local residents had created San Bruno Mountain State and County Park, which held of the 3,600 on the mountain, in order to protect the habitat of the Mission blue butterfly. Then, the butterfly began to turn up on private land. The U.S. Fish and Wildlife Service formed a committee with landowners, developers, local governments, the California Department of Fish and Game, and others to craft the first HCP in 1982 "to address problems caused by the presence of endangered butterflies on San Bruno Mountain." HCPs do not include any independent scientific review, thus none exists. The plan became the model for the 1983 amendment to the Endangered Species Act. HCPs work like this. In exchange for permission to build over the top of the prime habitat of two California endangered butterflies, the Mission blue and the San Bruno elfin butterfly, landowners agreed to measures to improve the prospects for the species' survival in other locations. This particular HCP allowed the development of to . Property owners who located in this area were required to offer land and funds to conserve and improve habitat in other locales around San Bruno Mountain. Property holders are also assessed for a Habitat Conservation Trust Fund which pays for species monitoring, alien plant removal and other tasks on the "donated" land slated for habitat. One such area on San Bruno Mountain was along the northeast ridge. There, a residential community was built over prime Mission blue habitat, a habitat that was supposed to be restored on the saddle of the mountain. However, the mountain's saddle is colder, damper and windier. On top of this, the saddle is overgrown with an invasive species, gorse, while the Mission blue requires lupine as its host plant. The environmental consulting firm, Thomas Reid Associates (TRA) crafted the plan and work to carry out the HCPs biological program and monitors the results. In addition, they have conducted the biological studies and environmental impact studies required under the HCP. TRA works with others to stop exotic plant invasions on butterfly habitat and began to undertake the daunting task of replacing the gorse infested saddle with lupine for the butterflies to relocate to. The project started in 1985. Gorse is a hardy plant that can reach heights of with deep root systems. TRA tried multiple methods to destroy the invasive species, including herbicides and burning. By April the unfazed gorse bloomed a