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While considering; your current proposal, we often referenced the outline for the Countywide i conservation plan and it's more recent. but short lived predecessor, the site specific Sebastian Highlands conservation plan_ "I'bough different in scope. both conservation plans were intended to relieve the County and Sebastian Highland hit owners of their responsibilities to avoid take of the threatened scrub jay, by providing "mitigation." Mitigation in both conservation plans � included conservation and management of scrub oak habitat. Unfortunately, it has never been clear which conserved and managed lands were being proposed for mitigation in either of the two conservation plans. However. there seems to have been a general consensus among the FWS and County that acquisition of tile St. Sebastian PUD, Atf]C Industrial Tract, Wabasso Scrub, and Sebastian highlands Unit 17 lots would provide a substantial portion of the mitigation that would ultimately be needed during, development of'a County -wide conservation plan, Your current proposal now requests FWS approval of a mitigation strategy that does not include lots in Unit 17 of Sebastian Highlands, For comparative purposes, we have summarized the approximate acreages of'scrub jay habitat (and families) adversely affected and protected under the previous conservation plans and the current mitigation proposal. 0 Previous Conservation Phan Proposed fldverse Affects = Alteration of 216 scrub lots in Units 3, 5, 10. and 17 in Sebastian I liehlands or about 47 acres of scrub jay habitat, ]'our Gmulies of lays are known to currently reside within these Units. A total of 47 acres and four scrub jay t"antilies would tic affected. j' o ins ltitigat_ ipli 119 lots in Unit 17 (about 30 acres) plus about 20 acres of managed school board property. Contiguous tracts known as the St. Sebastian PUD and ACC industrial Tract contain about 40 acres of occupied habitat and about 50 acres of unoccupied scrub habitat. The remaining uncommitted occupied and unoccupied habitat within the Wabasso Scrub Conservation Area (about 25 acres). Management plans were also proposed for other public lands containing scrub jays, including the Sebastian golf course, airport. and Sebastian elementary school. At total of sixteen families ofjays reside in these areas. A total of 115 acres of occupied habitat, 50 acres of unoccupied habitat, and 10 scrub jay families would benefit from this proposal. The Current Mitigation Proposal Pn7posed Adverse < fla is = Alteration of 18.5 scrub lots in Units 3, 5, and 10 ill Sebastian I lighlands (about 47 acres), development of 148 lots in unit 17 (about 37 acres), road construction impacts to about 3 acres ofoccupied scrub habitat. Light families reside ill these areas. About 87 acres of occupiedhabitat and eight scrub jay lamihes would lie affcmd bly this proposal. 7