planning the HCP. Planning agreements should identify the ecosystems and species to be included in the plan and set science-based goals for the plan that will further the conservation of these species and ecosystems. The planning agreement should also establish a process for gathering data on included species and ecosystems, particularly from independent sources, and a process for the participation of the public.
• To ensure that plans are working towards ecosystem level planning, HCPs must examine cumulative impacts of their terms on a regional level. Planners should consider how an HCP fits into its regional biological context. For example, plans analyze the cumulative impacts of proposed measures on migratory or wide-ranging species, soil quality, and regional watersheds.
• The size of the area included in the plan must be appropriate to the planning effort and the species covered. For endemic species with restricted ranges the HCP should ideally cover the entire range of the species. For more widely distributed species, the larger area the better, depending on the objectives of the HCP. If the HCP applies to only part of a population -- such as a cluster of nesting territories -- the area should be large enough to accommodate a viable source population to colonize other areas.
• Plans should consider the impact of HCPs on adjacent or nearby public lands as part of an ecosystem planning process. Nearby protected areas should not reduce the amount of protection that an HCP must afford to a species or an ecosystem. Species or ecosystems included in protected areas should continue to receive high levels of protection. In addition, a plan's reliance on a nearby protected area as a part of its reserve design, or for certain types of species habitat not provided by land subject to an HCP, must be justified. We are greatly concerned by several recent regional plans that include proposed protected areas whose future funding is uncertain as a component of their reserve for covered species.
• HCPs should not provide a means to circumvent or change the requirements of other land use and environmental laws. Planners must consult with other state, local, and federal agencies regarding the application of laws under their jurisdictions to the activities proposed under an HCP. If a proposed activity may violate, for example, the Clean Water Act, it must be modified or disallowed.
• The use of indicator species may be helpful in developing and implementing ecosystem-level plans. However, planning and conservation measures to protect indicator species should not substitute for species-specific planning for endangered, threatened, and candidate species.

Funding

Historic underfunding has prevented the full implementation of the Endangered Species Act, including the Habitat Conservation Plan program. Since 1994, the number of HCPs has grown from fewer than 20 to more than 200--a tenfold increase. In the same time period, the budget line that includes HCP development, monitoring, and enforcement has multiplied by only three and half times. FWS and NMFS lack necessary funding for recovery planning, monitoring, enforcement, public participation, land acquisition, and modifications to plans due to "No Surprises" assurances associated with the HCP program.

• Congress must ensure a secure source of funding for recovery planning. This is particularly important if, as we recommend, HCPs are linked to recovery plans.
• Both federal and state governments should fund basic biological research on declining species.
• We recommend the creation of a dedicated fund, made up of contributions from permit applicants and state, local, and federal governments, to pay scientific consultants on individual HCPs. This will remove an inherent conflict of interest that occurs when scientific consultants are paid for by an applicant alone and will help to ensure better plans.
• To pay for "unforeseen circumstances" under plans with "No Surprises" assurances, we recommend the creation of an insurance fund. This fund would be made up of Congressional appropriations and payments from landowners with "No Surprises" guarantees based upon the level of biological risk associated with their particular HCP.
• Alternatively, we support a bonding requirement for HCPs with "No Surprises" assurances. A landowner would purchase a bond to guard against the expense of unforeseen circumstances. This would encourage less risky plans both to reduce the initial cost of the bond, and to help ensure that the bond amount would eventually be paid back to the landowner if unused.
• We also support the requirement of a performance bond for HCPs to ensure that the terms of the original agreement are fully carried out. Such bonds are commonly used for environmental permits and would be appropriate here.
• We recommend that the fee for an HCP application be increased from its current level of $25 for all plans to more accurately reflect the level of complexity and risk of individual plans.
• For regional, government-sponsored plans, we support the use of development assessments and bonds to pay for plan implementation.
• In general, we support full annual appropriations from the Land and Water Conservation Fund to purchase key endangered and threatened species habitat independent of HCPs. We also support the use of LWCF funds to support the purchase of land as part of the reserve design for large regional plans.

Members of the National Audubon Society Task Force on Habitat Conservation Plans

• Craig Breon, Santa Clara Valley Audubon Society, California
• Tim Cullinan, National Audubon Society Washington State Office, Washington
• Pete DeSimone, National Audubon Society, Starr Ranch Sanctuary, California
• Paul Engelmeyer, National Audubon Society, Ten Mile Creek Sanctuary, Oregon
• Doris Falkenheiner, Baton Rouge Audubon Society, Louisiana
• Bryan Hale, Travis County Audubon Society, Texas
• John Kelley, Travis County Audubon Society, Texas
• Paul Ketchum, Portland Audubon Society, Oregon
• Jane Lareau, Charleston Natural History Society, South Carolina
• Chuck Lennox, Seattle Audubon Society, Washington
• John McCaull, National Audubon Society California Office, California
• Karen Messer, Buena Vista Audubon Society, California
• Mary Minette, National Audubon Society, Washington, D.C.
• Robert Reid, Birmingham Audubon Society, Alabama
• Kathleen Rogers, National Audubon Society, Washington, D.C.
• Anne Schnapf, National Audubon Society, Coastal Islands Sanctuary, Florida
• Ron Shultz, National Audubon Society Washington State Office, Washington
• Todd Tucci, National Audubon Society, Washington, D.C.