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FRAYED SAFETY NET S ...............................................................,.,.............,...,...,....................,............................'.'..'...........'...............: permit upon listing, even though the amount of old growth on DNR lands decreases under the HCP. DNR does plan to protect 100,000 acres of owl nesting, roosting and foraging habitat (old growth) for demographic support of spotted owls on federal lands. However, old growth is protect- ed only in 300-acre patches. The riparian man- agement zones will provide old growth, but not until the end of the planning period. Despite such sparse provision of old growth habitat, DNR still receives assurances for old-growth dependent species and all other species. National Trends In many ways, the examples of the San Bruno Mountain HCP and the Washington DNR HCP represent the respective extremes in good protection of multiple species versus assured permits without biological justification. Clearly, landowners have a powerful incentive to engage in conservation planning and to protect unlisted species if they are protected from regula- tions regarding those species upon listing. By providing some assurance to landowners, FWS can promote conservation plans oriented towards ecosystems and watersheds rather than manage- ment of patches currently occupied by endan- gered species. In trying to strike the balance between conservation and assurances, FWS has tried several approaches, all somewhere between the San Bruno Mountain HCP and the Washington DNR assurances. Most of these approaches are "habitat-based," where there is an assumption that if a habitat type is sufficiently protected under a plan, species associated with that habitat type are protected well enough. Unfortunately, those assumptions do not hold at times and often require much more scientific information to determine whether protecting tar- get species and habitat types adequately provides for other species (Murphy et al. 1997, see Appendix B). In this report, the plan that most explicitly uses this approach is the Multiple Species Conservation Program (MSCP) in southwestern San Diego County. A "covered species" list is at the heart of the plan, since it specifies which species ate included in the incidental take per- mit. During the planning process, a list of 57 "covered" species was expanded to 85 even though no significant conservation improve- ments were added to the MSCP. This list was generated by analyzing where sensitive species occur in the MSCP area, what habitats they use and the degree of population or habitat protec- tion under the preserve system. There are several types of species on the cov- ered species list. First, a species can be deemed "covered" based on what proportion of the species' range in the planning area is protected under the plan. Second, wetland-associated species are deemed to be "covered" because of federal regulations protecting wetlands (even though the local wetland regulations were being modified before the final MSCP approval). Third, some species are considered "covered" because the MSCP would have an insignificant impact on them. For example, such covered species as the golden eagle (Aquila chrysaetos) and the mountain lion (Felis concolor) are wide- rang- ing, and some species are peripheral to the plan- ning area and have few or no occurrences within fa