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purchase of the subject 47 platted lots in Phase 11 of the Sebastian Scrub Conservation Area project. The Board's decision halted all acquisition efforts in the Unit 17 platted lots comprising the Sebastian Scrub Conservation Area project (Indian River County, October 17, 1996 correspondence to the FWS - see Appendix B). The loss of the Unit 17 core scrub -jay habitat caused the Indian River County i Environmental Planning Staff, in consultation with the FWS, to re-evaluate the mitigation strategy needed to develop a county -wide or Sebastian area -wide HCP. Throughout the two-year process, there had been an informal understanding between the FWS and Indian River County that acquisition and management of the North Sebastian Conservation Area, Wabasso Scrub Conservation Area, and Sebastian Highlands Unit 17 lots would serve to provide a substantial portion of the mitigation needed to support a county -wide HCP (FWS, November 12, 1996 correspondence to Indian River County). It is important to note that at the urging of the FWS, the IRC Board subsequently authorized the purchase of a block of 34 contiguous lots in Unit 17, a portion of the Phase 1 of Sebastian Scrub Conservation Area project. These lots are part of the proposed Scrub -Jay Habitat Compensation Areas, referred to herein as the 10± acre Sebastian Highlands Scrub Conservation Area. The FWS supported this effort based on the opinion that the "... 34 AGC lots, in combination with Pelican Elementary School scrub, may provide enough suitable habitat to minimize the adverse effects of habitat fragmentation due to losses in the remainder of Unit 17. These scrub parcels, if properly managed, may be essential "stepping stones" for dispersal of scrub -jays from and to northern Indian River County..." (FWS, November 12, 1996 correspondence to Indian River County). In consideration of the loss of the Unit 17 scrub lots, the November 12, 1996 FWS correspondence to Indian River County identified other conservation actions that Indian River County could explore to support an HCP. Two of the referenced actions included the management of scrub habitat located on the Sebastian Airport/Golf Course and Sebastian and Pelican Island Elementary School. In October 1997, both the City the Sebastian and School District of Indian River County agreed to review a conservation plan that requires implementation of habitat management actions on the referenced parcels (City of Sebastian, October 9, 1997 correspondence to Indian River County; School District of Indian River County, October 2, 1997 correspondence to Indian River County - see Appendix B). In response to the FWS recommendation to continue with development and implementation of an NCP, the IRC Board approved a request from the Environmental Planning Section to solicit consultant proposals for development of the subject Sebastian Area -Wide Scrub -Jay Habitat Conservation Plan in December 1997. In March 1998, Indian River County issued a Request for Proposals, RFP 11 8047. In July 1998 Smith Environmental Services (SES) was authorized to proceed with development of this Sebastian HCP. Consolidation of existing data and performance of field surveys to update the existing information were undertaken by SES through October 1998. An informal meeting was held with FWS staff on 29