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Page 9: Detailed specifications of the construction of a monitor well seem to 

 be given an unusual amount of weight in this agreement. An implication is 

 that future attempts by the U.S. Government to assess the quantity and quality 

 of water in the government would also be highly restricted. Aerojet should be 

 compelled to do the monitoring at their expense to ensure that water quality 

 and quantity is not affected and that no major impacts occur to nearby 

 endangered species of fish. 



Page 10: A major problem with the proposed "exchange" is that Aerojet may 

 sell all, or a portion of, the land at a later date. The windfall profit 

 would come at the expense of the public because of the artificially low value 

 given to the land by the BLM. The highlighted item [with question mark] 

 covers the situation where Aerojet may chose to sell the land. This 

 possibility is not sufficiently restricted in the proposed land exchange to 

 protect the threatened desert tortoise or nearby endangered species of fish 

 from future large-scale developments in the area. 



Page II: Item 11 (c) as highlighted illustrates the "hammer" that Aerojet 

 possesses in this Agreement to ensure that they will be permitted to utilize 

 the land for the manufacturing and testing of rocket motors. If anything 

 changes, or they decide to develop larger rocket engines than currently 

 envisioned and someone protests, then they have the right in this agreement to 

 "rescind this exchange." If Aerojet does not get the necessary permits or 

 authorizations at some time in the future from some entity, then they retain 

 in this Agreement the option to stop the exchange. There can be no guarantees 

 with the development of land, particularly private land. There is a risk that 

 future development of property may not comply with local zoning ordinances, or 

 federal, state, and local regulations. Aerojet should be compelled to accept 

 that risk at the time the exchange is executed and be in a position to accept 

 the consequences if anything goes wrong with their development plans. If they 

 do not choose to accept that risk, then they should consider another option to 

 the proposed exchange such as a long-term lease of public lands at the Nevada 

 Test site, or continued use of their property in California or Florida. 



Page 12 & 13: The highlighted language covering the "period of time Aerojet . 

 makes all or a portion of the Nevada Land subject to a pending sale or option 

 to buy agreement" deserves further investigation and explanation. 



Item 12 states that the Department of Interior shall not oppose any 

 application to any federal, state or local government agency for permits . . . 

 necessary for Aerojet to conduct activities on the Nevada land that are 

 consistent with the provisions of the Agreement. This provision prevents the 

 Fish & Wildlife Service from taking necessary actions to protect threatened 

 and endangered species of wildlife that are in the area of the proposed rocket 

 manufacturing and testing facility. Further, the impact of the development of 

 the Coyote Springs land on adjacent 3LM wilderness study areas cannot be 

 challenged by the Department of Interior if the need arises. This provision 

 in tiie Agreement needs to be examined further to determine if iL is legal and 

 precedent setting. 



As noted in the Fish & Wildlife Service, memo of December 11 , 1986 (concerning 

 the "Formal Section 7 Consultation for Nevada Land Disposal"): 



Tlie Secretary will withdraw the Services' July 



