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these lands to the Desert National Wildlife Refuge with full 

 responsibility for desert tortoise, desert bighorn sheep, and other 

 sensitive species being shifted to the US Fish and Wildlife Service, 

 rather than merely a 20-year stipulation in the Land Exchange Agreement. 

 Wilderness study areas should be avoided. Hunting and other 

 recreational uses should be permitted to continue unless public safety 

 requires controls. Access for mining exploration should also be 

 permitted, rather than deeding the mineral estate to Aerojet as 

 presently proposed. 



3. The "Land Exchange Agreement Between Aerojet-General 

 Corporation and the United States of America" should be rewritten with 

 public review and input to ensure the public interest is served. On 

 page 3 of the current document, a statement that "AEROJET has determined 

 that the exchange of land set forth in this Agreement is in its best 

 interest..." is not sufficient, in our view, to establish that the 

 exchange is in the public interest. Specifically, greater environmental 

 protections, especially of Nevada's deep carbonate aquifer, must be 

 written into the agreement or a special use permit. An analysis of the 

 currently proposed agreement is submitted with these comments detailing 

 problems with its language. (Attachment B). 



