124 



(1) The proposal does not take into account the recent information 

 on the genetics of desert tortoise populations in the United 

 States and Mexico. The tortoise population in Coyote Spring 

 Valley, Arrow Canyon, Las Vegas Valley, and Ivanpah Valley 

 (extreme eastern California and west-central Nevada) is a 

 genetic unit different from all other populations. No part of 

 this population, which occurs primarily on public domain 

 lands, is protected. Tortoise populations in this genetic 

 unit are rapidly declining in northern Ivanpah and Las 



Vegas valleys and may soon reach the point where they are no 

 longer viable. 



(2) The Federal government loses access to important tortoise 

 hcibitat in Coyote Spring Valley. Government officials would 

 be allowed to enter no more than once per month and then only 

 during regular business hours. The Federal government would 

 lose the ability to monitor the status and condition of these 

 important tortoise populations . 



(3) The proposal to relocate tortoises (E:xhibit F, pg. 2, item 5) 

 is inadequate and inhumane. According to Ralph Clark, General 

 Manager of Aerojet Nevada, Aerojet has no intention of doing 

 anything other than collecting the tortoises and moving them 

 outside of the areas to be developed for static testing of 

 rockets, facilities, etc. (Remarks made at the 1987 Desert 

 Tortoise Council Symposium, March 1987). 



No studies will be conducted to determine if the relocated 

 tortoises survive. (Mr. Clark said that he personally did not 

 think such an effort was necessary). No constraints have been 

 placed on Aerojet as to the time of year for construction, 

 appropriate seasons and methods for relocation of tortoises, 

 or the type of fence to be placed around the developed 

 facilities. 



Tortoises tend to return to their home sites and will injure 

 themselves on the fence, if the fence is not properly 

 designed. Furthermore, it is very likely that the release 

 area is already at or near carrying capacity. The relocated 

 tortoises will be competing with long-term residents for food 

 and shelter. Numerous aggressive encounters are likely to 

 occur and the survivorship is likely to be poor. 



The results of tortoise relocation efforts were addressed at 

 the 1987 Desert Tortoise Council Symposium, where national and 

 international experts on relocation of turtles and tortoises 

 gathered to discuss the pros and cons of relocation in a 

 special session. The experts concluded that relocation 

 efforts have not been particularly successful to date. Many 

 problems have been documented. Tortoises have high fidelity 

 to their homesites. They use the same areas year after year, 

 and many do not thrive when moved. The experts concluded 

 that relocation should be undertaken only as a last resort. 



