128 



The preparers fail to take into accovint the fragmenting 

 effects of the project. This must be addressed. 



(6) pg. 124. The prepsirers make the statements that "[305] acres 

 of tortoise habitat would be degraded or permanently 

 removed. Tortoise movements would be restricted within 2,760 

 acres." This statement is incorrect. At least 2760 acres 

 would be lost to tortoises. Tortoises would be removed from 

 and fenced out of 2760 acres. 



pg. 124. The preparers state: "The degradation, permanent 

 loss, and fencing of tortoise habitat would be situated 

 outside of areas where moderate to high density tortoises 

 habitat have been indicated by previous population sampling 

 efforts." This statement is patently false. Most areas 

 contain moderate densities of 45 to 90 tortoises per square 

 mile; some sites have high densities of up to 140 

 tortoises per square mile. 



Resource Ascertainment Report, Drafting Service for Members of the 

 Nevada and Florida Congressional Delegations, Nevada-Florida Land 

 Exchange. Undated. Although this report probably has been 

 superseded by other, more recent documents, it still contains 

 considerable misinformation. 



pg. 13. The statement is made that "Most of the valley is poor 

 wildlife habitat, except for desert-adapted species such as the 

 desert tortoise." This statement gives an erroneous impression 

 about deserts and desert-adapted species. In fact, the valley 

 offers outstanding habitat for over 20 species of reptiles, 30 

 breeding birds, and about 30 species of mammals. The preparers 

 appear to be comparing desert-adapted to non-desert adapted 

 species. The preparers appear to be placing a value judgment on 

 desert habitats and species that are adapted to desert habitats, 

 calling them poor. 



pp. 13, 14. The statement is made that the desert tortoise is a 

 candidate species for federal listing. This is true in part. In 

 fact, in December of 1985, U. S. Fish and Wildlife Service 

 determined that desert tortoise populations were declining 

 throughout the geographic range in the United States and that 

 federal listing is warranted (Federal Register 50 [234]:49868- 

 49870). The listing package has not been prepared, because the 

 (1) the Fish and Wildlife Service is inadequately staffed, and (2) 

 there is a long list of species waiting to be listed. 



In the Mojave Desert of California, Nevada, and Utah, recent data 

 indicate that tortoise populations are suffering continued 

 reductions, with some populations close to extinction. 



pp. 14, 15. The statement is made that "The major threats to the 

 tortoise are from human ...collecting and vehicular collisions — 

 We disagree. The preparers should thoroughly review the 1984 



