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report on the status of the tortoise in Nevada before making such a 

 statement. Habitat deterioration, loss, and fragmentation are 

 major issues. Deterioration and losses come from many sources, 

 including off-road vehicle use, energy development, grazing, and 

 urban development. Populations are declining from the above uses. 

 Collecting, vandalism, and incidental vehicle kills are only a 

 part of a much larger issue. 



pp. 15, 16. The preparers of this report imply that considerable 

 human use already occurs in Coyote Springs Valley. This is true in 

 part. However, the level is considerably less than in most other 

 important tortoise habitats in Nevada. This is reason to consider 

 this land for future withdrawal as a federal Natural Area or Area 

 of Critical Environmental Concern. 



pp. 21. The preparers state: "However there should be no 

 unmitigable adverse impacts on the environment." This statement 

 is erroneous. In fact. Aerojet plans many actions that are not 

 mitigable, including: 



(1) the construction of facilities and new roads that will 

 result in: 



(a) loss of about five square miles of tortoise habitat, 



(b) fragmented habitat, 



(c) fences and facilities which will provide perches and 

 which will enhance predation 



(2) the relocation of 160 to 325 tortoises, many of which 

 will not survive 



(3) the reconstruction and use of approximately 15 miles of 

 old highway, which will increase tortoise losses from 

 collecting by construction workers and employees, 

 families, and friends (collecting is almost impossible to 

 stop) 



(4) the incomplete fencing and traffic will result in deaths 

 of tortoises on roads and will deplete tortoise 

 populations to distances of 0.5 to 1 mile on either side 

 of roads 



(5) the incomplete fencing and traffic will result in 

 roadkills of many species of animals, which will attract 

 scavenging ravens 



(6) ravens, attracted by roadkills and perches, will increase 

 predation on live juvenile tortoises throughout the area 



pg. 23. The preparers state: "Overall, the effect on the tortoise 

 should be negligible or beneficial." We disagree, for the reasons 



