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..................................................................................................................................,.. F RAY E 0 S A F E T Y NET S fa study must be performed, but incidental take outside potential habitat is permitted through the HCP. For the bay checkerspot butterfly, the only individuals lived on one portion of the mountain, which was already protected by San Mateo County. The HCP simply contained a prohibition on development or trail building within those areas of the county park and estab- lished annual monitoring for this species. Particular care was taken to avoid impacts on another federally endangered species, the San Francisco garter snake (Thamnophis sirtalis tetrataenia). FWS and the California Department of Fish and Game had determined that suitable habitat existed on the mountain, but they could not find the species in searches of the area. When the HCP was developed, the environmental consulting firm contracted a research herpetologist at U.c. Berkeley expert on the San Francisco garter snake, Ted Papenfuss, to prepare a map of the snake's potential habitat on the mountain. As with the elfin, further impact studies must be done for development to occur in those Botential habitat areas. If snakes are found, no take can occur. Outside potential habitat areas, incidental taking through develop- ment is permitted under the HCP. The approach contained in this HCp, which emphasizes thorough survey for the covered species, designation and protection of potential habitat, and assurances to landowners for areas outside potential habitat, is a practical approach to planning for multiple species. Under this approach, landowners can receive assurance that development can occur in areas that are not potential habitat, but habitat destruction is not permitted in occupied or suitable unoccupied habitat until more information is available and the exact impact is known. Washington DNR's Blanket Assurances Since the San Bruno Mountain HCP in 1982, conservation plans have become consider- ably more complicated, covering larger areas and affecting more sensitive species. In Washington, the HCP for state-owned land managed by the Department of Natural Resources (1.6 million acres) contains assurances that the incidental take permit will include each species that becomes listed during the 70 to 100 years of the HCP, unless the plan would jeopardize the species' continued existence. Determining jeopardy to such species, however, will be extremely difficult because DNR did not survey for these species before the HCP, and "under this HCP, DNR shall not be required to survey for nests, dens, roosts, or individual occurrences of unlisted species" (p. N-134, Draft HCP). In the HCP document, each unlisted but sensitive species that may be on the property is individually addressed. For nearly every sensitive species, however, there is a justification of why the conservation strategy designed for owls, mur- relets and salmon suffices for habitats needed by these other sensitive species. It may be true that species that become listed in the future will coin- cide with suitable habitat created under the HCP. Unfortunately, for many species it will be impossible to predict whether this is true, despite the blanket assurances for DNR provided under the HCP. For example, species that depend upon old growth habitat will be included in the