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FRAYED SAFETY NET S ".".,........,................,..,.....,...,.......................,..,..,..,.".....................,.....,....,.,..................................".,',..,."..,..., conservation plans that the wildlife agencies (DFG and FWS) deem adequate for issuance of incidental-take permits. The NCCP is intended to take a multispecies, multi-habitat approach. Planning areas are delineated by ecosystem boundaries rather than landowner or county boundaries. This approach relieves FWS of hav- ing to help develop and approve HCPs project by project and species by species and seeks to give local governments and the state wildlife agency (DFG) an official role in ESA-related conservation planning. Currently the NCCPis limited to a pilot pro- gram in southern California that embraces five counties: San Diego, Orange, Riverside, Los Angeles and San Bernardino. The program can be visualized as a giant jigsaw puzzle, in which the entire planning area encompasses the remaining coastal sage scrub habitat - 6,000 square miles stretching from Los Angeles and San Bernardino Counties to the Mexican border. This puzzle is broken into 11 pieces labeled subregions, each with its own Natural Communities Conservation Plan. The Multiple Species Conservation Program (MSCP) for southwestern San Diego County, assessed in this report, is one of those 11 pieces. Each subregion (including the MSCP) is divided into smaller subareas to facilitate planning. The NCCP is a habitat-based approach to conservation planning. The Habitat Conservation Planning Handbook (p 3-38) declares: "The rationale for a habitat-based approach is that if certain habitat-types are scientifically selected and assessed, and adequately protected under the terms of the HCP, the HCP could protect a broader range of species than the few 'target' species that might otherwise be addressed by a conventional HCP." Other ESA-related programs also seek to use large-scale planning to address ecosystem-level concerns. For example, for the Louisiana black bear (Ursus americanus LuteoLus), landowners, wildlife biologists and conservationists have developed recovery strategies and priorities focused on identifying remaining bottomland hardwood forests and employing management techniques to enhance habitat and develop corri- dors for bear movement. Concerns About Ecosystem Planning The ecosystem-based approach to conserva- tion gives momentum to fulfilling the ESA's origi- nal purpose - to protect ecosystems and recover imperiled species that depend on those ecosystems (patlis 1996). The ecosystem approach addresses potential cumulative effects, habitat fragmentation and multiple species. Many hold the NCCP up as the model for endangered species management, but it has potential flaws. For the NCCP, funding may be insufficient for plan implementation and preserve acquisition, and some individual plans have been developed with insufficient indepen- dent scientific oversight (NRDC 1997). In addi- tion, such plans are used frequently as an excuse not to list species that become imperiled despite NCCP implementation. e ....................................................................................................................................................................................................... ..........................