130 



-9- 



stated above, as well as others described below. The net effects 

 will be negative. The preparers should have used information 

 provided by the Fish and Wildlife Service in the Formal Section 7 

 Consultation for Land Disposal (see III. above). 



(1) Human use in the general region will increase with the 

 employment of 600 people. 



(2) Fragmentation of habitat will increase. 



(3) If the area or parts of the area are developed after 20 

 years, any benefits from prior mitigations will be 

 cancelled. 



VII. RECOMMENDATIONS 



This project deserves more than the cursory evaluation it has 

 received so far from state and federal agencies. We strongly oppose S. 

 854 as it is written, and more specifically, we oppose the location and 

 the incomplete and flawed environmental evaluation. We recommend: 



(1) Aerojet should seek out and fully evaluate alternate sites for the 

 proposed facilities . 



(a) Vast tracks of land are under the domain of the military. 

 Some parts of these lands receive little, if any use, and 

 would be suitable for the Aerojet facility. 



(b) Tikaboo Valley. Part of this valley is under the jurisdiction 

 of the Air Force, and serves as a buffer zone for the east 

 side of Nellis Air Force Base. 



(c) Dry Lake Valley, southeast of Caliente. 



Such sites could be fully evaluated in a formal Environmental 

 Impact Statement, which would include a public commenting process. 



(2) The U. S. Fish and Wildlife Service and conservation groups should 

 seek alternative sources of funds for acquisition of important 

 lands in the National Wildlife Refuges in Florida, e.g., through 

 the Land and Water Conservation Fund or The Nature Conservancy. 



VIII. IF AEROJET IS TO UTILIZE THE COYOTE SPRING VALLEY, THE FOLLOWING 

 ARE AMONG THE TORTOISE MITIGATIONS AND COMPENSATION MEASURES THAT 

 SHOULD BECOME PART OF THE AGREEMENT 



Stipulations, mitigations, and compensation measures must be 

 specified in detail and in writing. 



(1) The 17,885 reserved area should be protected by Congressional 

 mcindate into perpetuity, not just for 20 years. 



