National Park Service: Agency Should Recover Costs of Validity
Examinations for Mining Claims (Letter Report, 09/19/2000,
GAO/RCED-00-265).
Pursuant to a congressional request, GAO provided information on the
federal costs of conducting validity examinations at three California
Desert parks, focusing on whether: (1) data are available on the
National Park Service's costs of conducting validity examinations at
these parks since 1994; and (2) the Park Service recovers the costs of
such examinations from claimants.
GAO noted that: (1) the Park Service does not know how much it is
spending to conduct validity examinations because it does not routinely
track the direct costs of examinations--such as examiners' salaries and
time--and does not have a system to allocate the appropriate indirect
costs--such as fringe benefits, supplies, and utilities; (2) although it
cannot produce an accounting of its actual expenses, the Park Service
estimated it has spent about $668,000, primarily on direct costs, for
the 17 validity examinations it has initiated at three California Desert
parks--about $281,000 on contracts for fieldwork and about $387,000 on
examiners' salaries, travel, and mineral tests; (3) these estimates are
less than the full costs, however, because the Park Service has not
determined all of its direct or indirect costs that can be attributed to
the examinations; (4) the Park Service does not recover any costs of its
validity examinations from claimants; (5) the Secretary of the Interior
is authorized to establish reasonable charges for processing documents
relating to public lands; (6) relying on this authority, the Department
of the Interior's Solicitor issued an opinion in December 1996, stating
that the Bureau of Land Managment's costs of processing mining
documents, including validity examinations and plans of operations, can
and should be recovered from claimants; (7) the Bureau has drafted
regulations--which are expected to be published in the Federal Register
in fall 2000--to recover various costs incurred in managing its minerals
program, including the costs of its validity examinations; (8) Interior
officials believe that the Park Service also could recover the costs of
a validity examination when a claimant has submitted a plan of
operations, and the Park Service has been working with the Bureau to be
included in the regulations; (9) however, 7 of the 17 examinations
initiated by the Park Service since 1994 were not undertaken to process
and approve claimants' plans of operations but were instead initiated by
park superintendents for other reasons, such as a need to address
management or environmental problems posed by particular claims; and
(10) the Park Service has not written guidelines to guide its park
superintendents in making decisions about when it is appropriate to
initiate discretionary examinations.
--------------------------- Indexing Terms -----------------------------
REPORTNUM: RCED-00-265
TITLE: National Park Service: Agency Should Recover Costs of
Validity Examinations for Mining Claims
DATE: 09/19/2000
SUBJECT: National parks
Claims
Environmental policies
Environmental monitoring
Mining
Cost accounting
Cost analysis
Cost control
IDENTIFIER: Death Valley National Park (CA)
Joshua Tree National Park (CA)
Mojave National Preserve (CA)
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GAO/RCED-00-265
A
Report to the Chairman, Subcommittee on Government Management, Information,
and Technology, Committee on Government Reform, House of
Representatives
September 2000 NATIONAL PARK SERVICE
Agency Should Recover Costs of Validity Examinations for Mining Claims
GAO/ RCED- 00- 265
Letter 3 Appendixes Appendix I: Validity Examination Tasks and Time
Requirements 16
Appendix II: Comments From the Department of the Interior 17 Appendix III:
GAO Contacts and Staff Acknowledgments 18
Tables Table 1: Mining Claims Located on Land Managed by the Park Service 6
Table 2: Estimated Costs Associated With Seven Validit Examinations
Performed by Park Service Personnel in the California Desert Parks, Fiscal
Year 1995 Through
June 1, 2000 9 Table 3: Costs of Fieldwork and Report Preparation Associated
With 10 Validity Examinations Performed by Contractors in the California
Desert Parks, Fiscal Year 1995 Through June 1, 2000 10
Resource, Community, and Economic Development Division
Lett er
B- 285504 September 19, 2000 The Honorable Stephen Horn Chairman
Subcommittee on Government Management,
Information, and Technology Committee on Government Reform House of
Representatives
Dear Mr. Chairman: The notion of mining operations in the national parks may
be surprising to many people. 1 However, in 1999 there were 50 private
mining operations in 16 parks, including 17 operations on mining claims
located under the Mining Law of 1872. While all parks are now closed to
location of new mining claims, many mining claims, which represent possible
private property rights that could be developed in the future, exist on
national park lands. For example, there are about 875 such mining claims on
public land in the three national parks established by the California Desert
Protection Act of 1994- Death Valley National Park, Joshua Tree National
Park, and Mojave National Preserve. 2 In order to conduct mining operations
on an existing claim, a claimant must, among other things, demonstrate the
discovery of an economically valuable mineral deposit and submit a plan of
mining operations for approval. The National Park Service (Park Service)
verifies the existence of such deposits in national parks by conducting or
contracting for reviews, which are called validity examinations. Park
Service policy requires that a validity examination be conducted before
approving a claimant's plan of operations, which is a proposal to begin
mining activities. Park superintendents may initiate examinations, even
without a proposal to begin mining activities, to address environmental
concerns on specific claims, among other reasons.
1 In this report parks means any unit of the National Park System. 2 In this
report a mining claim refers to an “unpatented” claim for which
title remains with the federal government because the claimant has not gone
through the process of “patenting” the claim and thereby
receiving title.
The Park Service conducts these examinations under an interagency agreement
with the Bureau of Land Management (Bureau), which has primary
responsibility for managing mining claims on public land. 3 Validity
examinations consist of (1) an administrative review of the Bureau's mining
claim records to determine whether the claimant has complied with all
pertinent laws and regulations, (2) a mineral examination of the claim site
(fieldwork) to assess whether the claimant has discovered an economically
valuable mineral deposit, and (3) a detailed mineral report prepared by the
examiner. If an examiner finds that a claimant has not complied with
requirements or that the mineral deposit on a claim cannot be mined
economically, the Park Service will seek to have the claim eliminated by
requesting that the Bureau declare the claim invalid. Validity examinations
can take from several months to more than a year to complete because of
their technical and complex nature and legal appeals from claimants can add
more time to the process.
Concerned about the federal costs of conducting validity examinations at the
three California Desert parks, you asked us to determine (1) whether data
are available on the Park Service's costs of conducting validity
examinations at these parks since 1994 and (2) whether the Park Service
recovers the costs of such examinations from claimants. Results in Brief The
Park Service does not know how much it is spending to conduct validity
examinations because it does not routinely track the direct costs of
examinations- such as examiners' salaries and time- and does not have a
system to allocate the appropriate indirect costs- such as fringe benefits,
supplies, and utilities. Although it cannot produce an accounting of its
actual expenses, the Park Service estimated it has spent about $668, 000,
primarily on direct costs, for the 17 validity examinations it has initiated
at the three California Desert parks: about $281,000 on contracts for
fieldwork (for 10 examinations) and about $387,000 on examiners' salaries,
travel, and mineral tests (for 7 examinations). These estimates are less
than the full costs, however, because the Park Service has not determined
all of its direct or indirect costs that can be attributed to the
examinations.
The Park Service does not recover any costs of its validity examinations
from claimants. The Secretary of the Interior is authorized to establish
3 Both the Bureau and the Park Service are agencies within the Department of
the Interior.
reasonable charges for processing documents relating to public lands.
Relying on this authority, the Department of the Interior's (Interior)
Solicitor issued an opinion in December 1996, stating that the Bureau's
costs of processing mining documents, including validity examinations and
plans of operations, can and should be recovered from claimants. The Bureau
has drafted regulations- which are expected to be published in the Federal
Register in fall 2000- to recover various costs incurred in managing its
minerals program, including the costs of its validity examinations. Interior
officials believe that the Park Service also could recover the costs of a
validity examination when a claimant has submitted
a plan of operations, and the Park Service has been working with the Bureau
to be included in the regulations. However, 7 of the 17 examinations
initiated by the Park Service since 1994 were not undertaken to process and
approve claimants' plans of operations but were instead initiated by park
superintendents for other reasons, such as a need to address management or
environmental problems posed by particular claims. Such
problems include, for example, unauthorized occupancy of a claim site or
destruction of habitat for the desert tortoise, a threatened species.
According to Interior's Office of the Solicitor and Park Service officials,
it has not been determined whether the Park Service can recover the costs of
such discretionary validity examinations. Furthermore, the Park Service
has no written guidelines to guide its park superintendents in making
decisions about when it is appropriate to initiate discretionary
examinations. This report makes recommendations for the Park Service to (1)
develop an accurate accounting of the costs of its validity examinations,
(2) take steps to recover the costs of validity examinations to the extent
allowed by law, and (3) develop guidance that describes the circumstances
under which
discretionary validity examinations- for which costs may or may not be
recoverable from claimants- are appropriately initiated. We provided
Interior with a draft of this report for its review and comment. Interior
agreed with the report's recommendations and stated that the Park Service
will work closely with the Bureau and other Interior offices to determine
the most efficient and effective means to implement them.
Background Under the Mining Law of 1872, as amended, individuals or parties
who comply with pertinent laws and regulations may locate one claim or more
than one claim, which is called a claim group, to mine certain minerals-
such as gold, silver, and copper- on public lands. For example, at the
Mojave National Preserve, individual claim groups contain from 2 to 88
claims and vary in size from 5 to almost 3, 000 acres. Public lands on which
mining claims may be located may subsequently be designated as National Park
System or wilderness lands, and no new mining claims can be located on these
park and wilderness lands. For example, the California Desert Protection Act
of 1994 4 designated over 9 million acres for three national parks- Death
Valley National Park, Joshua Tree National Park, and Mojave National
Preserve- and 69 wilderness areas in the California Desert. While new mining
claims cannot be located on these designated lands, claims that existed
prior to designation continue to exist and can be mined after the Park
Service approves their plans of operations. There are 11 national parks that
contain about 1,200 preexisting mining claims on public land; about three-
quarters of these claims are in two of the three California Desert parks, as
shown in table 1.
Table 1: Mining Claims Located on Land Managed by the Park Service Park
State Number of claims
Mojave National Preserve California 584 Death Valley National Park
California 292 Yukon - Charley Rivers National Preserve Alaska 129 Denali
National Park and Preserve Alaska 115 Wrangell - St. Elias National Park
Alaska 27 Bering Land Bridge National Preserve Alaska 17 Great Basin
National Park Nevada 10 Bighorn Canyon National Recreation Area Montana 5
Kenai Fjords National Park Alaska 3 Joshua Tree National Park California 1
Saguaro National Park Arizona 1
Total 1,184
Source: Data provided by the Park Service as of June 1999.
4 P. L. 103- 433, Oct. 31, 1994.
Park Service data indicate that the number of claims in the parks has
declined over time. For example, the Park Service estimated there were about
2, 400 claims within the boundary of the Mojave National Preserve when it
was designated in 1994. By June 2000, the number of claims at the Preserve
had declined to about 600. Park Service officials attributed this decline to
claims having been eliminated through an active program to determine the
status of claims within the parks and to claimants having
forfeited their claims by failing to pay a required $100 per claim annual
maintenance fee. According to Park Service officials, claimants have also
been encouraged to donate claims to the park to protect park resources.
Within national parks, because mining operations may conflict with the Park
Service's preservation and conservation mission, the Park Service is
responsible for the oversight of mining claims. The Mining in the Parks Act
of 1976 makes all activities resulting from valid mining claims within any
area of the National Park System subject to regulations prescribed to
preserve and manage those park areas, and the Park Service has issued
regulations to implement the act. The Bureau is responsible for developing
and promulgating policies for administering the mining laws on public lands,
including conducting validity examinations. Through an interagency
agreement, the Park Service agrees to perform validity examinations of
mining claims in national parks, but the Bureau retains responsibility for
approving the examinations. The Bureau also provides guidance and
requirements for validity examinations and certifies federal mineral
examiners. The Park Service's mineral examiners conduct validity
examinations and oversee any examinations performed by contracted examiners.
To conduct mining operations in the parks, a claimant must, among other
things, demonstrate the existence of a valuable mineral deposit capable of
sustaining a profitable mining operation. However, historically, many
claimants hold their claims without discovering such deposits or conducting
any significant mining operations. Before claimants begin development
activities, Park Service regulations require that they submit, and obtain
Park Service approval of, a plan of operations. The plans are to contain,
among other things, a description of the proposed mining activity and a plan
for reclaiming the mine site. As part of the approval process, Park Service
policy requires a validity examination to verify that there has
been a discovery, by the claimant, of a valuable mineral deposit.
Furthermore, the California Desert Protection Act requires the Secretary of
the Interior to determine the validity of claims at the Mojave National
Preserve before approving any plan of operations; the act did not impose
this requirement on the other two parks. In addition to conducting validity
examinations to process and approve plans of operations, park
superintendents may initiate validity examinations for other purposes- for
example, to address environmental concerns such as threats to wildlife
habitat that could result from mining activities on specific claims. If the
Park Service finds, on the basis of a validity examination, that the
mineral deposit is not economically valuable, the Park Service can request
that the Bureau declare the claim invalid, meaning that the claim can be
legally extinguished. However, claimants who disagree with the finding can
contest the Bureau's decision and may appeal to the Interior Board of Land
Appeals and ultimately to federal court. This process can result in lengthy
administrative and judicial proceedings. If, on the other hand, the claimant
has met all requirements and the mineral deposit is found to be
economically valuable, the claim is valid and mining operations may occur
subject to Park Service regulations; alternatively, the Park Service may
preclude mining through a buyout of the claimant's property right interest
at fair market value. For example, the Park Service recently negotiated to
acquire six valid claims located in an environmentally sensitive wilderness
area for $2. 5 million. The Park Service Does The Park Service does not know
the full cost of its validity examination Not Know How Much
program. The agency does not routinely track the direct costs of the
examinations it conducts- such as the examiners' time and salaries- nor Its
Validity does it have a system under which it accurately identifies or
allocates the Examinations Cost
appropriate indirect costs to the program. Indirect costs could include
those for items such as fringe benefits (medical insurance and retirement),
physical overhead, supplies, and utilities. Because of the technical and
contentious nature of mining claims, the validity examination process is
lengthy and detailed (see app. I), and the direct and indirect costs of the
examinations are likely to be substantial. In response to our request, the
Park Service developed an estimate of the costs associated with the 17
validity examinations that it has initiated at the three California Desert
parks since the passage of the California Desert Protection Act of 1994. For
examinations conducted by Park Service examiners during this period, the
Park Service estimated direct costs and some, but not all, indirect costs.
This estimate included examiners' salaries for conducting fieldwork and
writing reports, costs for travel and mineral tests, and 26 percent of the
examiners' salaries to reflect employee benefits. Table 2 shows the Park
Service's estimated total costs of about $387,000 for the seven
examinations, which ranged from about $104,000 to $21,000. Park Service
officials attributed the range in costs to the unique nature of each
examination, including the number of claims that were examined, the type of
mineral deposit, the extent and type of exploration or mining activity, and
the remoteness and accessibility of the claim site.
Table 2: Estimated Costs Associated With Seven Validity Examinations
Performed by Park Service Personnel in the California Desert Parks, Fiscal
Year 1995 Through June 1, 2000
Estimated costs Name of claimant or Number of claim group Park claims
Fieldwork Reporting Travel Testing Total
Golden Quail Mojave 16 $14,000 $83,000 $4, 000 $2, 850 $103, 850 Volco
Mojave 9 7,800 15,600 2,000 75, 250 a 100, 650 Rainbow Talc Death Valley 6
11, 500 45,200 4,000 4, 220 64, 920 Blair Mojave 7 6,400 34,600 3,000 490
44, 490 U- Thor Joshua Tree 3 3,600 23,400 1,000 450 28, 450 J. O . Death
Valley 7 10, 900 0 b 4, 000 9, 135 24, 035 Lucky Day Mojave 2 6,650 13,640 0
700 20, 990
Total 50 $60, 850 $215,440 $18,000 $93, 095 $387, 385
a A contractor performed most of the examination at a cost of about $75,000.
b The report was not written because the examination was halted when the
claimant failed to pay the maintenance fees for 1999. Source: GAO's analysis
of data provided by the Park Service.
The Park Service also provided costs for the contracts it awarded for
fieldwork and report preparation associated with the other 10 mineral
examinations it initiated at Mojave National Preserve and Joshua Tree
National Park since the passage of the California Desert Protection Act of
1994. Park Service examiners monitor these contracts, review the validity
examination reports prepared by the contractors, and develop report
conclusions and recommendations. The costs of these or other associated
services provided by Park Service personnel are not included in the contract
data the Park Service provided to us. Table 3 shows the Park Service's
contract costs totaled about $281,000 and ranged from about $57,000 to
$13,000. Again, Park Service officials attributed the range in costs to the
unique nature of each examination.
Table 3: Costs of Fieldwork and Report Preparation Associated With 10
Validity Examinations Performed by Contractors in the California Desert
Parks, Fiscal Year 1995 Through June 1, 2000
Name of claimant or claim Number of group Park claims Contract cost
Soda Lake Mojave 4 $57, 400 Barnett Mojave 8 40, 353 Moonstar Mojave 8 39,
723 Telegraph Mojave 12 28, 808 Coxcomb Eagle Joshua Tree 1 27, 126 a Oro
Fino Mojave 12 26, 813 Maxfield Mojave 19 17, 541 Gyron Mojave 1 15, 505 M.
H. B. G. #5 Mojave 1 14,088 Storm Jade Joshua Tree 1 13, 291
Total 67 $280, 648
a The examination was not completed because the Bureau declared the claim
null and void for other reasons. Source: Data provided by the Park Service.
The Park Service Is The Park Service is seeking to recover the costs of its
validity Seeking to, but Does
examinations. The Secretary of the Interior is authorized to establish
reasonable charges- or user fees- for processing documents relating to Not
Yet, Recover the
public lands. Relying on this authority, Interior's Solicitor issued an
opinion Costs of Its Validity in December 1996 concluding that the Bureau
should recover the costs of
Examinations processing mining- related documents, including plans of
operations and
the costs of validity examinations, from claimants. Because the Park Service
conducts validity examinations in national parks under its interagency
agreement with the Bureau, officials in the Solicitor's Office believe that
the Park Service should also recover these costs. This position
is consistent with Interior's policy, which states that agencies should
recover, to the extent authorized by law, the costs of activities that
provide a special benefit to a nonfederal recipient above and beyond those
benefits that accrue to the general public.
The Bureau is drafting regulations that will, among other things, require it
to recover the costs of validity examinations undertaken when claimants
submit plans of operations to begin mining. However, Park Service officials
we contacted were unaware of the Bureau's efforts in this regard until we
told them. The Park Service then initiated discussions with the Bureau and
Interior's Solicitor seeking to clarify and amend the draft regulations to
cover validity examinations performed by the Park Service. The Bureau
anticipates it will publish the draft regulations in the Federal Register
for public comment in fall 2000. The draft regulations do not specifically
provide for recovery of the cost of examinations conducted by the Park
Service. However, they leave open the possibility that the Bureau- the
agency responsible for promulgating policies on validity examinations- may,
in the final regulations, require claimants to reimburse the Bureau for both
agencies' validity examinations. The agencies would then have to establish a
means for the Park Service to recoup its costs from the Bureau,
for example, through an Economy Act transaction. 5 Officials from the
Solicitor's Office said that the Park Service, as an alternative to being
included in the Bureau's draft regulations, could issue similar regulations
of its own. However, the Park Service's position is that it would be most
expedient and efficient to the government and claimants for the Bureau to
include the Park Service in the final rule rather than having two sets of
regulations and processes for claimants to follow. The Park Service's
discretionary validity examinations- that is, examinations that are not
initiated to process and approve plans of operations submitted by claimants-
are not covered by the Bureau's draft regulation. Officials from the
Solicitor's Office said that they have not
specifically addressed whether the Park Service is authorized to recover the
costs of discretionary examinations. They and Park Service officials we
contacted were uncertain whether or not recovery for such examinations is
possible. Seven of the 17 validity examinations initiated by the Park
Service since 1994 were discretionary and were initiated by the park
superintendents. The Park Service has no internal written direction or
guidance on when to initiate such discretionary examinations. When no plan
of operations is submitted, park superintendents have broad discretion in
deciding whether
and when to initiate such validity examinations. Park officials provided a 5
The Economy Act provides authority for agencies to enter into reimbursable
agreements to furnish materials or to perform work or services.
variety of reasons for initiating these discretionary examinations,
including (1) ascertaining whether nonfederal property rights, that is, a
valid mining claim, exist in the park and (2) addressing management or
environmental problems posed by particular claims. For example:
In one case, a claimant constructed a cabin and several other structures on
the claim site and conducted some mining activities. However, the claimant
had been using the site primarily for recreational purposes for many years
before the land was designated by the Congress as Park Service wilderness.
The Park Service believes that the claimant does not have a right to occupy
the site and has initiated a validity examination. If the examination proves
that the claim is invalid and this conclusion is upheld, the Park Service
would then possess full rights to the land in
order to manage it as wilderness. In another case, the claims are in an
environmentally sensitive area, in a desert wilderness as well as on a
national natural landmark. Mining
operations here would also disturb fragile habitat for the desert tortoise,
a threatened species. The Park Service is conducting a validity examination
to determine if the claims contain a mineral deposit that is economically
valuable and meet other requirements, and thus are valid;
if not, the claims could be extinguished. Without any written direction or
guidance on initiating discretionary validity examinations, we found a wide
range of opinions within the Park Service about their appropriateness.
Several officials believe the Park Service should systematically conduct
validity examinations on all claims located in the national parks regardless
of whether claimants submit plans
of operations. These officials noted that it is important to obtain a clear
title to park lands to better protect and manage resources; it is less
expensive to do examinations in the near term, thus avoiding possible future
cost increases; and there is greater likelihood that claimants will
relinquish claims they believe have marginal value, knowing that a validity
examination will be performed. Other Park Service officials said that
validity examinations should not be conducted unless a plan of operations
has been submitted or activity on a specific claim presents a serious threat
to park resources. These officials noted that there is little or no activity
on most claims and thus they do not pose an immediate threat to park
resources; many claims of this type are likely to be relinquished over time;
examinations may prove a claim to be valid when it might have otherwise been
relinquished; and examinations themselves may disturb some park resources.
An official in Interior's Solicitor's Office said that there is no law
or regulation that requires the Park Service to generally perform
examinations other than those needed to process a plan of operations. 6
Conclusions The Park Service does not recover the costs of its validity
examinations from claimants who submit plans of operations but is beginning
to explore
the possibility. And, by not accounting for the costs of the examinations,
it is not in a position to recover the costs. Furthermore, seven of the
examinations at the three parks since 1994 were conducted at the park
superintendents' discretion, and it is uncertain whether the Park Service
can recover the costs of discretionary examinations. In addition, there is
no guidance that describes when it is appropriate for the Park Service to
conduct such discretionary examinations.
Recommendations for We recommend that the Secretary of the Interior require
that the Director
Executive Action of the Park Service develop an accurate accounting of the
costs of its validity examinations,
take steps to recover the costs of validity examinations to the extent
allowed by law, and develop guidance that describes the circumstances under
which
discretionary validity examinations- for which costs may or may not be
recoverable from claimants- are appropriately initiated.
Agency Comments We provided Interior with a draft of this report for its
review and comment. Interior agreed with the report's recommendations and
stated that the Park Service will work closely with the Bureau and other
Interior offices to
determine the most efficient and effective means to implement them.
Interior's comments are in appendix II.
To obtain data on the cost to the Park Service of conducting validity
examinations at the parks established by the California Desert Protection 6
He noted that an exception was provided in the Mining in the Parks Act of
1976, which required the Park Service to determine the validity of all
unpatented claims in Death Valley National Monument- now Death Valley
National Park- and certain other parks within 2 years of enactment.
Act of 1994, we obtained and compiled cost estimates for validity
examinations performed since 1994 (as of June 1, 2000) from Park Service
officials at the Geologic Resources Division in Denver, Colorado, and at
those parks. We discussed the development of these costs and the tasks and
time requirements for validity examinations with certified mineral
examiners. To determine whether the Park Service can recover its costs of
conducting validity examinations, we reviewed pertinent laws, regulations,
and policy and procedural manuals. We discussed these requirements with the
Chief of the Park Service's Policy and Regulations Branch of the Geologic
Resources Division, Bureau headquarters officials, and the Interior's Office
of the Solicitor headquarters officials. We also visited mining claims at
the Mojave National Preserve and Death Valley National Park and interviewed
Park Service representatives at both parks. We conducted our review from May
through August 2000 in accordance with generally accepted government
auditing standards. As requested, unless you publicly announce its contents
earlier, we plan no further distribution of this report until 30 days from
the date of this letter. At that time, we will send copies of this report to
the Honorable Jim Turner,
Ranking Minority Member, Subcommittee on Government Management, Information,
and Technology, House Committee on Government Reform; the Honorable Bruce
Babbitt, Secretary of the Interior; the Honorable Robert Stanton, Director
of the National Park Service; the Honorable Thomas Fry, Director of the
Bureau of Land Management; and other
interested parties. We will also make copies available to others upon
request.
If you or your staff have any questions about this report, please call me at
202- 512- 3841. Key contributors to this report are listed in appendix III.
Sincerely yours,
Jim Wells Director, Energy, Resources,
and Science Issues
Appendi xes Validity Examination Tasks and Time
Appendi x I
Requirements Tasks to be completed Time needed Records research 2 to 3 weeks
Check Bureau of Land Management database and claims files to determine if a
claim is administratively current. Research county records. Contact
claimants to resolve discrepancies or inconsistencies.
Preliminary literature search 2 to 4 weeks Obtain appropriate maps,
commodity data, production history, and geologic reports. Contact industry
and agency information sources.
Field examination preparation 2 weeks Send letter to claimant giving 30- day
advance notice of the field examination. Arrange logistics and travel,
develop sampling strategy, and assemble and pack field equipment and
materials.
Field examination 2 to 3 weeks Contact claimant to identify claim
boundaries, discovery points, sample points, and workings. Traverse claims
and photo- document survey claim corner and discovery monuments. Generate
map with geology, topography, surface features, and sample sites. Map,
describe, and photo- document workings. Describe geologic structures,
mineralization, ore deposit, associated mill sites and facilities. Take
samples and photo- document them, following established protocol.
Assay and laboratory analysis 2 to 8 weeks Deliver samples to assayer or
laboratory. Analyze and interpret results.
Report preparation 4 to 6 months Research literature on site geology, mining
history, exploration, Park Service documents. Research laws, Park Service
and Bureau of Land Management policies, Interior Board of Land Appeals.
Research appeal decisions, other federal and state decisions. Prepare
photos, maps, and illustrations. Prepare economic evaluation: ore volume,
assay and market analyses, and cost calculations. Prepare draft report and
obtain internal review.
Bureau of Land Management review 2 to 4 weeks Assemble and mail report for
Bureau of Land Management review. Bureau reviews report and returns for
revision.
Edits, corrections, and final Bureau approval 2 to 4 weeks Revise draft and
return for second Bureau review. Finalize and mail to Bureau and claimant.
Total time needed 8 to 13 months
Comments From the Department of the
Appendi x II Interior
Appendi x I II
GAO Contacts and Staff Acknowledgments GAO Contacts Barry T. Hill, (202)
512- 3841 Sue Ellen Naiberk, (303) 572- 7357 Acknowledgments In addition to
those named above, Arleen L. Alleman, Brian W. Eddington,
Richard P. Johnson, William J. Temmler, and William F. Wright made key
contributions to this report.
(141453) Lett er
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GAO United States General Accounting Office
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Contents
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Page 3 GAO/ RCED- 00- 265 National Park Service United States General
Accounting Office
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Appendix I
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Appendix II
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Appendix III
United States General Accounting Office Washington, D. C. 20548- 0001
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