Federal Land Management: Appraisal of Crown Butte Mines' New World
Property (Letter Report, 05/29/98, GAO/RCED-98-209).

Pursuant to a legislative requirement, GAO reviewed the appraisal of
Crown Butte Mines, Incorporated's New World property, focusing on: (1)
whether it complied with federal appraisal standards and and how the
value of the appraisal was derived; and (2) key assumptions used in the
appraisal.

GAO noted that: (1) GAO did not identify any areas in which the
appraisal of Crown Butte Mines' New World property interests deviated
from federal appraisal standards; (2) federal appraisal standards state
that the government should appraise a property to be acquired at its
fair market value; (3) the appraiser relied on two approaches to derive
this fair market value: (a) evaluating comparable sales; and (b)
estimating the gross income from future mining operations and adjusting
this amount to the present value of the reserves in the ground; (4)
following these standards led the appraiser to estimate the value of the
property at $72 million and reduce this amount by about $3 million to
account for reserved mining royalty interests granted by Crown Butte to
a third party and a conservation easement limiting mining on parts of
the property; (5) GAO's work found that four key assumptions made during
the appraisal process tended to raise the value of the appraisal; and if
other assumptions were used, the appraised value might have been lower;
(6) GAO does not, however, question the reasonableness of the
assumptions made; (7) in particular, the appraisal assumed that: (a)
mineral rights associated with a portion of the property subject to a
conservation easement have no value because the easement will prevent
mineral development; (b) the mining operations that Crown Butte had
planned would have been issued permits by state and federal agencies in
a timely manner; (c) known hazardous waste conditions would not affect
the property's value; and (d) Crown Butte's estimate of gold reserves is
valid; (8) GAO did not estimate the specific monetary impact of these
assumptions; (9) however, GAO believes these assumptions could have
tended to increase the appraised value in comparison with the value that
would have been estimated using others; (10) for example, if permits had
been delayed for a year, the present appraised value would have been
lower; (11) the appraiser noted that the appraisal could not have been
completed without making assumptions to address these issues; and (12)
GAO does not believe that use of these assumptions invalidates the
appraisal estimate.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  RCED-98-209
     TITLE:  Federal Land Management: Appraisal of Crown Butte Mines' 
             New World Property
      DATE:  05/29/98
   SUBJECT:  Mining
             Mineral resources
             Mineral bearing lands
             Land transfers
             Appraisals
             Fair market value
             Economic analysis
IDENTIFIER:  Yellowstone National Park (WY)
             Gallatin National Forest (MT)
             New World Mine Project (MT)
             
******************************************************************
** This file contains an ASCII representation of the text of a  **
** GAO report.  Delineations within the text indicating chapter **
** titles, headings, and bullets are preserved.  Major          **
** divisions and subdivisions of the text, such as Chapters,    **
** Sections, and Appendixes, are identified by double and       **
** single lines.  The numbers on the right end of these lines   **
** indicate the position of each of the subsections in the      **
** document outline.  These numbers do NOT correspond with the  **
** page numbers of the printed product.                         **
**                                                              **
** No attempt has been made to display graphic images, although **
** figure captions are reproduced.  Tables are included, but    **
** may not resemble those in the printed version.               **
**                                                              **
** Please see the PDF (Portable Document Format) file, when     **
** available, for a complete electronic file of the printed     **
** document's contents.                                         **
**                                                              **
** A printed copy of this report may be obtained from the GAO   **
** Document Distribution Center.  For further details, please   **
** send an e-mail message to:                                   **
**                                                              **
**                                            **
**                                                              **
** with the message 'info' in the body.                         **
******************************************************************


Cover
================================================================ COVER


Report to Congressional Committees

May 1998

FEDERAL LAND MANAGEMENT -
APPRAISAL OF CROWN BUTTE MINES'
NEW WORLD PROPERTY

GAO/RCED-98-209

Federal Land Management

(141198)


Abbreviations
=============================================================== ABBREV

  EIS -

Letter
=============================================================== LETTER


B-280072

May 29, 1998

Congressional Committees

In Public Law 105-83, the Congress authorized and appropriated up to
$65 million to acquire mining interests held by Crown Butte Mines,
Inc., its New World property, which is located near Yellowstone
National Park.  Before the acquisition can occur, however, the law
requires that four conditions be met, including that the property be
appraised and that the Comptroller General review the appraisal
within 30 days.  The Crown Butte interests are located on land in the
Gallatin National Forest, and the land will be managed by the
Department of Agriculture's Forest Service once it has been appraised
and acquired; for this reason, the Forest Service arranged for the
appraisal.  We received the completed appraisal on April 30, 1998,
and this report presents the results of our review. 

Specifically, we reviewed the appraisal to (1) determine whether it
complied with federal appraisal standards and how the value of the
appraisal was derived and (2) assess key assumptions used in the
appraisal.  To do this work, we reviewed federal appraisal standards
and instructions and the appraisal itself and discussed the key
assumptions with the appraiser, Forest Service officials, Department
of Justice officials, and outside experts.  In the limited time
available to us, we reviewed only the summary appraisal report and
not the technical appendixes, proprietary data, or supporting
analyses that accompanied the summary or were used in developing it. 


   RESULTS IN BRIEF
------------------------------------------------------------ Letter :1

We did not identify any areas in which the appraisal of Crown Butte
Mines' New World property deviated from federal appraisal standards. 
Federal appraisal standards state that the government should appraise
a property to be acquired at its fair market value.  We found that
the appraiser relied on two approaches to derive this fair market
value:  (1) evaluating comparable sales and (2) estimating the gross
income from future mining operations and adjusting this amount to the
present value of the reserves in the ground.  Following these
standards led the appraiser to estimate the value of the property at
$72 million and reduce this amount by about $3 million to account for
reserved mining royalty interests granted by Crown Butte to a third
party and a conservation easement limiting mining on parts of the
property. 

Our work found that four key assumptions made during the appraisal
process tended to raise the value of the appraisal; and if other
assumptions had been used, the appraised value might have been lower. 
We do not, however, question the reasonableness of the assumptions
made.  In particular, the appraisal assumed that (1) mineral rights
associated with a portion of the property subject to a conservation
easement have no value because the easement will prevent mineral
development, (2) the mining operations that Crown Butte had planned
would have been issued permits by state and federal agencies in a
timely manner, (3) known hazardous waste conditions would not affect
the property's value, and (4) Crown Butte's estimate of gold reserves
is valid.  We did not estimate the specific monetary impact of these
assumptions.  However, we believe these assumptions could have tended
to increase the appraised value in comparison with the value that
would have been estimated using others.  For example, if permits had
been delayed for a year, the present appraised value would have been
lower.  The appraiser noted that the appraisal could not have been
completed without making assumptions to address these issues.  We do
not believe that the use of these assumptions invalidates the
appraisal estimate. 


   BACKGROUND
------------------------------------------------------------ Letter :2

Crown Butte Mines, Inc., applied for a permit to construct and
operate a mine--to produce gold, silver, and copper--in the New World
mining district in November 1990.  Located about 3 miles from the
northeast boundary of Yellowstone National Park, the New World mining
district has had mining activity since the 1860s.  Facing increasing
opposition to the proposed project over concerns for the park's water
quality and other resources, in August 1996 Crown Butte and the
federal government agreed to exchange Crown Butte's New World
property for up to $65 million in federal assets (subject to an
appraisal that the property has a fair market value of at least this
amount).\1 Of this amount, $22.5 million is to be placed in an escrow
account to fund environmental response and restoration in the
district, which, according to Department of Justice officials, the
United States will direct.  Any cost above the $22.5 million will be
borne by the United States.  The federal government plans to
permanently withdraw any lands acquired from subsequent mineral
development. 

The Congress, in its fiscal year 1998 appropriation for the
Department of the Interior and related agencies, authorized and
appropriated up to $65 million for Crown Butte's New World
property.\2 We noted in a report last year that there was uncertainty
about the property's fair market value, and the Congress subsequently
required that it be appraised before it is acquired by the Secretary
of Agriculture.\3 According to the law's conference report, the
appraisal must be done in compliance with federal appraisal standards
and other applicable laws and regulations governing federal land
acquisitions.  According to the law, the appraisal must be reviewed
by the Comptroller General within 30 days of receiving the appraisal
from the Department of Agriculture and must be provided to the list
of committees in the mandate.  Separately, as Chairmen of the
Subcommittees on Interior and Related Agencies, Senate and House
Committees on Appropriations, you also requested that we do this
work. 

The Forest Service entered into a contract with an appraiser to
determine the property's value as of the date of the
agreement--August 1996--and expected the appraisal to be completed in
early March 1998.  This schedule was extended to allow time to review
extensive additional information provided by the company--a task that
the appraiser hired two subcontractors to do.  After the appraisal
was reviewed and approved by the Chief Appraiser of the Forest
Service as meeting federal appraisal standards, and accepted by the
Forest Service, it was forwarded to us on April 30, 1998. 

The appraisal covers the mineral interests that Crown Butte owns and
leases on private property in the Gallatin National Forest, totaling
101 separate mining parcels\4 that cover about 1,625 acres.  All of
these parcels were mining claims that were patented under the Mining
Law of 1872, which means the owners have title to the property and
are entitled to use the surface and subsurface lands for any purpose. 
Of the 101 parcels, the company owns or has a part-ownership interest
in 44 parcels covering about 694 acres, leases from an individual 47
parcels covering about 756 acres, and jointly owns with the same
individual 10 parcels covering about 175 acres. 

The appraisal established a value for the property of $69,076,000 as
of August 12, 1996, the date of the agreement to acquire the property
from Crown Butte.  Under the terms of the agreement, Crown Butte was
to acquire title to the 57 parcels owned in full or in part by the
individual.  Crown Butte was subsequently unable to do so and instead
paid the owner to acquire a conservation easement for these lands. 
Under the terms of the conservation easement, the owner retains title
to the property but is prevented from developing if for mining.  The
appraised value includes a reduction of about $1 million to reflect
this situation. 


--------------------
\1 A third party to the exchange agreement is the Greater Yellowstone
Coalition, a coalition of environmental groups.  The coalition agreed
to settle its legal action against Crown Butte and not to pursue
legal action against the federal government for certain environmental
effects of previous mining in the New World district.  Acceptable
exchange lands could not be found; therefore, Crown Butte agreed to
accept a cash payment for the property. 

\2 Department of the Interior and Related Agencies Appropriations
Act, 1998 (P.L.  105-83). 

\3 Federal Land Management:  Estimates of Value and Economic Effects
of the New World Mine Project (GAO/RCED-97-232R, Sept.  9, 1997). 

\4 These parcels are referred to in the appraisal report as patented
mining claims. 


   APPRAISAL STANDARDS AND RESULTS
------------------------------------------------------------ Letter :3

In its contract for the Crown Butte appraisal, the Forest Service
instructed the appraiser to follow federal appraisal standards in
valuing the property.\5 These standards state that the government
should appraise a property to be acquired at the fair market value. 
According to the standards, fair market value is the amount for which
a property would be sold--for cash or its equivalent--by a willing
and knowledgeable seller who is not obligated to sell to a willing
and knowledgeable buyer with no obligation to buy.  According to the
Forest Service's Chief Appraiser, the appraisal of natural resources,
particularly mineral deposits, is imprecise because measuring the
extent of mineral deposits is difficult.\6 Furthermore, he stated an
appraised value can vary by 10 percent yet still reflect the market
value of the property. 

The standards provide for several methods of determining fair market
value, including analyzing prior sales of comparable properties or of
the property itself.  While the standards indicate that the use of a
sales comparison approach is normally the most accurate method, they
also provide that property containing known minerals may be appraised
using the income approach.  The income approach involves estimating
the value of a resource on the basis of the present value of
anticipated future income from production, including income such as
royalties (a percentage of the value of the minerals produced that is
paid to the lease owner).  Generally, the income method values the
estimated future income stream from a project and adjusts the value
of this income stream to its value today by using a discount rate.\7

In cases in which the government does not acquire a full property,
but acquires only a piece of it, federal appraisal standards state
the preferred way to value the partial property is to use a "before
and after" method.  In this method, the appraiser estimates the value
of the whole property before the transaction and reduces it by the
value of the property remaining in private ownership after the
transaction is completed.  The Forest Service's instructions directed
the appraiser to estimate a single value for the Crown Butte
property, using a "before and after" method to account for the
portion of the property remaining in private ownership under the
conservation easement.  As a result, the appraiser assumed that the
use of the property before acquisition would have been mining and
that the use of the private land left after the acquisition will be
for recreational purposes such as cross-country skiing, hunting, and
snowmobiling. 


--------------------
\5 Uniform Appraisal Standards for Federal Land Acquisitions,
Interagency Land Acquisition Conference (1992) and Uniform Standards
of Professional Appraisal Practice, The Appraisal Foundation (1998). 

\6 The preferred method for measuring a mineral deposit is based on
exploratory drilling, which provides a partial picture of the
deposit.  Extrapolations from this information are made as to the
size of the deposit.  This method was used on the New World property. 

\7 A discount rate reflects the earning power of money over time and
the risk associated with this earning.  The choice of a discount rate
is a key factor in determining net present value--in effect, the
lower the discount rate, the higher the net present value of an
asset. 


      ESTIMATE OF CROWN BUTTE
      PROPERTY'S VALUE
---------------------------------------------------------- Letter :3.1

To determine the value of the property before acquisition, the
appraiser estimated the fair market value of the property as required
in federal standards, assuming it would be developed for the proposed
mine.  In establishing the fair market value, the appraiser
considered four approaches--resulting in a range of values between
$70 million and $79 million--but relied on two in making his final
estimate:  a sales comparison approach, as allowed under the federal
appraisal standards, and a bulk sale discount approach, which the
appraiser stated, and the Forest Service's Chief Appraiser confirmed,
is an income method developed specifically for mineral properties. 
The appraiser concluded, on the basis of the results of the two
approaches, that the value before acquisition was $72 million. 

Under the sales comparison approach, the appraiser estimated the
price paid per ounce of gold in other mine sales, including one prior
sale of the New World property.  He derived these estimates from
sales prices and reserve estimates for the properties.  He then
applied the estimated prices per ounce for the prior sale of the New
World property and the sale that he judged most comparable to the
estimated reserves for the New World property to obtain an appraised
value for this property.  Under the bulk sale discount approach, the
appraiser used data on prior sales to calculate for each the ratio of
the sales price to the potential retail income from the estimated
gold reserves on that property.  He inferred from these ratios,
particularly the ratio for the most comparable sale, a comparable
ratio for the New World property.  He then applied that ratio to the
estimate of potential retail income from the New World property to
estimate the likely sales price. 

The appraiser then made two adjustments that reduced the $72 million
value to the appraised value of $69,076,000.  The first adjustment
reflects a royalty interest owned by Kennecott Corporation for its
interest in several claims.  This money would have been paid from
future income from the proposed mine.  The appraiser discounted the
proposed mine's projected cash flow and estimated the present value
of the outstanding debt to be $1,900,000.  The second adjustment
reflects the restrictions imposed by the conservation easement on the
private lands.  The appraiser assumed that 931 acres--those acres
associated with property owned by the individual--would remain in
private ownership and could be used only for recreational activities,
in accordance with the terms of the easement.  Accordingly, the
appraiser identified comparable sales of land for recreational use
and reduced the Crown Butte appraisal by $1,024,000. 


   KEY ASSUMPTIONS USED
------------------------------------------------------------ Letter :4

In estimating the fair market value of the proposed mine, the
appraisal relied on several assumptions that could have tended to
overstate the appraised value.  In general, the need to make
assumptions about key unknown factors increases the uncertainty
associated with any estimate of appraised value.  Although we have
not determined the cumulative effect of relying on these assumptions,
it appears to us that they would tend to increase the appraised value
compared to the value that might have been obtained with different
assumptions.  The key assumptions made in the appraisal were that (1)
mineral rights associated with the private property have no value
because the conservation easement prevents mineral development; (2)
the mine would have been issued permits to commence operations in a
timely manner; (3) hazardous waste conditions would not affect the
property's value; and (4) Crown Butte's revised estimate of gold
reserves is valid. 


      APPRAISER ASSUMED MINERAL
      RIGHTS ON PRIVATE PROPERTY
      HAVE NO VALUE
---------------------------------------------------------- Letter :4.1

The "before and after" method used in the appraisal relied on the
assumption that the mineral rights still attached to private property
have no value because of the conservation easement.  Specifically,
the value before the transaction reflects full ownership of all
mineral rights attached to both the Crown Butte and private
properties.  The appraised value after the transaction includes an
adjustment for the value of the property to remain in private
ownership, including the mineral rights attached to that property,
but assumes the value of the minerals would be zero.  While the
minerals' value may be decreased by the easement's restriction on
development, at the same time, the private owner, not the government,
retains rights to the minerals.  Yet the appraised value was not
decreased to reflect the value of this asset retained by the private
owner.  If the appraiser had included some value for the mineral
rights to remain in private ownership, this would have increased the
amount of the adjustment to the appraised value.  For this reason, we
believe the appraised value may be overstated.  However, according to
the appraiser, it was not possible to value the mineral rights
retained with the private property without more potentially costly
drilling information about the individual claims held by the private
owner as compared with those held by Crown Butte. 


      GOVERNMENT ASSUMED MINE
      OPERATIONS WOULD HAVE BEEN
      ISSUED PERMITS
---------------------------------------------------------- Letter :4.2

The appraisal also relied on the assumption that the New World mine
would have received the required governmental permits and been able
to commence operations in a timely manner--or, in the words of the
appraisal, it assumed that permits were a "non-factor." Mine
operators are required to apply for and receive various permits prior
to mining, including mine and water quality permits.  In addition,
the proposed mine would have been subject to environmental protection
laws, which require an environmental impact statement (EIS) for such
activities.  According to a Forest Service official, at the time of
the agreement, Crown Butte had submitted its mine development plan
and permit applications for four of its five deposits, and they were
expected to be approved.  According to the official, an application
to mine the fifth deposit also probably would have been approved if
submitted.  However, neither the permit process nor the EIS was
finished at the time of the agreement and could have taken years.  We
believe the net present value of future income from the mine would
have been lower if delays had occurred.  If the appraiser had
assumed, for example, a 1-year delay in obtaining permits, he would
have obtained a lower appraised value. 


      GOVERNMENT ASSUMED KNOWN
      HAZARDOUS WASTE WOULD NOT
      AFFECT VALUE
---------------------------------------------------------- Letter :4.3

A third assumption in the appraisal was that the known hazardous
waste on the property would not affect its value.  Prior to the 1996
agreement, a federal court decision held Crown Butte liable for Clean
Water Act violations related to acidic runoff from historic mining
operations on the site.  According to Department of Justice
officials, a new owner of the property would be responsible for these
conditions.  The appraiser disclaimed responsibility for determining
any problems associated with hazardous waste conditions that might
exist on the property.  He stated he could have included a value for
such costs if one had been provided but emphasized that because the
property was going to be developed as a mine, he would not have
reduced the appraised value by the full amount of these costs.  He
stated that some of these costs would have been treated as a cost of
doing business (operating costs).  A Forest Service official stated
the appraisal could not include speculations about the potential
cleanup costs or the impact of these costs on the economic
feasibility of the proposed mine and the value of the property. 
Since the responsibility for the hazardous waste conditions resides
with the property's owner, the appraised value did not reflect the
extent to which the value would be diminished by these conditions. 
But if the appraiser had been provided the amount of estimated costs
to clean up the property, the appraised value could have been reduced
by some amount. 


      APPRAISER ASSUMED CROWN
      BUTTE'S ESTIMATE OF GOLD
      RESERVES IS VALID
---------------------------------------------------------- Letter :4.4

Finally, the appraisal assumed that an updated estimate of gold
reserves provided by Crown Butte was valid, even though the appraiser
reported that the revised estimate used optimistic assumptions and
unverified data.  Crown Butte estimated a reserve level of 3,003,000
ounces of gold in the proposed mine, whereas earlier mining plans
indicated reserves ranging from less than 700,000 ounces to about
1,600,000 ounces of gold.  This difference results from Crown Butte's
additional analysis of data from exploratory and development
drilling, lower projected operating costs, and the inclusion of
possible reserves.  However, the appraiser's own analysis of the
likely costs of operating a gold mine at the New World property
suggests that a smaller figure for gold reserves should have been
used for appraising the property.  The appraiser told us that he used
Crown Butte's estimate in the appraisal but that he adjusted the
price per ounce of gold downward to account for the possible
overstatement.  However, we could not determine whether his
adjustment counterbalanced the use of the overstated reserves. 


   OBSERVATIONS
------------------------------------------------------------ Letter :5

In our review of the Crown Butte appraisal we did not identify areas
in which the appraisal deviated from federal appraisal standards. 
The appraisal was based on several assumptions, however, and the need
to rely on these assumptions increased the uncertainty of the
appraised value.  Although we could not determine how much the
assumptions affected the value, they tended to increase the value in
comparison to the value that would have been estimated using
different assumptions.  However, given the imprecision involved with
appraising mineral properties, we did not find that the use of these
assumptions was unreasonable. 


   AGENCY COMMENTS
------------------------------------------------------------ Letter :6

We provided the Forest Service with a draft of this report for review
and comment.  In its comments, the Forest Service said that, overall,
it concurred with the report.  However, it expressed concern about
the wording and possible misinterpretation of the assumption made by
the appraiser that mineral rights for the portion of the Crown Butte
property under a conservation easement have no value.  Specifically,
the Forest Service was concerned that the report gave the impression
that the federal government may be paying for an interest in a
property that has no value and that the conservation easement cannot
effectively prevent mining.  As stated in our draft report, the
appraiser indicated he could not value the mineral rights retained
with the private property without more potentially costly drilling
information.  It was not our intention to say this portion of the
property has no value or that the conservation easement will not
prevent mining.  However, what we are pointing out is that if the
government decides to remove the conservation easement and allow
mining, the benefit would go to the owner of the mineral rights, not
the government.  (The Forest Service's comments are reproduced in
app.  I.)


   SCOPE AND METHODOLOGY
------------------------------------------------------------ Letter :7

We reviewed the Uniform Appraisal Standards for Federal Land
Acquisitions, issued in 1992 by the Interagency Land Acquisition
Conference, as well as the Uniform Standards of Professional
Appraisal Practice issued in 1998, to become familiar with federal
appraisal standards, and we reviewed the appraisal itself, Crown
Butte Mine New World Project:  Complete Appraisal--Summary Appraisal
Report, signed April 23, 1998, to become familiar with its
methodology and data.  We discussed both the standards and the
appraisal with the Chief Appraiser and a field review appraiser of
the Forest Service and the contract appraiser who conducted the
appraisal.  We interviewed an outside gold expert, officials with the
Nature Conservancy, and other agency officials.  We also met with the
Department of Justice, which provided legal counsel to the Forest
Service regarding the appraisal process. 

In a December 1997 letter to the Secretary of Agriculture, you
recommended that the Department of Agriculture coordinate the
appraisal process with us in advance of our receiving the final
appraisal.  While the Chief Appraiser of the Forest Service did
apprise us of the status of the appraisal process before we received
the final appraisal on April 30, he declined to provide us any
analyses or drafts of the appraisal before that date because this
information was subject to review and change. 

We performed our review in May 1998 (and did some preliminary work in
January and February 1998) in accordance with generally accepted
government auditing standards.  We are sending copies of this report
to the appropriate congressional committees, the Secretary of
Agriculture, and other interested parties.  We will also make copies
available to others upon request. 


---------------------------------------------------------- Letter :7.1

If you or your staff have any questions, please call me on (202)
512-3841.  Major contributors to this report were Jay Cherlow, Tim
Guinane, Susan Iott, Diane Lund, Dick Kasdan, Mehrzad Nadji, Sue
Naiberk, and Victor Rezendes. 

Sincerely yours,

Barry T.  Hill
Associate Director, Energy,
 Resources, and Science Issues


List of Congressional Committees

The Honorable Ted Stevens
Chairman
The Honorable Robert Byrd
Ranking Minority Member
Committee on Appropriations
United States Senate

The Honorable Frank H.  Murkowski
Chairman
The Honorable Dale Bumpers
Ranking Minority Member
Committee on Energy
 and Natural Resources
United States Senate

The Honorable Slade Gorton
Chairman
The Honorable Robert Byrd
Ranking Minority Member
Subcommittee on Interior
 and Related Agencies
Committee on Appropriations
United States Senate

The Honorable Bob Livingston
Chairman
The Honorable David Obey
Ranking Minority Member
Committee on Appropriations
House of Representatives

The Honorable Don Young
Chairman
The Honorable George Miller
Ranking Minority Member
Committee on Resources
House of Representatives

The Honorable Ralph Regula
Chairman
The Honorable Sidney R.  Yates
Ranking Minority Member
Subcommittee on Interior
 and Related Agencies
Committee on Appropriations
House of Representatives




(See figure in printed edition.)Appendix I
COMMENTS FROM THE FOREST SERVICE
============================================================== Letter 



(See figure in printed edition.)



(See figure in printed edition.)


*** End of document. ***