In May 1997 Environment International, a peer-reviewed scientific journal, published a study detailing the errors and omissions in the design and implementation of the Endangered Species Act. The study is a compilation of discoveries based on review of thousands of pages of government documents and creating a data base with more than 200,000 points of information to draw conclusions that:

• Numerous species were incorrectly listed as threatened or endangered;
• No species has ever recovered primarily as a result of the ESA;
• Most species claims by the US Fish and Wildlife Service to have achieved 75 percent of their recovery objectives are not recipients of beneficial actions under the act;
• Government data is too poor to demonstrate a general trend for protected species;
• There is no scientific rationale for the allocation of funds among species.

Rob Gordon, James Streeter, and James Lacy of the National Wilderness Institute conducted a year-long review of government reports to paint a depressing picture of the country's leading environmental law. They looked at reports of the FWS and the National Marine Fisheries Services, species recovery plans, Federal Register notices for listing, reclassifying, and delisting species, and other sources.

The men determined that "numerous species have been incorrectly diagnosed as endangered or threatened with extinction." They said that the process for listing species is based on subjective criteria rather than scientific evidence, which amounts to a 'leap before looking' policy with serious scientific, economic, political, social, and conservation consequences.

The report maintains that no recoveries have been made primarily because of ESA management and that alligators, one of the notorious "successes" of the ESA were never endangered at all; that the brown pelican probably should not have been listed; and that the gray whale and Arctic peregrine falcon would have recovered without the ESA. When a species is removed from the list because of data error, the reason given may be "additional discoveries" or "better data," but such qualifying phrases are not used to describe recoveries or reclassifications of species. "Terms such as 'recovered through captive breeding,' 'recovery attributable to DNA ban,' or 'extinct by hybridization' would have used the same logic as that used to describe 'data error,' but such terms would cast doubt on the Endangered Species Act efficacy," according to the executive summary of the study.