123 



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$10,000 to "Californians Against the Toxics Initiative." The initiative 

 to control toxic wastes was passed overwhelmingly by California voters 

 in the November 1986 election, in spite of efforts by corporations such 

 as Aerojet General. 



We do not believe the subject of toxic waste management and 

 disposal has been adequately covered in the legislative and 

 environmental documents . 



IV. FEDERAL AND STATE AGENCIES DID NOT USE THE ADVICE OF THEIR OWN 

 BIOLOGISTS AND DESERT TORTOISE EXPERTS ON THE AEROJET PROPOSAL 



The Fish and Wildlife Service made strong statements about the 

 negative impacts of Aerojet 's proposal on desert tortoises in a Formal 

 Section 7 Consultation for Nevada Land Disposal ( see Case Nvunber 

 1-5-87-FW-9; Memorandum from the Regional Director of Region 1 to the 

 Asst. Regional Director of Region 1, dated Dec. 11, 1986). The Regional 

 Director states: 



The effects of this proposal to listed and candidate species are 

 not restricted to those anticipated by Aerojet and their 

 activities. The eventual sale of this land opens the way for 

 indirect effects that will further degrade lands, and hence, desert 

 tortoise habitat... It is believed that these future impacts will be 

 more detrimental to local listed and candidate species thein the 

 activities of Aerojet. This would result in approximately 17,000 

 acres of crucial, moderate-density desert tortoise habitat being 

 adversely affected. This would represent a major negative impact 

 to one of the only six known areas in Nevada where tortoise 

 populations are believed sufficient to maintain viable populations. 

 Past release of Federal lands in Nevada has caused problems that 

 have resulted in the listing of 11 plants and animals as threatened 

 or endangered... [pg. 13] 



The Fish and Wildlife Service downplayed and understated these 

 impacts to the desert tortoise in the Resource Ascertainment Report, 

 Drafting Service for Members of the Nevada and Florida Congressional 

 Delegations, Nevada-Florida Land Exchange . The above statements were 

 not included in the Resource Ascertainment Report . 



In addition, senior level management officials in appointed 

 positions in the Nevada Department of Wildlife ignored materials 

 presented by staff members on the degree and nature of impacts of the 

 Aerojet project on the desert tortoise and other species. 



V. THE DESERT TORTOISE WILL LOSE HABITAT ESSENTIAL TO ITS CONTINUED 

 EXISTENCE IN NEVADA, IF S. 854 IS PASSED 



The proposed legislation contains "stipulations" which are supposed 

 to benefit the tortoise and its habitat (Exhibit F) . We do not believe 

 that these stipulations are adequate even to mitigate impacts, much less 

 to result in net benefits to the tortoise. In fact, they are mere 

 window dressing. We have outlined major problem £ireas below. 



