126 



-5- 



desert tortoise population in Coyote Spring Valley. Although 

 superficially appealing, the proposal is worthless in a long- 

 term sense. After 20 years, development could take place. 



The proposed reserve does not meet essential specifications 

 outlined by experts in reserves, parks, or refuges (see 

 studies by J. Diamond, M. Soule, B. Wilcox, and others). 

 The proposed reserve is fragmented and too small to meet the 

 long-term biological needs of desert tortoises. 



(7) The proposed buffer zone of 11,420 acres has no tortoise 

 management plan. These lands can be sold after 20 years. If 

 sale or development of these land occurs, tortoise habitat 

 would be further fragmented and tortoise populations in the 

 reserved area would be jeopardized. 



(8) The proposal to have a seven-member Board (Exhibit F, pg. 4) 

 oversee the "reserved acreage" is unacceptable to us. Most 

 members of the board will be political appointees. None will 

 have tortoise expertise. It is our collective experience--and 

 many of us are government employees--that such Boards place 

 far more weight on benefits of economic development than on 

 the well-being of threatened and endangered species. 



Aerojet has had the opportunity to use our collective 

 expertise on many occasions in 1986 and 1987. As of June, 

 1987, Aerojet has shown no willingness to utilize our 

 experience and information. Instead, Aerojet has chosen to 

 seek advice of political appointees in senior management 

 positions. Aerojet has misinterpreted data on distribution 

 and density of the tortoise, apparently for self-serving 

 purposes . 



VI. ENVIRONMENTAL DOCUMENTS ASSOCIATED WITH S. 854 ARE SERIOUSLY FLAWED 



Several documents associated with the S. 854 proposal are seriously 

 flawed. They contain false statements, errors of fact, and misleading 

 information. In general, they indicate that tortoise populations and 

 habitat will not suffer unmitigable impacts or irreparable harm. These 

 reports indicate, falsely, that passage of S. 854 will not jeopardize 

 the continued existence of important tortoise habitats in Nevada. 



Examples include: 



Aerojet-General Corporation, Florida-Nevada Land Exchange. 

 Environmental Report for Coyote Spring Valley. Prepared by 

 Resource Concepts, Inc., Carson city, Nevada. February 1987. 



(1) pg. vii, pp. 125 and 126. The preparers state that 81 acres 

 would be permanently lost, 224 acres would be disturbed, and 

 2760 acres would be enclosed by fencing. In fact, 2760 

 acres would be lost. This is habitat for 160 to 325 



I 



