125 



only with intensive preparation, long-term monitoring with 

 radio telemetry, and with expert advice and assistance. 



(4) The proposal (Exhibit F, pg. 2, item 5) to fence portions of 

 roads through high density tortoise habitat is inadequate and 

 unacceptable. Preparers of the Aerojet Environmental Report 

 and personnel at Aerojet do not have an adequate understanding 

 of tortoise population management, movements, and behavior. 

 The impacts of paved roads on tortoise populations are well 

 documented. In 1977 and 1978, the Bureau of Land Management 

 in California conducted research on effects of roads on 

 tortoises. They reported that tortoise populations decline 

 significantly to distances of 0.5 to 1 mile on either side of 

 a well-used road. Since the old highway in Coyote Spring 

 Valley has not been used for many years, tortoises have 

 gradually reoccupied the area on and adjacent to the old 

 road. Many tortoises would be at risk with reconstruction 

 and use of the highway. 



If only parts of the old highway and roads through tortoise 

 crucial habitat are fenced, the tortoises from high density 

 habitat will be forced to move along the fence to areas with 

 no fencing in moderate to low density habitats. All tortoises 

 crossing roads at the fencing gaps will be at risk. 



All roads used by Aerojet in Desert Tortoise Crucial Habitat 

 in Coyote Spring Valley and Arrow Canyon should be fenced with 

 tortoise-proof fencing and standard tortoise underpasses 

 should be constructed underneath the roads. The Desert 

 Tortoise Crucial Habitat is shown in Plate 8-7 of the 

 report, "The Status of the Desert Tortoise ( Gopherus 

 aqassizii ) in the United States," dated 1984 and edited by K. 

 H. Berry (report from Desert Tortoise Council to U. S. Fish 

 and Wildlife Service, Sacramento, California). The California 

 Department of Transportation supported a pilot study on the 

 subject and identified effective types of culverts and 

 fencing. Their results should be used to design the fence and 

 culverts. 



(5) The proposal (Exhibit F, pg. 2, items 3 and 4) to place a 

 reasonable number of signs (not to exceed 20) along the 

 highway to warn motorists to drive carefully to protect 

 tortoises is a totally inadequate and unwise mitigation. 

 Motorists have difficultly seeing adult tortoises in time 

 to avoid hitting them, and are even less likely to see the 

 juveniles. The signs will call attention to the presence of 

 tortoises in the area and will stimulate illegal collecting. 



(6) The proposal (Exhibit F, pp. 3-4, item 9) to set aside 



a reserved area of 17,885 acres for 20 years to encourage 

 study and observation of the tortoises does virtually nothing 

 to ensure the long-term protection and conservation of the 



