Context: Growing scientific recognition of the role of private lands for endangered species recovery and the landmark 1981 court decision in Palila v. Hawaii Department of Land and Natural Resources both contributed to making Habitat Conservation Plans/ Incidental Take Permits "a major force for wildlife conservation and a major headache to the development community", wrote Robert D.Thornton in the 1991 Environmental Law article, Searching for Consensus and Predictability: Habitat Conservation Planning under the Endangered Species Act of 1973.

Question: What 1981 court decision added to the power of HCPs and ITPs for conservation?
Answer: Palila v. Hawaii Department of Land and Natural Resources

Question: Who wrote the article "Searching for Consensus and Predictability: Habitat Conservation Planning under the Endangered Species Act of 1973."
Answer: Robert D.Thornton

Question: What did Thornton compare the scientific and legal advances to, from the viewpoint of the development community?
Answer: a major headache

Question: When did private lands start to have more recognition?
Answer: Unanswerable

Question: Who ruled on the Palila v. Hawaii Department of Land and Natural Resources?
Answer: Unanswerable

Question: What did Thornton say the role of private lands was like for the development community?
Answer: Unanswerable

Question: When was the Environmental Law magazine started?
Answer: Unanswerable

Question: What case limited ITP power?
Answer: Unanswerable