127 



-6- 



tortoises. The fencing also will partially fragment habitat 

 of several hundred additional tortoises, who have parts of 

 home ranges inside the fenced areas. 



(2) pp. vii and viii, pg. 127. The preparers state that in 

 addition to the reserve area, the powerline corridor of 

 10,555 acres would function as additional protection, with 

 negative impacts limited to powerline construction and 

 maintenance. However, the transmission line towers are used 

 as perches by the raven, a highly effective predator on 

 juvenile tortoises. In practice, with each new powerline, 

 perch sites will increase and additional tortoise habitat will 

 be lost. 



The proposed reserve, buffer zone, and corridor combined do 

 not meet the minimum standards for preserves for species such 

 as the desert tortoise. The minimum standards have been set 

 by scientists working together nationally and internationally 

 to protect rare, threatened, and endangered species. 



(3) pp. vii and viii. The preparers fail to mention in this 

 section that the Conservation Reserve is guaranteed for only 

 20 years! After that time, it could be developed. 



(4) pp. 97, 98; Fig. 4.11. The preparers call densities 

 of to 45 tortoises per square mile low density. We 

 disagree. We use the term low density to refer to densities 

 of to 10 or to 20 tortoises per square mile. We use these 

 designations in all four states where desert tortoises occur. 

 The preparers have misinterpreted data and have redefined "low 

 densities" for their own purposes. 



(5) pp. 97, 98 and Figs. 4.10 and 4.11. These pages contain 

 misleading information about tortoise distribution and 

 abundance. We have repeatedly advised Mr. Clark, General 

 Manager of Aerojet Nevada, of problems with these figures. 

 We have provided him with a map of tortoise densities 

 delineated by desert tortoise experts. See enclosed map, 

 Plate 8-7. 



The preparers address the negative impacts to areas with 

 moderate and high tortoise densities only. This is a limited 

 view of what is critical. Actually, any area large enough to 

 sustain a viable subpopulation (such as the proposed Aerojet 

 exchange) naturally includes small areas of low density (0-20 

 tortoises per square mile). It is essential to consider 

 impacts to the total area. 



The preparers state that the exchange boundary area would 

 encompass only 14% of the tortoise habitat in Arrow Canyon/ 

 Coyote Springs Valley. This is a misleading statement. 

 The proposed Aerojet Land Exchange lies within the core of 

 Arrow Canyon/Coyote Spring Valley tortoise habitat. 



