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Page 2 of 5: Item 3 is virtually worthless in protecting the migration habits 

 and routes of the bighorn sheep and the desert tortoise. Aerojet might as 

 well put up signs for the animals warning them of approaching vehicles. 



Item 5 also offers limited protection for the "threatened" desert tortoise. 



Page 3 of 5: Item 6 states "Aerojet shall consider" the historical migration 

 routes of big horn sheep. "Protect" or "preserve" would be better than 

 "consider." 



Item 8 directs Aerojet to "cooperate" with the 3LM in reducing grazing on the 

 Coyote Spring land. Since the BLM presently manages the land and administers 

 grazing rights to the land, it is a curious choice of words on Aerojet's part. 

 Perhaps they are saying that they will buy the grazing rights from the permit 

 holder? 



Item 9 addresses the establishment of a "17,885 acre "reserve" for desert 

 tortoises over a 20 year period. After 20 years, a seven member board may 

 approve a change in the usage of the "reserve." Note, no member of the 

 general public is included on the board, especially representatives of the 

 Oesert Tortoise Council. Further, no provisions are stated in how the "board 

 rflll conduct their meetings and arrive at a decision. Loolcing at the makeup 

 of the board it is conceivable that a rnajorlty could easily be assembled to 

 allow the "r.eserve" to be managed quite differently than Ln the past. Roads, 

 water wells, utilities, facility signs "or otiier wildlife protective measures" 

 are some of the periitted uses of the "reserve." When is a "road" a "wildlife 

 protective measure?" 



Page 4 of 5: Item 10 is perhaps the most disturbing clause in the Agreement. 

 It states that the Fish and Wildlife Service and Aerojet "shall jointly" seek 

 a determination from the Nevada State Engineer as to the cause of a depletion 

 in the water-table which might impact nearby endangered species of fish. 

 Objection is taken to the usage of "jointly." The Fish and Wildlife Service 

 should be allowed to act independently to protect the fish no matter whether 

 Aerojet is the "sole cause of t!ia depletion of water" or not. 



T!ie State Water Engineer lias previously testLfi.jd .before the Nevada 

 '..egislatura's Committee on Public Lands that t!ie capacity of the aquifer 

 cannot be adequately determined because of insufficient data. Further, he 

 stated Aerojet siiould be allowed to stress the aquifer because that would be a 

 way to determine the capacity of the aquifer. Given the problems that would 

 be created to the nearby endangered species of fish if Aerojet were allowed to 

 develop the site and then find that insufficient water exists, it would seem 

 that the Fish and Wildlife Service should be allowed to act independently to 

 protect endangered species of fish. 



Approximately 460 acres of private land lies across the Iiigliway from Aerojet. 

 If this land were developed to a great degree and the land Aerojet were to 

 acquire were also developed to a large extent, then the impact on water 

 availability at Coyote Springs could be severe. Wiat then? 



