[Final Audit Report on Bureau of Land Management Implementation of the Southern Nevada Public Land Management Act (Report No. 2003-I-0065)]
[From the U.S. Government Printing Office, www.gpo.gov]

Title: Final Audit Report on Bureau of Land Management Implementation
       of the  		Southern Nevada Public Land Management Act (Report
       No. 2003-I-0065) 

September 30, 2003

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calling the Office of Inspector General, Division of Acquisition and Management Operations at 
(202) 219-3841. 
******************************
										
September 30, 2003                                                                                                 September 30, 2003
7430


        
Memorandum										 
											
To:		Director, Bureau of Land Management

From:		Michael P. Colombo
		Regional Audit Manager

Subject:	Final Audit Report on Bureau of Land Management Implementation of the 
		Southern Nevada Public Land Management Act (Report No. 2003-I-0065)

      The attached report presents the results of our review of the Bureau of Land 
Managementï¿½s (BLM) implementation of the Southern Nevada Public Land Management 
Act (SNPLMA).  SNPLMA was enacted in 1998 to allow BLM to dispose of public land 
in southern Nevada through public auction and to use the receipts for education and 
environmental purposes and capital improvements in the State of Nevada.  Our objective 
was to review certain operational aspects of the SNPLMA Project Office since its 
inception, including its management of the land sale program; its efforts to monitor and 
preserve BLMï¿½s interest in land transferred to Clark County, Nevada; and its 
administration of receipts and disbursements from the special U.S. Treasury account 
authorized by SNPLMA.  Please see the appendix to the attached report for a summary of 
our audit scope and methodology.
      
      We undertook our review because of news articles and inquiries from individuals 
who were concerned about Clark Countyï¿½s use of lands transferred under SNPLMA and 
the Countyï¿½s acceptance of the best offer in lieu of a higher offer for some of the lands 
exchanged.  Our General Counsel concluded that under Nevada statutes it was legally 
defensible for Clark County to accept either the highest offer or an offer that allowed the 
County to meet its priority of limiting incompatible development near the airport.   

	We are pleased to report that BLM has made great strides in implementing 
SNPLMA.  Specifically, BLM has established a SNPLMA Project Office; formed good 
working relationships with the federal, state, and local governmental agencies necessary 
to implement SNPLMA; transferred about 5,200 acres of public land to Clark Countyï¿½s 
Department of Aviation; implemented a successful land sales program; and established a 
special U.S. Treasury account to manage land sales and other SNPLMA receipts.  



	The success of the land sales program confirms the value of using competitive 
sales to let the market place set the price of the land to be sold.  Partnerships with local 
government agencies to nominate federal lands to be sold contributed to BLMï¿½s success


because only lands desired for development were offered for sale.  In addition, BLM 


officials acknowledged that a volatile real estate market with more bidders than land, 
such as the market in the Las Vegas Valley, significantly contributed to the success of the 
program.  We believe that selling federal land through public auctions, as advocated in 
SNPLMA, expedites the disposal of federal lands and provides full and open competition 
to the private sector, thereby generating the greatest monetary return to the taxpayer (see 
following tabulation). 
 



Acres Offered 
for Sale


Acres 
Sold

Appraised 
Value 
($ million)

Estimated 
Sale Receipts
($ million*) 
Estimated
Receipts In Excess Of 
Appraised Value
($ million)

3,951


3,897 

$222.9 

$333.4 

$110.5 
* As of March 31, 2003, collections totaled $189.6 million.  An additional $143.8 million is scheduled for
   collection by July 31, 2003.  Receipts do not include results of June 5, 2003 sales. 
 

	We found that BLM has developed and maintained good controls both to account 
for and disburse the receipts derived primarily from the sale of federal land.  We noted, 
however, that the Project Office needed to improve its controls over administrative 
expenses, such as salaries, and believe that BLMï¿½s Nevada State Office should exercise 
stringent oversight over these expenses.  While the instances and amounts of questionable 
charges we tested during fiscal year 2002 were relatively small, we are concerned that the 
growing balance in the special U.S. Treasury account and the expansion of the SNPLMA 
program by recently passed legislation may increase the risk of abuse.  For example, 
within the near future, the Project Office will gross in excess of $1 billion from federal 
land sales and other receipts related to the use of land transferred to Clark Countyï¿½s 
Department of Aviation.  We believe that such large sums could represent a serious 
temptation for BLM managers to use part of these monies to supplement their budgets.  
We discussed our concerns with BLMï¿½s State Director and Associate State Director for 
Nevada, who agreed that effective fund control would be implemented and enforced by a 
Project Office business manager reporting directly to the Nevada State Office.  
      
	We also advised that the Project Office should finalize an enforceable operating 
agreement with Clark Countyï¿½s Department of Aviation to delineate respective 
responsibilities for complying with SNPLMA provisions regarding the disposition of the 
5,200 acres of land.





	The legislation, as amended, creating the Office of Inspector General requires that 
we report to Congress semiannually on all audit reports issued, actions taken to 
implement our audit recommendations, and recommendations that have not been 
implemented.  	We especially appreciate the cooperation shown by BLM staff during our
review.  A response to this report is not required.  However, if you have any questions 
regarding the report, please call me at (916) 978-5653.  

Attachment

cc:  Audit Liaison Officer, Bureau of Land Management (MS 1000 L Street)











Las Vegas, one of the fastest growing cities in the United 
States, is landlocked by federal lands.  Over the past 
decade, the population has increased by more than 60,000 
people per year.  To accommodate this rapid growth and 
expedite the disposal of federal land, Congress enacted 
SNPLMA in 1998 (Public Law 105-263, 31 USC 6901). 

SNPLMA allows BLM to sell federal land (about 27,000 
acres) primarily through public auctions, establish a special 
U.S. Treasury interest-bearing account, and use the 
resulting receipts for educational and environmental 
purposes and capital improvements.  In addition, SNPLMA 
directed BLM to transfer ownership of about 5,200 acres of 
land in the McCarran Airport Cooperative Management 
Area (CMA) to Clark County to help the County enforce 
regulations concerning airport noise within the CMA.  
BLM is entitled to 85 percent of any receipts from the sale, 
lease, or other conveyance of CMA lands.   

As of March 31, 2003, SNPLMA has generated 
$262.8 million.   By July 31, 2003, an additional 
$143.8 million representing final payments from the 
November 2002 live auction and the January 2003 Internet 
auction is scheduled to be collected.  By July 31, 2003, 
SNPLMA will have generated at least $406.6 million (see 
Figure 1). 
  
 
                                                               Figure 1

Under SNPLMA, state and local governments get ï¿½first 
pickï¿½ of available land for public purposes, and BLM and 
the applicable unit of local government jointly select the 
lands to be offered for sale.  SNPLMA provides an 
opportunity for anyone, not just select private parties with a 
successful track record for completing land exchanges with 
federal agencies, to purchase federal land and lets the 
market place set the price of the land to be sold through 
competitive sales.  It allows BLM to privatize federal land 
around the Las Vegas Valley to facilitate community 
growth. 
	
 


Selling federal lands (primarily by auction) has generated 
$197.8 million of the $262.8 million.  Receipts from land 
sales are distributed as follows:  5 percent to the State of 
Nevada for use in general education, 10 percent to the 
Southern Nevada Water Authority, and 85 percent to a 
special U.S. Treasury account that is managed by BLMï¿½s 
national business center.  The distribution of land sales 
receipts as of March 31, 2003, is shown in Figure 2. 


 


With the Secretaryï¿½s approval, receipts deposited into the 
special U.S. Treasury account can be used for the 
following:  

>	To purchase environmentally sensitive lands in the 
State of Nevada. 

>	To pay for capital improvements at the Lake Mead 
National Recreation Area; the Desert National 
Wildlife Refuge; the Red Rock Canyon National 
Conservation Area; and other areas administered by 
BLM in Clark County, including parks, trails, and 
natural areas.  

>	To develop a multi-species habitat conservation 
plan.  

Of the reported $220.5 million  deposited in the special 
U.S. Treasury account, $23 million has been expended and 
$85.2 million obligated or set aside to pay for land, capital 
improvements, and habitat conservation plans; $6 million 
has been expended for administrative expenses; and 
$5.8 million has been reserved for acquiring environmental 
lands at Lake Tahoe.  The remaining $100.5 million is 
available to be expended in accordance with SNPLMA. 




Although more work remains to be done, BLM has done a 
good job of implementing SNPLMA in a businesslike 
manner.  It has established a Project Office; forged 
effective partnerships with federal, state, and local 
governmental agencies; implemented a successful land 
sales program validating the competitive sales approach; 
transferred 5,200 acres of federal land to Clark Countyï¿½s 
Department of Aviation in a timely manner; and established 
and effectively administered a special U.S. Treasury 
account.  We noted, however, that the Project Office needs 
assistance from the Nevada State Office in controlling 
inappropriate assessments for operational or administrative 
expenses, such as salaries, against the special U.S. Treasury 
account.  The Project Office also needs to finalize an 
operating agreement with Clark Countyï¿½s Department of 
Aviation, which delineates respective responsibilities for 
complying with SNPLMA provisions. 

SNPLMAï¿½s Project Office and BLMï¿½s national business 
center have worked together to develop and maintain good 
controls in accounting for and disbursing the receipts 
derived from federal land sales.  The business centerï¿½s 
senior operations accountant worked with SNPLMAï¿½s 
business manager, certified collection officers, realty 
specialists, General Services Administration personnel, and 
BLM law enforcement rangers to provide good 
accountability over sales receipts, disbursements for 
program purposes, and interest earned from SNPLMA 
receipts.  

The success of the land sales program established by the 
Project Office validates a competitive approach as the best 
means of disposing of federal land.  Thus far, the program, 
which lets the market place set the price of land through 
live or online Internet auctions, has garnered about 
$333 million for the federal land sold.   From November 
1999 through March 31, 2003, the Project Office, in 
coordination with the General Services Administration, 
completed seven live and five online auctions.  In many 
cases, the highest bid for a parcel of land exceeded its 
appraised value.  BLM records indicated that the appraised 
value of the 3,897  acres sold was $223 million, yet the 
acres sold for $333 million or $110 million over their 
appraised value (see following table).  
Auction 
Date*
Acres
Sold
Appraised 
Value

Sales Price
Amount over 
Appraised Value
Nov 99
105
$7,855,500
$9,478,500
$1,623,000
Jun 00
110.16
13,812,500
15,079,000
1,266,500
Nov 00
198.05
18,742,500
20,807,000
2,064,500
May 01
2,015.50
53,013,000
62,170,501
9,157,501
Nov 01
131.20
10,665,000
14,326,110
3,661,110
Jul 02
210
22,382,500
31,610,000
9,227,500
Nov 02
1,127.50
96,431,450
179,916,500
83,485,050
Totals:
3,897.41
$222,902,450
$333,387,611
$110,485,161













BLM officials told us that the partnerships established with 
local agencies to nominate land for sale have reduced the 
risk of trying to sell lands that are not desirable.  BLM 
officials also acknowledged that the success of the land 
sales program is due to the high demand for federal land in 
an upward spiraling, volatile real estate market with more 
bidders than land.  Receipts from each auction exceeded 
appraised values, and the November 2002 auction alone 
exceeded appraised values by almost 90 percent (see 
Figure 3):

	 
                                                         Figure 3
BLMï¿½s emphasis on customer service also contributed to 
the success of the land sales program.  For example, BLM 
designed Web pages and pamphlets to keep its customers 
and prospective bidders informed of critical land sale 
information, such as general auction procedures, terms of 
sale, eligibility of bidders, procedures for bidding, and 
daily bidding results for online auctions.  

We believe that the success of the land sales program 
confirms the value of the competitive sales approach 
advocated by proponents of SNPLMA in disposing of 
federal land and generating the greatest return to the 
taxpayer.  To illustrate, in the November 2002 live and 
follow-up Internet auctions, BLM sold 1,127.50 acres of 
land for about $180 million to 26 private parties.  The 
appraised value of the land was about $96 million.  One 
investor group alone purchased 992.5 acres of land in three 
separate transactions for $159.1 million.  Appraised value 
of the acres was about $81.8 million.   

The competitive sales approach contrasts sharply with 
previous BLM practices of disposing of federal land 
primarily through exchanges to select groups and using 
appraisals to establish the market value of the lands to be 
exchanged.  Past General Accounting Office (GAO) and 
Office of Inspector General reports have criticized this 
method and questioned whether the appraisals resulted in 
lands being conveyed at lower values than those established 
by competitive sales.  To illustrate, GAOï¿½s report BLM and 
the Forest Service, Land Exchanges Need to Reflect 
Appropriate Value and Serve the Public Interest (No. 
RCED-00-73), issued in June 2000, stated that BLM had 
given more than fair market value for land it acquired and 
received less than fair market value for public land it 
conveyed because the appraisals used to estimate land 
values did not always meet federal standards.  Under 
SNPLMA the highest bidder in an auction establishes the 
price of federal land to be sold. 

BLM has developed effective partnerships with local 
governments to jointly select the lands to be sold, and sales 
have progressed smoothly.  These partnerships have also 
assisted BLM in conveying public land needed for local 
public use.  Under SNPLMA and the Recreation and Public 
Purposes Act (43 USC 869 et. seq.), BLM can convey 
federal lands to local governments at low or no cost for 
public use.  BLM has worked with local governments, such 
as school and library districts, to give them an opportunity 
to select lands needed for such use before the land is sold, 
thereby demonstrating a commitment to the needs of the 
local communities.  BLM reported that it has provided 
2,256 acres of land to local governments since passage of 
SNPLMA.   

 



The success of the land sales program mandates strict 
oversight and controls over funds disbursed for 
administrative salaries and other administrative expenses 
incurred to implement SNPLMA.   We expect that in the 
next 2 to 3 years, the Project Office will likely gross in 
excess of $1 billion from federal land sales and receipts 
related to the use of CMA lands.  Our expectation is based 
on the recent passage of the Clark County Conservation of 
Public Land and Natural Resources Act (Public Law 
107-282), which expanded the SNPLMA disposal 
boundary by an estimated 20,000 acres and increased, to 
about 43,000 acres, the amount of federal land remaining to 
be disposed of.  In addition, the average sales price for each 
acre sold has exceeded $85,000 per acre.  Because of the 
growing balance in the special U.S. Treasury account and 
the expansion of the SNPLMA program, we believe that 
the Nevada State Office must provide stringent oversight 
for the disbursement of funds for Project Office expenses, 
particularly administrative salaries and costs.   

We found, however, that BLMï¿½s Las Vegas Field Office  
was inappropriately charging Field Office employee 
salaries to the Project Office even though the employees 
did not work on Project Office activities to the extent that 
they charged their salaries to Project Office activities.  
While we did not identify the full extent of these 
inappropriate assessments, the following cases illustrate our 
concerns. 

>	A Las Vegas Field Office realty specialist was told 
by her supervisor to charge all work time to Project 
Office work codes for the remaining 5 months of 
fiscal year 2002, even though the specialist spent 
only about 1 month of her time working on Project 
Office related activities during that time.  In 
response to our questions, a Las Vegas Field Office 
official stated that funding for the realty specialist 
would be fully expended before the end of the fiscal 
year and that it was necessary to charge her time to 
the Project Office activities. 

>	About $85,000 of the Las Vegas Field Office 
managerï¿½s salary was paid for by SNPLMA receipts 
in 2002.  Yet, in 2001, none of the salary was paid 
for by SNPLMA receipts.  The manager stated that 
he worked on Project Office activities in both years 
but acknowledged that records were not routinely 
kept to support these charges. 

A business manager hired in 1999 to oversee the financial 
activities of the SNPLMA program and the Project Office 
was not given authority to disallow erroneous or improper 
salary or other administrative charges assessed against 
SNPLMA funds.  An internal memorandum prepared by 
the Nevada State Directorï¿½s office authorizing such fund 
control for the manager was never implemented.  We 
discussed our concerns with the State Director and the 
Associate State Director for Nevada, who agreed to 
implement stringent fund controls and assured us that the 
business manager would have this control.  They also told 
us that while most Project Office activities would fall under 
the jurisdiction of the Las Vegas Field Office, the Project 
Officeï¿½s business manager would report to the Nevada 
State Office.  

In addition to providing for the sale of public land, Section 
4(g) of SNPLMA directed BLM to transfer ownership of 
about 5,200 acres of land in the McCarran Airport 
Cooperative Management Area (CMA) to Clark County, 
Nevada.  On March 30, 1999, 6 months after passage of 
SNPLMA, BLM transferred ownership of these acres.  
Clark County designated the Countyï¿½s Department of 
Aviation as the lead agency in administering, managing, 
and disposing of CMA lands.  As of March 31, 2003, the 
Department of Aviation had reported collections of 
$48.3 million  from CMA lands (Figure 4). 

 
 Figure 4

Under SNPLMA, the County remits to BLM 85 percent of 
any proceeds derived from the sale, lease, or other 
conveyance of CMA lands, such as land exchanges.  The 
State of Nevada receives 5 percent for educational 
purposes, and the Department of Aviation retains the 
remaining 10 percent.  Since March 1999, the County has 
completed 31 land exchanges, in which it disposed of about 
900 acres and acquired 513 acres within the CMA, and has 
correctly remitted the proper funds to BLM (Figure 5).

 
Figure 5

We also believe that BLM and the Department of Aviation 
should finalize an enforceable operating agreement that 
they have been negotiating since December 2001 to 
delineate their respective responsibilities for complying 
with SNPLMA provisions regarding CMA lands.  It makes 
good business sense to finalize this agreement, which we 
believe should address, at a minimum, submissions of 
County financial reports, provisions for updated land maps, 
conduct of County audits, exchanges that include land 
outside CMA boundaries, legal notices, modifications and 
amendments, and mediation of disputes.  Both BLM and 
the County agreed that the agreement should be finalized.  

A December 2000 publication (Property Disposal Program 
for Cooperative Management Area (CMA) Properties) 
addressed the sale, lease, or exchange of CMA lands; listed 
the general location of desired land acquisitions; and stated 
that exchanges reducing residential development within the 
CMA area would be the Countyï¿½s highest priority.  We 
found the County had generally identified the land acquired 
through the exchanges in its December 2000 publication. 



Appendix
Scope and Methodology

Our review included BLM activities related to 
implementing SNPLMA from its enactment in 1998 
through March 2003 and selected activities related to the 
disposition of CMA lands managed by Clark Countyï¿½s 
Department of Aviation.  We conducted our review at 
BLMï¿½s Las Vegas Field Office and the McCarran Airport 
in Las Vegas, Nevada. 

We undertook our review, in part, because of news articles 
and inquiries from concerned individuals who questioned 
the Countyï¿½s use of land exchanges and its acceptance of 
the best offer in lieu of a higher offer for some of the lands 
exchanged.  We addressed these issues during our review.  
Our Office of General Counsel concluded that Nevada 
statutes provided authority for the exchanges and that it 
was legally defensible for Clark County to accept either the 
highest offer or an offer that allowed the County to meet its 
priority of limiting incompatible development near the 
airport.   

We conducted our review, as applicable, in accordance 
with the Government Auditing Standards issued by the 
Comptroller General of the United States.  Accordingly, we 
included such tests of records and other auditing procedures 
that we considered necessary under the circumstances.  To 
accomplish our objective, we reviewed (1) applicable 
federal laws, including Nevada statutes, (2) Congressional 
briefings and testimony, (3) BLM policies and procedures 
for implementing provisions of SNPLMA, (4) Clark 
County Department of Aviation planning documents, maps, 
and Land Trade Analysis that depicted the scope of County 
land exchanges, (5) news articles and written complaints 
questioning Clark Countyï¿½s land exchanges within the 
CMA, (6) Project Office budgets, receipts, and expenditure 
documents, and (7) correspondence and other documents 
maintained at the Project Office to identify key actions and 
decisions of BLM and Airport officials concerning the 
implementation of all provisions of SNPLMA. 

As part of our review, we evaluated BLMï¿½s system of 
internal controls related to implementing provisions of 
SNPLMA and controls related to accounting for disbursing 
receipts to the extent we considered necessary to 
accomplish our audit objective.  In this regard, we 
expanded on our previous review, the results of which are 
included in our ï¿½Advisory Letterï¿½ of June 5, 2001 (see 
Prior Audit Coverage).  In our current review, we validated 
that Project Office managers maintained the same internal 
controls over receipts and disbursements or had improved 
on them.  Since the previous review, we noted that the 
Project Office had sought additional help from BLMï¿½s 
national business center regarding investing, controlling, 
and accounting for SNPLMA receipts.  We also noted that 
the Project Office had issued standard operating procedures 
for the auctions, which included delineating specific roles 
and responsibilities for BLM staff, including staff of 
BLMï¿½s national business center.  

Although we validated that the Project Office had 
maintained or improved internal controls over receipts and 
disbursements, we found a minor weakness relating to fund 
control, which is discussed in the ï¿½Magnitude of Land 
Sales and of Other Receipts Highlights the Need for 
Improved Controlsï¿½ section of this report.  Based on 
discussions with BLM State and Associate State Directors 
for Nevada, we did not issue any recommendation in this 
regard. 

We also reviewed Department of the Interior Reports on 
Accountability for fiscal years 2001 and 2002, which 
included information required by the Federal Managerï¿½s 
Financial Integrity Act of 1982, and BLMï¿½s annual 
assurance statements on management controls for fiscal 
years 2001 and 2002.  We determined that no material 
weaknesses directly relating to the objective of our review 
were reported.  

As part of our review, we also evaluated whether BLM 
included SNPLMA activities when reporting to Congress 
under the Government Performance and Results Act of 
1993 (GPRA) (Public Law 103-62).  GPRA requires that 
each federal department and agency prepare annual 
performance reports comparing planned accomplishments 
for mission-related activities with results actually achieved.  
BLMï¿½s Annual Performance Plans for fiscal years 2002 and 
2003, which include BLMï¿½s Annual Performance Reports 
for fiscal years 2000 and 2001, discussed SNPLMA land 
sales activities under the GPRA program activity: ï¿½Provide 
Economic and Technical Assistance,ï¿½ (Long-Term Goals 
01.06.03 and 01.06.04).  BLM reported that it had 
accomplished the disposal of 345,902 acres of federal land 
outside the State of Alaska in support of local community 
and state economic needs.  Although BLM identified 
SNPLMA land sale activities as one of the most innovative 
land conveyance authorities, BLM did not specifically 
identify or compare SNPLMAï¿½s planned accomplishments 
with the results of its land sale activities (3,897 acres sold). 
Given that the results of SNPLMA land sale activities 
comprised only a small portion of BLMï¿½s reported land 
disposal activities, we agree that BLM should not 
specifically identify goals and measures for SNPLMA land 
sale activities.  In addition, we noted that BLM had 
developed a strategic plan to implement SNPLMA and 
produced a fiscal year 2002 Annual Performance Plan 
including program goals, which were compared with  
SNPLMA accomplishments.         

The Office of Inspector General issued one Memorandum 
Advisory Letter since SNPLMAï¿½s inception in 1998.  Our 
review was conducted in September and October of 2000 at 
the request of BLM to evaluate BLM controls over receipts 
and disbursement of funds derived from land sales 
authorized by SNPLMA.  We concluded that the Project 
Office had established sufficient internal controls over 
receipts and disbursements.  We noted a minor weakness in 
the separation of duties over cash deposits and 
reconciliations with the Departmentï¿½s collection and billing 
system, which was resolved prior to issuance of our 
Advisory Letter on June 5, 2001. 




























































 The $262.8 million comprises the following:  $189,577,161 from live and 
Internet auctions; $8,229,540 from direct land sales; $48,308,917 from the use 
of CMA lands; $5,691,053 from interest earnings; and $10,987,676 from land 
exchanges, mineral conveyances, and forfeitures. 
 As of March 31, 2003, distributions to the State of Nevada and Water 
Authority were less than the required 5 percent and 10 percent because of 
timing differences related to collecting the remaining receipts from the 
November 2002 and the January 2003 land sales.  BLM typically makes the 
required distributions after all land sales receipts have been collected.  
 Of the $262.8 million generated by all of SNPLMAï¿½s funding sources, about 
$14.1 million was distributed to the State of Nevada, $23.4 million was 
distributed to the Stateï¿½s Water Authority, and an additional $4.8 million was 
retained by Clark Countyï¿½s Department of Aviation.  The remaining 
$220.5 million was deposited in the special U.S. Treasury account.   
 There is a delay in collecting the total sale price from the winning bidder, who 
conveys 20 percent of the sale price to BLM on the date of the auction and pays 
the remaining 80 percent within 6 months.  If the bidder defaults on the 
payment, BLM retains the deposited funds and resells the land.  As of 
March 31, 2003, $189,577,161 has been collected, an additional $127,280,000 
is in escrow, and the remaining $16,530,450 should be collected by July 31, 
2003. 
 Of the 3,951 acres offered for sale, 3,897 acres have been sold.  

 Under SNPLMA, BLM can expend program receipts for arranging and 
administering federal land sales, completing land exchanges, and paying the 
administrative costs of implementing SNPLMA.  Senate Report 106-99 defined 
administrative costs as those necessary to establish and administer the Special 
Account, transfer CMA lands to Clark County, develop implementation 
procedures, and consult with legal counsel.  
 At the time of our review, the Las Vegas Field Office was co-located with the 
Project Office.
 Proceeds were derived from the cash payments required to equalize the values 
of exchanged lands and from the sale and lease of other CMA lands.  
                                                 
United States Department of the Interior

Office of Inspector General
Western Region
Federal Building
2800 Cottage Way, Suite E-2712
Sacramento, California 95825








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