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F RAY E 0 SA F E T Y NET S ..........................................................................................................................................................................; This type of strategic plan, focusing on specific techniques, particular high-priority locations and experimental approaches, should be approved by FWS along with the plan. Because conservation plans (especially HCPs) often focus on single species, there is a tempta- tion to minimize and mitigate harm byempha- sizing manipulation of individual animals instead of preserving and managing habitat. Yet for 88 percent of listed species, habitat loss is a major factor in the decision to list (Wilcove et al. 1996). For these species, any program that seeks to authorize take of occupied habitat, mitigated by transplantation of individuals to protected sites, results in a loss of protected habitat and is detrimental to species survival in the long term. Moreover, for some species, there is a trend toward deemphasizing the importance of protect- ing individuals where they currently live and translocating endangered species from private to public land. In general, this approach loses sight of the purpose of the ESA, which is to conserve species and the ecosystems upon which they depend (ESA ~2). It is highly questionable whether transloca- tion programs can be effective unles~ habitat loss also is addressed. Unfortunately, there are many examples of species-specific, intensive transplan- tation programs in our sample of conservation plans. For the Coleman Company HCP for the Utah prairie dog, the plan allows development on land with a prairie dog colony after transplan- tation of all 116 prairie dogs to BLM land. Transplantation has been an increasingly popular technique for Utah prairie dog management on private agricultl1ralland, and since 1992 increas- ing numbers of prairie dogs have been trans- planted from private to public land. Yet accord- ing to a recent report by state wildlife officials, transplantation has not been well researched or proven to be effective: A better understanding of habitat requirements of Utah prairie dogs is required to allow managers to identifY transplant sites and manage habitat in a manner suitable for prairie dogs. Guide- lines contained in the Utah Prairie Dog Recovery Plan are vague and have never been tested scientifically.... (p. 28, Utah Division of Wildlife Resources 1997). In fact, a study that attempted to track 430 transplanted prairie dogs determined that approximately 21 percent of prairie dogs stayed in the surrounding area of release, and individu- als recaptured multiple times appeared to gain an abnormally low amount of weight. What effect this dispersal of groups from transplantation sites has on the social behavior of prairie dogs is unknown. In Clark County, Nevada, the HCP for the Mojave desert tortoise employs a strategy to avoid take by translocating tortoises from areas slated for development. Although thisHCP began in 1995, the tortoise relocation strategy was in place for the county under a short-term HCP from 1991 to 1995. The short-term HCP allowed incidental take on approximately 30,000 acres of tortoise habitat, and tortoises that were rescued from development sites were transferred to a holding facility, where an upper respiratory tract disease spread among the captive popula- tion. At the beginning of the long-term HCP (reviewed here), 250 of the tortoises rescued dur- ing the short-term HCP were languishing in the CD