Comment (6): Some commentators have considered a net-conservation profit standard to be inappropriate and ambiguous for pre-listing agreements. They stated that, given the successes already achieved under the current CCAA policy, the FWS should only streamline the CCAA process and improve the efficiency of CCAA approval instead of changing the standard. One commenter also stated that the changes are not necessary, given that the nature of the existing rules and guidelines already establishes principles of avoidance, minimization and/or reduction that achieve proven results. Several commentators recommended that the services withdraw the proposed rule and directive. To participate in a CCAA, non-federal landowners commit to implementing specific CCAA conservation measures on their lands that reduce or eliminate threats to the species covered by the agreement. An ESA authorization under section 10 (a) (1) (A) to improve survival is granted to the contract participant, which provides a certain degree of applause coverage when agreed conservation measures and routine land management measures (e.g. B agriculture, livestock or forestry) lead to the implementation of start printed page 95165take of the species covered, if any.