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F RAY E 0 SA F E T Y NET S .........................................................................................................................................................................., approved conservation plan subsequently is listed pursuant to the Act, no furthet mitigation requirements should be imposed if the conserva- tion plan addressed the conservation of the species and its habitat as if the species were listed pursuant to the Act." (H.R. Report No. 97-835, 97th Congress, Second Session, and 50 FR 39681-39691; italics added). Although the FWS made this point even more clear in the Habitat Conservation Planning Handbook (FWS and NMFS, 1996; Chapter 4), this standard is extremely difficult to meet for unlisted species, because there is almost always much less known about unlisted species. One way of attempting to deal with multiple species is through a "habitat-based" HCP. The NCCP program (see introduction) takes this approach, whereby species are grouped according to the habitat communities they require, and landowners infer that there is adequate protec- tion for each species through protection for each habitat type. We discuss this approach as exem- plified in the MSCP later. This attempt to broaden HCPs and other conservation plans to benefit multiple species is frustrated by two important factors. First, legally, HCPs and other plans are part of the ESA, which imposes legal responsibilities regarding individual species (Rohlf 1991). Indeed, it is extremely dif- ficult to define habitats and ecosystems precisely so that they can be legally protected (Orians 1993). Second, from a scientific perspective, pre- dicting and monitoring the effects of manage- ment actions on communities and ecosystems is much more difficult than for individual species. Merely protecting certain habitat types in a con- figuration appropriate for one species does not guarantee adequate protection for multiple species. Perhaps the best way of addressing this dilemma is to determine scientifically what endangered, indicator or keystone species exist in a system and to monitor those species (Murphy et al. 1997 - see Appendix B). To date, however, it has been extremely difficult to define and iden- tifY true indicator and keystone species (Landres et al. 1988; Mills et al. 1993; Power et al. 1996). In addition, target species are typically vertebrate species, which are generally poor indicator species (Landres et al. 1988). San Bruno's Conservative Approach The San Bruno Mountain HCP contains a good strategy for addressing multiple species because there were surveys for other sensitive species, there were an assessment and protection of potential habitat for those sensitive species in the planning area, and there was no attempt to provide landowner assurances with respect to other species not studied during the planning process. The conservation strategy of the plan empha- sizes grassland habitat for two imperiled species - the mission blue butterfly and the callippe sil- verspot butterfly. That region also has several other endangered species, including two addi- tional endangered butterflies - the San Bruno elfin (Callophrys mossii bayensis) and the bay checkerspot (Euphydryas editha bayensis). The elfin is dependent upon brush habitat rather than grassland, and the HCP designates "poten- tial habitat" for this species. If development is proposed in potential habitat, a separate impact fa