[Advisory Report on the Del Webb Land Exchange in Nevada, Bureau of Land Management]
[From the U.S. Government Printing Office, www.gpo.gov]

Report No. 98-I-363

Title: Advisory Report on the Del Webb Land Exchange in Nevada,
        Bureau of Land Management

     Date: March 23, 1998




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     U.S. Department of the Interior         
     Office of Inspector General
  
     ADVISORY REPORT
         
         
     THE DEL WEBB LAND EXCHANGE IN NEVADA,
     BUREAU OF LAND MANAGEMENT
                            
     REPORT NO. 98-I-363
     MARCH 1998
  
  

  
     U.S. Department of the Interior
     Office of Inspector General
  
  
     MEMORANDUM
  

     TO:               The Secretary
  
     FROM:             Robert J. Williams,
                       Acting Inspector General
  
     SUBJECT SUMMARY:  Final Advisory Report for Your Information
                       - "The Del Webb Land Exchange in Nevada,
                       Bureau of Land Management" (No. 98-I-363)



     Attached for your information is a copy of the subject final advisory
     report, which is being issued as part of our followup review of our
     July 1996 audit report "Nevada Land Exchange Activities, Bureau of
     Land Management" (No. 96-I-1025). We will also issue a report
     focusing on the Bureau of Land Management's actions to implement the
     recommendations included in our July 1996 report. This advisory
     report is being issued because of our concerns regarding the Bureau's
     conformance with applicable standards, procedures, and controls
     relating to the appraisal and valuation of land for the Del Webb
     exchange (No. N-60167).
  
     During its processing of the exchange, the Bureau of Land Management's
     Washington Office did not fully conform to established standards,
     procedures, and controls for appraisals and land valuations and did
     not justify or document the propriety of its actions. Specifically,
     the Bureau's Washington Office (1) allowed Del Webb to use an
     appraiser who was not preapproved by the Nevada State Office, which
     was not in accordance with established statewide procedures and
     practice; (2) allowed the Del Webb appraiser to perform a
     development-based appraisal of the selected Federal land, which was
     not in accordance with the Federal standards which state that
     comparable sales should be relied on when adequate sales data are
     available; and (3) relieved the Nevada State Chief Appraiser of his
     appraisal review responsibilities for this exchange, which was
     contrary to the statewide procedures and guidance in the Bureau
     Manual. In addition, the Bureau issued a contract for an appraisal
     review to a firm nominated by Del Webb. As a result, if external
     pressure had not caused the Bureau to obtain a second appraisal, the
     Government would have lost $9.1 million on the Federal land selected
     for exchange because the development approach was used in the initial
     appraisal.
  
     Although the report contained no recommendations, we stated that the
     Bureau should establish a moratorium on land exchanges in Nevada
     until new control processes are instituted, including having an
     external Departmental team review and provide advice on exchanges. We
     will formally recommend that such processes and an external team be
     established in our followup report.
  
     In response to the draft report, the Director, Bureau of Land
     Management, stated that he did not believe a moratorium was necessary
     because of its significant impact on relationships which the Bureau
     has with various local, county, and state governments. In addition,
     the Director stated that he had established procedures for a second
     -level review of land exchanges involving land valued in excess of
     $500,000. Further, the Director stated that he was considering a
     Bureauwide land exchange team to assist in high priority exchanges.
  
     If you have any questions concerning this matter, please contact me at
     (202) 208-5745 or Mr. Ronald K. Stith, Acting Assistant Inspector
     General for Audits, at (202) 208-4252.
  
  
  
                   


                                                      W-IN-BLM-001-97(A)
     ADVISORY REPORT
  

     Memorandum
  
     To:      Director, Bureau of Land Management
  
     From:    Robert J. Williams
              Acting Inspector General
  
     Subject: Advisory Report on the Del Webb Land Exchange in Nevada, 
              Bureau of Land Management (No. 98-I-363)




     INTRODUCTION
  
     This report provides, for your information, the results of our review
     of the Del Webb Corporation land exchange administered by the Bureau
     of Land Management. We are issuing this report as part of our
     followup review of our July 1996 audit report "Nevada Land Exchange
     Activities, Bureau of Land Management" (No. 96-I-1025). We will also
     issue a report focusing on the Bureau's actions to implement the
     recommendations included in our July 1996 report. We are issuing this
     advisory report because of our concerns regarding the Bureau's
     conformance with applicable standards, procedures, and controls
     relating to the appraisal and valuation of lands for the Del Webb
     exchange (No. N-60167).
  
     BACKGROUND
  
     The Bureau of Land Management is responsible for managing and
     protecting over 260 million acres of Federal land, of which about 48
     million acres are in the State of Nevada. The Congress has emphasized
     the use of land exchanges and fee purchases to acquire lands
     containing resource values of public significance and to improve the
     manageability of Federal land by consolidating its land ownership.
     The Bureau prefers to acquire land through exchanges, which may be
     initiated by the Bureau or other interested parties called
     proponents. In recent years, the Bureau has identified about 70,000
     acres of Federal land for disposal in the Las Vegas Valley of Nevada,
     which continues to be one of the fastest growing metropolitan areas
     in the United States. The potential for real estate development in
     the private market associated with this growth in the Valley has
     created significant interest in acquiring available Federal land.
  
     The Bureau conducts land exchanges under the authority of Section 206
     of the Federal Land Policy and Management Act of 1976 (Public Law 94
     -579), which authorizes the Secretary of the Interior to dispose of
     Federal land by exchange when the public interest will be well
     served. Under Section 206, the values of the lands exchanged must be
     equal or, if not equal, must be equalized by a cash payment by either
     party except in circumstances where the value of the Federal land
     transferred by the Government is not more than $150,000 (the value of
     the Federal land transferred in the Del Webb exchange exceeded
     $150,000). Section 206 specifically directs the Secretary to make the
     amount of such payments as small as possible but states that in no
     event may the value difference between the properties exceed 25
     percent of the value of the Federal land exchanged. On August 20,
     1988, the Congress enacted the Federal Land Exchange Facilitation Act
     of 1988 (Public Law 100-409), which granted the Secretary limited
     authority to approve adjustments in the values of lands exchanged as
     a means of compensating a party for incurring costs such as those for
     land surveys, mineral examinations, and title searches, which would
     ordinarily be borne by the other party. In December 1993, the Bureau
     finalized comprehensive regulations for land exchanges (43 CFR 2200)
     to implement the provisions of both Acts.
  
     The values of the public and private lands exchanged are established
     by appraisals conducted in accordance with principles defined in the
     "Uniform Appraisal Standards for Federal Land Acquisitions," issued
     by the Interagency Land Acquisition Conference in 1992. The
     "Standards" stipulates that each appraisal be carefully reviewed by a
     qualified review appraiser and that the review be documented by a
     written report indicating the scope of the review and the actions
     recommended by the reviewer. The "Standards" also states that
     appraisals should rely on the comparable sales method to value
     Federal property when adequate sales information is available.
     Section 9310 of the Bureau Manual provides specific policies and
     procedures for management and administration of the Bureau's
     appraisal function, including the preparation of appraisal reports
     and the requirement that the State Chief Appraiser should review
     appraisal reports and approve the fair market value estimated in
     those reports in accordance with professional standards.
  
     PRIOR REVIEW
  
     Our 1996 audit report "Nevada Land Exchange Activities, Bureau of Land
     Management" (No. 96-I-1025) concluded that while the Nevada State
     Office had acquired some high quality properties by exchanging lands
     with private entities, it did not consistently follow prescribed land
     exchange regulations or procedures or ensure that fair and equal
     value was received in completing three of the four exchanges we
     reviewed. As a result, we estimated that the Government may have lost
     revenues totaling about $4.4 million in completing the three
     exchanges. In addition, we concluded that the State Office acquired
     about 2,500 acres of land, with an exchange value of $2.7 million,
     that had no discernable mission-related purpose.
  
     In our 1996 report, in regard to exchange processing, we recommended
     that the Director of the Nevada State Office (1) institute
     competitive procedures (sale or exchange) into the land disposal
     process to the maximum extent possible, (2) direct that all easements
     on Federal land proposed for disposal be reviewed to verify grantee
     needs and that actions be taken to remove any easements which are not
     needed before the Federal lands are exchanged or sold, and (3)
     establish controls necessary to ensure that land exchanges are
     processed in full accordance with applicable laws and regulations and
     Bureau procedures. At a minimum, these controls should ensure that
     the land to be acquired is obtained in conformance with approved
     land-use plans or properly executed amendments; that land acquired
     and disposed of is properly valued; and that all significant
     decisions involving the exchange transactions, particularly those
     affecting land valuation, are fully justified and documented in the
     exchange files. Our report contained two other recommendations.
     However, these recommendations were related to Santini-Burton Act
     lands and were not specifically relevant to issues discussed in this
     report.
  
     DISCUSSION
  
     During its processing of the Del Webb land exchange, the Bureau of
     Land Management's Washington Office did not fully conform to
     established standards, procedures, and controls for appraisals and
     land valuations and did not justify or document the propriety of its
     actions. Specifically, we concluded that the Bureau's Washington
     Office (1) allowed Del Webb to use an appraiser who was not
     preapproved by the State Office, which was not in accordance with
     established statewide procedures and practice; (2) allowed the Del
     Webb appraiser to perform a development-based appraisal of the
     selected Federal land, which was not in accordance with the Federal
     standards which state that comparable sales should be relied on when
     adequate sales data are available; and (3) relieved the Nevada State
     Chief Appraiser of his appraisal review responsibilities for this
     exchange, which was contrary to the statewide procedures and guidance
     in the Bureau Manual. In addition, the Bureau issued a contract for
     an appraisal review to a firm nominated by Del Webb. As a result, if
     the Bureau had not obtained a second appraisal, the Government would
     have lost $9.1 million on the Federal land selected for exchange
     because the development approach was used in the initial appraisal.
  
     The Del Webb Corporation is a publicly traded national real estate
     company and developer of planned communities, including its Sun
     Cities retirement developments in Phoenix, Arizona; Las Vegas,
     Nevada; Palm Desert and Roseville, California; Hilton Head, South
     Carolina; and Georgetown, Texas. On September 29, 1994, Del Webb
     submitted a proposal to acquire, through an exchange with the Bureau,
     about 4,975 acres of Federal land located southwest of the City of
     Henderson, Nevada. According to the exchange proposal, Del Webb
     intended to develop the acquired Federal land as "a Master Planned
     Community incorporating a mixture of commercial, residential and
     recreational uses, with the residential uses to be primarily for an
     age-restricted community for residents [aged] 55 and over."
  
     On September 29, 1995, the Bureau's Nevada State Office determined
     that the proposed exchange could be executed in multiple phases over
     a period of 3 to 7 years, with each phase including about 1,000 acres
     of Federal land.  The initial exchange transaction, Phase IA, was
     finalized on July 29, 1997, when the Bureau acquired four properties
     totaling 5,328 acres, valued at $10,990,000, in exchange for 922
     acres of Federal land in the Las Vegas Valley, valued at $11,452,639.
  
     Acceptance of Del Webb Appraiser
  
     The Bureau's Washington Office overrode the Nevada State Office's
     usual practice for appraising Federal land by allowing the Del Webb
     Corporation to use its own appraiser to value the Federal land
     selected for exchange. In order to ensure that the Bureau received
     fair market value for the Federal land exchanged, appraisal requests
     were to be processed through the State Office, and the appraisals
     were generally conducted by contract appraisers preapproved by the
     Bureau.  Section 9310 ("Real Property Appraisals") of the Bureau
     Manual requires state directors to impartially administer an
     appraisal program in accordance with applicable laws and Departmental
     policies. Section 9310.04 of the Bureau Manual requires that state
     chief appraisers be responsible for "planning, organizing, and
     providing program leadership for the appraisal function . . .
     including procuring . . . qualified real estate appraisal expertise
     [and] . . . approve an amount which represents the Bureau's estimate
     of fair market values." In carrying out these delegated
     responsibilities, the Nevada State Chief Appraiser established
     procedures that included using appraisal firms under contract with
     the Bureau to perform the appraisals of the Federal land selected by
     proponents in land exchanges.
  
     In a November 27, 1995, letter to a Del Webb representative, the
     Nevada State Director stated, "We [the Bureau] will appraise both the
     offered [private] lands and selected [Federal] lands as we enter into
     each phase of the exchange." Additionally, the draft agreement to
     initiate the exchange stated:
  
       The BLM [Bureau of Land Management] or other benefiting Federal
     agency will arrange with a contractor to prepare an appraisal of the
     selected lands for each phase within ninety days of the initiation of
     that phase of the exchange.  The appraisal will be done in accordance
     with federal appraisal standards and will be subject to federal
     review and approval.
  
     However, according to the exchange file chronology, the Del Webb
     Corporation disagreed with this appraisal arrangement and informed
     the Bureau, at a November 30, 1995, meeting between representatives
     of the Nevada State Office and the Del Webb Corporation, that it was
     having its own appraisal performed of the selected Federal land. Del
     Webb took issue with the Nevada State Director's position on the
     appraisal in its January 16, 1996, letter which stated:
  
       The proposed [appraisal] language in your draft is far more
     restrictive than the plain language of the Federal Regulations [43
     CFR 2201.3 and 3-1] and we believe that the process will be aided
     immeasurably by adhering to federal regulations rather than by
     restricting those regulations with a localized policy not
     specifically designed to produce the best available appraiser.
  
     The letter from Del Webb did not, however, provide information on how
     Del Webb was providing the "best available appraiser." We noted that,
     in 1994, the Nevada State Office had implemented the Statewide
     practice of using Bureau contract appraisers to ensure that the
     Government received fair value for the lands it was exchanging.
     According to documents in the exchange file, the Del Webb Corporation
     contacted the Deputy Director regarding the initial appraisal and the
     use of its own appraiser. On February 2, 1996, the Nevada State
     Director signed an agreement that initiated the exchange and enabled
     Del Webb to provide an appraisal of the selected Federal land. This
     appraisal provision was contrary to the provision in the draft
     agreement submitted to Del Webb by the State Director to initiate the
     exchange and was contrary to the State Office's practice of using its
     preapproved contract appraisers.
  
     We did not find any documentation that justified a change from the
     State Office's initial position as reflected in the November 27,
     1995, letter to a Del Webb representative and the draft agreement to
     initiate the exchange. Our reviews of four land exchanges processed
     in the Las Vegas Field Office from June 1, 1995, through August 1,
     1997, found that, with the exception of the Del Webb exchange, Bureau
     contract appraisers valued the Federal land selected. In our
     discussions with Bureau officials from the Nevada State Office,
     including the State Director and the Associate State Director, these
     officials stated that the Deputy Director had made the decision to
     allow Del Webb to hire its own appraiser and had directed the State
     Director to sign the agreement. The Bureau's Deputy Director stated
     that he had consulted with officials in the Nevada State Office but
     that the State Office had made the decision to allow Del Webb to use
     its own appraiser. However, a July 1, 1996, letter from the Chairman
     of the Board and Chief Executive Officer of Del Webb makes reference
     to the Deputy Director's "intervention on numerous occasions in order
     to get Nevada BLM [Bureau of Land Management] to comply with FLEFA
     [Federal Land Exchange Facilitation Act of 1988] and the Justice
     Department's Uniform Appraisal Guidelines." We noted that the Federal
     Land Exchange Facilitation Act allows either party to the exchange to
     obtain the appraisal of the selected Federal land by stating, "[T]he
     Secretary concerned and the other party or parties involved in the
     exchange shall arrange for appraisal of the lands or interests
     therein involved in the exchange."  In addition, the Code of Federal
     Regulations (43 CFR 2201.3-1) states that the appraiser may be an
     employee or contractor to the Federal or non- Federal exchange
     parties. As such, the Nevada State Office's practice of using a
     Bureau contract appraiser to conduct the appraisal of the selected
     Federal land was also in compliance with the Act and implementing
     regulations.
  
     Use of Development Approach
  
     The initial appraisal, which was prepared by Del Webb's appraiser,
     valued the 4,776 acres of Federal land at $43 million using the
     development approach. This approach reflects the highest price a
     proponent of a land exchange could afford to pay for the lands and
     still earn its desired profit. The "Uniform Appraisal Standards for
     Federal Land Acquisitions" states, "[W]hen comparable sales are
     available to determine the property's fair market value, the
     developer's residual approach [development approach] should not be
     employed, as the approach is highly speculative, prone to error, and
     reflects not so much value [of the lands being appraised] as the
     highest price a developer can afford to pay for the lands and still
     earn the desired profit." The Nevada State Chief Appraiser had
     informed Del Webb's appraiser of his concern regarding the use of
     this method on March 5, 1996. Subsequently, the Bureau ordered a
     second appraisal of the selected Federal land. The second appraisal
     relied on comparable sales and estimated the value of the selected
     Federal land at $52.1 million (an increase of $9.1 million over the
     initial appraisal). The appraisal report validated the Nevada State
     Chief Appraiser's position that the comparable sales approach should
     be relied on for estimating the value of the selected Federal land
     (see the section "Contract for Second Appraisal" in this report).
  
     State Chief Appraiser Relieved of Responsibilities
  
     The Bureau's Deputy Director relieved the Nevada State Chief Appraiser
     of his responsibilities for reviewing the appraisal of the Federal
     land selected by Del Webb, and the Washington Office decided to
     contract with a non-Federal source for the appraisal review. Section
     1203 of the Bureau Manual, which was in effect at the time, limited
     the responsibility for reviewing and approving exchange values to
     "the State Office Chief Appraiser only." According to a chronology of
     events on the Del Webb exchange prepared by the  State Chief
     Appraiser, the State Chief Appraiser was relieved of his
     responsibilities because a Del Webb representative had stated to the
     Washington Office that the State Chief Appraiser had expressed a
     "preconceived opinion of value" during a meeting with Del Webb's
     appraiser and other Bureau and Del Webb officials on March 5, 1996.
     However, based on our review of the exchange files and interviews
     with Nevada State Office officials, we did not find any evidence of a
     "preconceived opinion of value" by the State Chief Appraiser.  We
     confirmed with the Associate District Manager for the Las Vegas
     District, who was present at the meeting with Del Webb, that the
     State Chief Appraiser did not express a "preconceived opinion of
     value." In addition, our review of the files in the Nevada State
     Office found no information documenting or justifying the decision to
     relieve the State Chief Appraiser of his responsibilities or
     information supporting Del Webb's view that he had a "preconceived
     opinion of value" regarding the selected Federal land. Instead,
     according to the State Director and the Associate District Manager
     and the chronology prepared by the State Chief Appraiser, the State
     Chief Appraiser wanted to comply with the "Standards" regarding the
     valuation of property (comparable sales versus development approach).
  
     During the March 5, 1996, meeting, Del Webb's appraiser informed the
     State Chief Appraiser that he was relying on the development approach
     as the method to estimate the value of the selected Federal land. The
     State Chief Appraiser stated that he informed the Del Webb
     representatives that the appraisal would not be in conformance with
     the "Uniform Standards for Federal Land Acquisitions" unless it
     relied substantially on comparable sales. The State Chief Appraiser
     stated that he was subsequently notified by his supervisor that he
     was relieved of his responsibilities regarding the Del Webb exchange.
  
     Appraisal Review Contract
  
     After the State Chief Appraiser was relieved of his review
     responsibilities on this exchange, a Bureau contracting officer (from
     the Bureau's National Business Center in Denver, Colorado), relying
     on the recommendation of the Washington Office Chief Appraiser,
     awarded a contract on May 10, 1996, with limited competition for an
     appraisal review to a firm nominated by the Del Webb Corporation.
     Before this contract was awarded, the Nevada State Director stated
     that the Nevada State Office had recommended that another state chief
     appraiser assume the responsibility for reviewing the appraisal.
     However, this recommendation was not accepted by the Deputy Director.
  
     According to the Washington Office Chief Appraiser, competition for
     the contract award was limited "to avoid greater expense to the
     United States and weaken the integrity of the appraisal report."
     However, we did not find documentation such as estimated costs or
     other rationale concerning the extent and nature of the adverse
     impact on the Government or the appraisal if a fully competitive
     contract were to be awarded. In addition, the justification for the
     award noted that the contractor was selected because the firm was
     experienced "in appraising master planned communities" and is
     "familiar with the Las Vegas real estate market," but it did not
     document why the other appraisal firms solicited were not selected.
  
     The appraisal review contractor approved an appraisal that was not
     performed in accordance with the "Uniform Appraisal Standards for
     Federal Land Acquisitions" (development approach versus comparable
     sales). The Del Webb appraiser had valued the 4,776 acres of Federal
     land at $43 million by relying on the development approach.  The
     December 5, 1996, appraisal review report, obtained by the Bureau
     under the contract, accepted the appraiser's value of the land
     without any adjustments. On December 9, 1996, the Bureau's Washington
     Office Chief Appraiser accepted the appraisal review report and the
     $43 million valuation and recommended that this value be approved by
     the Bureau's Las Vegas District Manager.
  
     Contract for Second Appraisal
  
     On December 12, 1996, we notified the Bureau of our intent to perform
     a followup audit of its Nevada land exchange activities. In a
     December 23, 1996, letter responding to a request from Senator Harry
     Reid from Nevada about the status of the Del Webb exchange, the
     Deputy Director stated:
  
       Another factor which may potentially affect the timing of the Del
     Webb exchange is the investigation of land exchange activities in
     Nevada by the Office of Inspector General (IG). . . . We will meet
     with the IG's office during the week of January 6, 1997, to discuss
     this new audit.
  
     On January 7, 1997, we held an entrance conference on our followup
     audit with Bureau officials and informed them that the Del Webb
     exchange would be included as part of the scope of our audit. On
     January 27, 1997, the Bureau contracted for a second appraisal on the
     Federal land selected by the Del Webb Corporation. This contract,
     which also did not use an appraisal firm preapproved by the Nevada
     State Office and which was reviewed by the Washington Office Chief
     Appraiser instead of the Nevada State Chief Appraiser, used the
     comparable sales method to value the selected Federal land.
  
     According to the Bureau, a "large number of [Department] officials,
     including BLM [Bureau of Land Management] Washington and Field
     Officials, Solicitor's Office representatives, and a representative
     of the Assistant Secretary's Office . . . made a consensus decision
     to seek a second appraisal." The Bureau stated that it made this
     decision for the following reasons:
  
       The concerns that led to this conclusion included: 1) the values
     recommended by the contract review may be too low; 2) the public had
     not had an opportunity to comment on the appraisal during the public
     comment period on the initial Notice of Decision; 3) the appraisal
     review contractors had identified 10 comparable sales, some of which
     had not been identified by Del Webb's appraiser; 4) BLM continued to
     have questions regarding the appraisal methodology (feasibility of
     the preferred approach based on comparables); 5) several protests
     questioned the initial appraisal; and 6) there was an unresolved
     issue concerning a power line right-of-way that potentially affected
     appraised value.
  
     The Bureau received the second appraisal, dated March 21, 1997, which
     valued 4,756 acres of selected Federal land at $52.1 million. In
     addition, the appraisal report validated the Nevada State Chief
     Appraiser's position by stating, "[O]nly the Sales Comparison
     Approach to value was directly applicable in this analysis."  The
     appraisal increased the value of the Federal land selected by Del
     Webb from $43 million for 4,776 acres (an average of about $9,000 per
     acre) to $52.1 million for 4,756 acres (an average of about $11,000
     per acre), or an increase of $9.1 million for 20 fewer acres. The
     initial exchange transaction (Phase IA), which was subsequently
     finalized on July 29, 1997, provided 922 acres of selected Federal
     land valued at $11,452,639 (an average of $12,423 per acre for this
     land) to Del Webb using the higher appraisal value.
  
     Conclusion
  
     As presented in our audit reports issued in 1991 and 1992 and, more
     recently, in July 1996, the Bureau of Land Management had not
     administered land exchanges in accordance with established standards
     and procedural controls.
  
     On June 20, 1996, three members of the U.S. House of Representatives
     (including the Chairman of the House of Representatives Resources
     Committee and the Chairman of the House of Representatives
     Subcommittee on National Parks, Forests and Lands) sent a letter to
     the Secretary requesting that a moratorium be placed on all land
     exchanges in Nevada. In his July 19, 1996, response to the request,
     the Bureau's Deputy Director stated that the Bureau had:
  
       . . . instituted several procedural and policy changes to set
     priorities on exchange proposals, to streamline the paperwork
     process, to improve coordination with local governments, to improve
     management of the land exchange process and to assure that the public
     receives a fair value for land exchanges.
  
     The Deputy Director informed the Congress that a partial moratorium
     had been imposed but that the Bureau was concentrating on six high
     priority exchange proposals (which included the Del Webb exchange).
  
     On July 30, 1996, the Subcommittee on National Parks, Forests and
     Lands, Committee on Resources, House of Representatives, conducted
     hearings with the Inspector General regarding the Office of Inspector
     General's July 1996 audit report on Bureau land exchange activities
     in Nevada. At this hearing, in response to a question from a member
     of the Subcommittee as to whether a moratorium was necessary on all
     land exchanges in Nevada, the Inspector General stated:
  
     I do not believe that the results indicated in our [July 1996]
     audit report require a moratorium on land exchanges. We did not come
     to that conclusion. We believe that there are problems with the
     process that need to be addressed and that should be addressed as
     promptly as possible, but I would not go so far as to say we have
     concluded that there is a need for a moratorium on land exchanges.
  
     During the hearing, another member of the Committee asked the
     Inspector General if it was the Inspector General's "expectation that
     no future land exchanges would occur without the implementation of
     those three recommendations . . . [in the July 1996 audit report]."
     In response, the Inspector General stated:
  
     Obviously it would be our hope that any future exchanges
     incorporate the recommendations that we have made. . . . There are
     certain things like ensuring that appraisal values are approved by a
     chief appraiser. That is something that doesn't require any period of
     time to implement. . . . I think based on the Bureau's response [to
     the July 1996 audit report], they [the Bureau] are talking about
     reviewing all of their processes to ensure that, in fact, they are in
     compliance with the applicable rules and regulations [for land
     exchanges]. But it is certainly my hope that the particular items
     that we have pointed out in the audit report, to the extent that they
     arise again in another exchange, that they would be able to do it the
     right way. . .
  
     In reviewing the Del Webb exchange, we found that the Bureau's
     Washington Office did not fully conform to established standards,
     procedures, or controls.  The Bureau had assured the Congress, in
     response to several inquiries from its members about land exchanges,
     and our office, in response to our prior audit report on Nevada land
     exchanges, that it would comply with established land exchange
     procedures and controls. However, on December 9, 1996 (about 6 months
     after its response to the June 1996 House of Representatives letter
     and about 5 months after the Congressional hearing), the Washington
     Office Chief Appraiser accepted and recommended approval of the
     initial appraisal and appraisal review when the appraisal did not
     conform to the "Standards" preferred method of appraising Federal
     land and was not reviewed and approved by the Nevada State Chief
     Appraiser.  As stated previously, a second appraisal was obtained
     that increased the value of the selected Federal land. The processing
     of the Del Webb exchange without the second appraisal would have
     resulted in a $9.1 million loss to the Government.
  
     Because the Bureau has not conformed to established procedures and
     controls, notwithstanding its assurances of such to the Congress and
     the Office of Inspector General, we believe that the Bureau should
     establish a moratorium on land exchanges in Nevada until new control
     processes are instituted, including having an external team review
     and provide advice on land exchanges. We will formally recommend that
     such processes and an external team be established in our followup
     report.
  
     Bureau of Land Management Response and Office of Inspector General
     Reply
  
     In the February 25, 1998, response (Appendix 1), the Director, Bureau
     of Land Management, included, as Attachment 1, a chronology of Del
     Webb land exchange events. The excerpted narrative from this
     chronology and our comments and clarifications of the events are
     presented in Appendix 2. The Bureau's comments on the report and
     exchange actions are discussed in the following paragraphs.
  
     In his response, the Director discussed the benefits of the land
     exchange program for acquiring land containing resource values of
     public significance and improving the manageability of Federal land
     ownership. The Director stated that the Del Webb exchange was "one of
     the largest and most challenging exchanges ever undertaken" by the
     Bureau and that this exchange was given "unprecedented attention" in
     both the Nevada State Office and the Bureau's Washington Headquarters
     Office because of the "very speculative and volatile nature of the
     land values in the Las Vegas area, and the size of this exchange."
     The Director further stated that our draft advisory report "expresses
     concern about different/several decisions made early" in the
     exchange. Specifically, according to the Director, our report "does
     not question the consistency of these decisions with controlling law
     or regulations" but the "departure, . . . from established standards
     or procedures." The Director also stated that our report "only
     suggests that, had BLM [Bureau of Land Management] not undertaken a
     second appraisal, there could have been a $9.1 million loss to the
     Federal government." The Director further stated that "[m]ore
     relevant to the ultimate question of whether the public interest was
     served in this matter, I believe there is no doubt that BLM [Bureau
     of Land Management] acted with appropriate caution before making any
     final decisions on this exchange" and that the decision to obtain the
     second appraisal "effectively eliminated concerns about the
     appropriateness of the final decision." The Director further stated
     that the Bureau "takes particular issue with" the draft report's
     "implied criticism that there is something inappropriate about
     elevating decisions on high priority, high visibility and/or
     sensitive issues from a field organization to Headquarters."
  
     The Director agreed that the "exchange program [should] be maintained
     on a solid footing" and that procedures for a secondary review and
     concurrence by either the State Director or the Washington
     Headquarters Office of exchanges exceeding $500,000 in value had been
     established. The Director also stated that he was "considering
     establishing a Bureauwide land exchange team to assist in the review
     of high priority exchanges, provide additional technical support to
     BLM [Bureau of Land Management] field offices, and address policy and
     procedural issues." Finally, the Director disagreed with the draft
     report's suggestion that the Bureau should establish a moratorium on
     land exchanges until new controls are instituted, stating that the
     moratorium would have an "adverse impact" on the Bureau's
     relationship with various local governments.
  
     Office of Inspector General Reply  In our July 1996 audit report of
     land exchanges (discussed in the Prior Review section of this
     report), we noted that the Bureau had "acquired some high quality
     properties by exchanging lands with private entities." However, we
     also identified deficiencies in the Bureau's administration of land
     exchanges, most notably in the valuation of lands through appraisals,
     which limited the program's benefits and resulted in the Bureau not
     obtaining fair value in its Nevada land exchanges. This advisory
     report discusses our newest concerns regarding the Del Webb land
     exchange.
  
     Our criticism was not with the elevation of decisions to the
     Headquarters level but with the Washington Office's nonconformance
     with established standards and controls. Our particular concerns with
     this exchange were that (1) the Bureau did not comply with appraisal
     standards and established policies and procedures; (2) the proponent
     was significantly involved in the decision-making process; (3) the
     Nevada State Chief Appraiser was removed from his appraisal review
     responsibilities; and (4) the Washington Office Chief Appraiser
     decided to accept the first appraisal and appraisal review, concluded
     that the $43 million value was reasonable and adequately supported,
     and recommended (December 9, 1996) to the Las Vegas District Manager
     that the appraisal be approved. We are encouraged by the Director's
     reference to the additional procedures that were implemented or are
     under consideration to provide better control over the land exchange
     process. However, except for the decision of the Bureau's Washington
     Office to obtain a second independent appraisal, we do not agree that
     the Bureau's decisions on the Del Webb exchange were reasonable or
     appropriate or ensured that the public interest was served.
  
     We do not believe that the Bureau's Washington Office was justified in
     its acceptance of the purported urgency of the appraisal or in its
     actions to facilitate completion and review of an appraisal of the
     entire Federal parcel. We found that Del Webb did not have sufficient
     offered property available to exchange for all the selected public
     land. For example, even after the Bureau approved an appraised value
     for the selected public land on April 8, 1997, almost 15 months after
     the date of Del Webb's letter to the Nevada State Director, the
     Bureau was able to accept only four properties valued at about $11
     million in the initial exchange transaction.
  
     Additional Comments on Advisory Report
  
     In its response, the Bureau provided additional comments on our
     report. The comments and our replies to the comments are as follows:
  
     Bureau Response. The Bureau stated: "The decision to allow Del Webb
     to furnish the initial appraisal for the proposed exchange was in
     compliance with the Federal Land Exchange Facilitation Act of 1988
     (P.L. 100-409) and implementing regulations (43 CFR 2200). Section
     2201.3-2 states 'A qualified appraiser may be an employee or a
     contractor to the Federal or non-Federal exchange parties.' To the
     extent that a decision to allow Del Webb to furnish the initial
     appraisal conflicted with a field policy or practice, the decision
     was fully within the discretion of BLM [Bureau of Land Management]
     Headquarters' Officials."
  
     Office of Inspector General Reply. Our preliminary draft report did
     not state that the Bureau had not complied with authorizing land
     exchange legislation or its implementing regulations. However, we
     reported that the Bureau did not comply with established policies,
     standards, and controls for appraisals and land valuations. Our
     report also noted that the decisions of Headquarters officials to
     override the Nevada State Office's standard policy and practice of
     obtaining the appraisal of selected public land was not justified or
     documented to show the propriety of this action. Furthermore, the
     Bureau's response conflicts with the information provided to us
     during interviews with Headquarters officials concerning the
     Washington Office's involvement in the decision-making process for
     the Del Webb exchange. Specifically, the Deputy Director and the
     Washington Office Chief Appraiser both told us that they offered only
     advice to Nevada State officials who made the decision to allow Del
     Webb to furnish the appraisal and that the Washington Office did not
     make this decision.
  
     Bureau Response. The Bureau stated: "The use of the 'cost development
     approach' is acceptable under the Department of Justice's 'Uniform
     Appraisal Standards for Federal Land Acquisitions', when the
     Appraiser, in his or her professional judgment, concludes there are
     inadequate or no comparable sales. It is appropriate for reviewing
     appraisers to withhold judgment on an appraiser's reasoning and
     appropriate use of appraisal methods until the appraisal is reviewed.
     The Contracting Appraiser . . . appraisal supplied by Del Webb met
     Federal Standards although it was not accepted by BLM [Bureau of Land
     Management]. It should be noted that there was some market analysis
     included in the first appraisal. Lack of confidence in this market,
     however, was one of the primary reasons for deciding to do a second
     appraisal."
  
     Office of Inspector General Reply. The "Uniform Appraisal Standards
     for Federal Land Acquisitions" states that the cost development
     approach is "highly speculative, prone to error, and reflects not so
     much value as the highest price a developer can afford to pay for the
     land and still earn the desired profit." The "Standards" also states
     that the use of this approach should be reserved for providing a
     check on the accuracy of value determined by the more reliable
     comparable sales method or in situations where "no comparable sales"
     are available.
  
     We believe that the Nevada State Chief Appraiser correctly advised
     (March 5, 1996) Del Webb's appraiser of the "Standards" preference
     for the comparable sales approach and that adequate information was
     available to use this approach. Further, we noted that the
     Solicitor's Office suggested that the comparable sales approach be
     used by the appraisers who were preparing the second appraisal for
     the Bureau.
  
     Bureau Response. The Bureau stated: "The decision to remove the BLM
     [Bureau of Land Management] Nevada Chief Appraiser . . . from the
     reviewing appraiser function was based on the perception that [the
     Nevada State Chief Appraiser] had a dispute with [Del Webb's
     appraiser] before the initial appraisal was performed in which he
     [the Nevada State Chief Appraiser] strongly expressed inappropriate
     preconceived notions of value or methodology. This disagreement
     between [the Nevada State Chief Appraiser and Del Webb's appraiser]
     could have potentially jeopardized the processing of the exchange. .
     . . Obtaining BLM in-house appraisal review expertise would have
     added additional delay in the land exchange processing."
  
     Office of Inspector General Reply  We noted that the second appraisal
     supported the Nevada State Chief Appraiser's position that only the
     comparable sales approach was appropriate for valuing the public land
     sought by Del Webb. In addition, the Solicitor's Office advised the
     Washington Office Chief Appraiser to advise the second appraisers of
     the requirement in the "Standards" that the comparable sales approach
     was the preferred method to be used when appraising Federal lands. As
     stated in the report (pages 6 and 7), we found no evidence to support
     the position that the State Chief Appraiser expressed a preconcieved
     notion of value. To the contrary, we noted that the State Chief
     Appraiser was attempting to comply with the "Standards" preferred
     method of valuation.
  
     The Bureau stated that obtaining an in-house appraisal review would
     have additionally delayed the exchange processing. However, we noted
     that there were extensive delays in processing this exchange that
     were caused in part by the concerns raised by Nevada State Office
     officials about the Del Webb appraisal and its contract review.
  
     Bureau Response. The Bureau stated: "As the chronology shows,
     discussions within BLM [Bureau of Land Management] about securing a
     second appraisal began before the IG [Inspector General] announced a
     follow-up audit and well before the IG informed BLM that the
     following audit would include the Del Webb exchange. Ultimately, a
     large number of DOI [Department of the Interior] officials, including
     BLM Washington and Field Officials, Solicitor's Office
     representatives, and a representative of the Assistant Secretary's
     Office were involved in these discussions and made a consensus
     decision to seek a second appraisal. The concerns that led to this
     conclusion included: 1) the values recommended by the contract review
     may be too low; 2) the public had not had an opportunity to comment
     on the appraisal during the public comment period on the initial
     Notice of Decision; 3) the appraisal review contractors had
     identified 10 comparable sales, some of which had not been identified
     by Del Webb's appraiser; 4) BLM continued to have questions regarding
     the appraisal methodology (feasibility of the preferred approach
     based on comparables); 5) several protests questioned the initial
     appraisal; and 6) there was an unresolved issue concerning a power
     line right-of- way that potentially affected appraised value. (See
     December 9, 1996 and September 10, 1996 chronology.)"
  
     Office of Inspector General Reply. We have incorporated the Bureau's
     reasons for acquiring the second appraisal into the report. However,
     notes prepared by the Washington Office Chief Appraiser of a December
     18, 1996, meeting attended by the Deputy Director, the Washington
     Office Chief Appraiser, the Nevada State Director, the Las Vegas
     District Manager, and a representative of the Assistant Secretary for
     Land and Minerals Management stated that decisions on whether to use
     the first appraisal and on how to proceed would not be made until the
     Bureau could determine whether our audit would include the Del Webb
     exchange (see December 18, 1996, in Appendix 2 chronology).
  
     Bureau Response. The Bureau stated: "The decision to seek a second
     appraisal and the subsequent decision to accept that appraisal led to
     BLM [the Bureau of Land Management] receiving greater value for its
     lands. These decisions support a conclusion that the safeguards to
     protect and serve the public interest in the exchange process worked
     in the case of the Del Webb exchange; they do not support the
     inferences in the IG [Inspector General] report that improper
     processes and procedures were followed."
  
     Office of Inspector General Reply. We disagree that proper processes
     and procedures were followed and that safeguards to protect the
     public interest worked in the Del Webb exchange. The procedural
     safeguards established by the Nevada State Office, which were
     designed to ensure that a fair value was established and that the
     appraisal was conducted in accordance with Federal appraisal
     standards, were overridden by the Washington Office in February and
     March 1996. We firmly believe that the exchange would have been
     consummated using the initial appraisal had the Bureau not been
     subjected to external factors that exerted pressure on it to obtain a
     second appraisal.
  
     Since this report does not contain any recommendations, a response is
     not required.
  
     The legislation, as amended, creating the Office of Inspector General
     requires semiannual reporting to the Congress on all audit reports
     issued, actions taken to implement audit recommendations, and
     identification of each significant recommendation on which corrective
     action has not been taken.
  
     We appreciate the assistance of Bureau personnel in the conduct of our
     review.
  
  


     BUREAU OF LAND MANAGEMENT
     CHRONOLOGY OF 
     DEL WEBB LAND EXCHANGE EVENTS  
     AND OFFICE OF INSPECTOR GENERAL COMMENTS


                    In order to present the Office of Inspector General's
     comments to the Bureau of Land Management's "Chronology - Del Webb
     Land Exchange" (Attachment 1 to Appendix 1), we have replicated the
     Bureau's comments except that names of individuals have been replaced
     with their official titles or other designations. This appendix
     provides discussions of our disagreement or additional clarification
     of the facts in the Bureau's Attachment 1. If the information in
     Attachment 1 did not affect the facts and conclusions presented in
     our report, we did not comment accordingly.




     Bureau Chronology                      

     Office of Inspector General Comments
     and Supplemental Information                      

  
  
     September 29, 1994 Initial exchange proposal made by Del Webb.
     September 29, 1994 Del Webb's exchange proposal identified a solid
     block of Federal land in the Las Vegas Valley that Del Webb sought to
     acquire (approximately 5,000 acres), but the proposal did not
     identify any specific private lands offered in exchange.
  
  
     September 29, 1995 The Associate District Manager approved a
     feasibility report for the exchange which stated that Del Webb had
     selected 4,975 acres of public land and that the exchange would be
     completed in phases, of which each phase would consist of about
     1,000-acre parcels and would be exchanged over a period of 3 to 7
     years.
  
     November 27, 1995 The Nevada BLM State Director forwards by letter a
     draft "Agreement to Initiate Exchange" to Del Webb, that provides
     that the Bureau will appraise the private and Federal lands involved
     in the proposed exchange. November 27, 1995 The draft agreement also
     stated that the Bureau "or other benefitting Federal agency will
     arrange with a contractor to prepare an appraisal of the selected
     lands for each phase within 90 days of the initiation of that phase
     of the exchange."
  
  
     November 30, 1995 Del Webb's representative advised the Las Vegas
     District Manager and the Associate District Manager that Del Webb was
     having an appraisal performed on the selected public land.
  
     January 16, 1996 Del Webb responded by letter to the Nevada State
     Director regarding the provisions of the draft exchange agreement
     between BLM and Del Webb. The letter stated: "the proposed appraisal
     language in your draft is far more restrictive than the plain
     language of the Federal Regulations [43 CFR, Part 2201.3 and 3-1] and
     we believe the process will be aided immeasurably by adhering to
     federal regulations rather than by restricting those regulations with
     a localized policy not specifically designed to produce the best
     available appraiser." The letter was expressing concern that the BLM
     would not promptly start the appraisal process and that Del Webb's
     appraiser was better qualified than any appraiser on BLM Nevada's
     list of qualified appraisers. Del Webb anticipated having an
     appraisal completed by early March 1996; BLM's timing would have been
     later. January 16, 1996 The Bureau's statement confirms that Del Webb
     had already selected an appraiser to estimate the value of the
     selected public land before the "Agreement to Initiate Land Exchange"
     was approved by the Bureau. Further, the Bureau did not provide
     information on when Del Webb retained the services of the appraiser,
     identify the Bureau official who approved the selection of this
     appraiser, or specify the date when the approval was given.
  
     We believe that Del Webb's desire to expedite the appraisal in order
     to establish the price for all of the approximately 5,000 acres of
     public land it sought to acquire was understandable given the rapid
     increases in land prices in the Las Vegas area. However, we found
     that Del Webb did not have sufficient offered property available to
     exchange for all of the selected public land.  For example, even
     after the Bureau approved an appraised value for the selected public
     land on April 8, 1997, almost 15 months after the date of Del Webb's
     letter to the Nevada State Director, the Bureau was able to accept
     only four properties valued at about $11 million in the initial
     exchange transaction. Accordingly, we do not believe that the
     Bureau's Washington Office was justified in its acceptance of the
     purported urgency of the appraisal or in its actions to facilitate
     completion and review of an appraisal of the entire Federal parcel.
  
     February 2, 1996 Upon the advice of the Washington Office, Nevada
     State Director signs revised "Agreement to Initiate Land Exchange"
     for Del Webb land exchange. Agreement provides for Del Webb to assist
     in the exchange by preparing several of the required documents and
     studies, including appraisal reports. Basically, BLM agreed with Del
     Webb that the regulations provide for the exchange proponent to
     appraise the lands, subject to BLM review. BLM felt that the
     contracting appraiser selected by Del Webb could do as good a job as
     a BLM appraiser. February 2, 1996 We agree that Bureau regulations
     authorize Bureau officials to allow exchange proponents to appraise
     exchange lands. The authorized officials for this exchange, the State
     Director and the State Chief Appraiser, acting in accordance with the
     authority delegated to them in Sections 1203 and 9310 of the Bureau
     Manual, had previously established and complied with a policy that
     the State Office would obtain its own appraisals of the public land.
     Their policy was also in compliance with the law. Given the
     significant interest in Nevada exchanges and the "very speculative
     and volatile nature of land values in the Las Vegas area" cited by
     the Director in his response to the draft report, we believe that the
     Nevada State Office's policy was a valid and reasonable method for
     providing the Bureau's authorized officers with an acceptable level
     of confidence in the appraised value of lands to be exchanged.
     However, we believe that the Washington Office's advice that Del Webb
     should be allowed to use the appraiser raised concerns that Del Webb
     was exerting undue influence over the exchange.
  
     March 5, 1996 Associate District Manager and Project Lead, and BLM
     Nevada Chief Appraiser and BLM Arizona Chief Appraiser, meet in
     Phoenix, Arizona with the Del Webb Appraiser and Del Webb
     representatives. The purpose of the meeting is to discuss
     instructions for completion of the appraisal report. The Nevada State
     Chief Appraiser expresses concern with Del Webb's appraiser and the
     Del Webb representatives over use of the "Cost Development Approach,"
     a valuation method proposed to be used by the Del Webb appraiser.
  
  
     March 14, 1996 Del Webb's Appraiser completes appraisal, based upon a
     "Cost Development Approach," for Del Webb for 5,312.5 acres of
     selected lands in the proposed exchange.

  
  
     March 25, 1996 (Approximate date) A conference call was held
     involving Deputy Director, Washington Office Chief Appraiser, Deputy
     State Director-Resources and Associate State Director. The purpose of
     the call was to discuss options for reviewing the appraisal. During
     the course of the conversation, the Associate State Director informed
     the Deputy Director and the Washington Office Chief Appraiser that
     Nevada had decided to remove the BLM Nevada State Chief Appraiser
     from the appraisal review responsibilities because of his possible
     lack of objectivity to the appraisal process and perceived poor
     working relationships with Del Webb. The Deputy Director and the
     Washington Office Chief Appraiser concurred with this decision.
     (Note: The BLM Nevada State Chief Appraiser was not removed from his
     job--just the Del Webb exchange process.) It was concluded that it
     would be very difficult to find another BLM appraiser with the
     expertise and time to conduct this review. BLM had recently lost
     appraisal staff in several states, existing workload in other states
     was perceived as heavy, and BLM did not have the level of expertise
     for the appraisal of of these types of property. Additionally
     appraiser from other state offices are March 5, 1996 When using a new
     appraiser on an appraisal assignment, the Bureau State Chief
     Appraiser meets with the appraiser before work begins to ensure that
     the appraiser has a thorough understanding of the scope of the work
     and of the "Uniform Appraisal Standards for Federal Land
     Acquisitions," which is required to be complied with in Federal land
     acquisitions and exchanges (private sector appraisers are not subject
     to these requirements). The Nevada State Chief Appraiser, the Arizona
     State Chief Appraiser, and the Associate District Manager stated that
     their impression after the meeting was that Del Webb's appraiser had
     completed most of his work and was not interested in expending
     additional effort to develop a substantive comparable sales analysis.
  
     March 14, 1996 Del Webb's appraiser completed his appraisal using the
     more complex development approach in only 9 days after the appraisal
     meeting with the Nevada Chief Appraiser and other Bureau
     representatives. Although there are no established time frames for
     conducting appraisals, the second appraisal of the Bureau land
     required about 8 weeks to complete. Consequently, we believe that Del
     Webb's appraiser had substantially completed this assignment before
     the March 5, 1996, meeting with Bureau officials.
  
     March 25, 1996 The information presented in the Bureau's chronology
     for March 25, 1996, conflicts with information we obtained during the
     audit and omits other relevant information about the meeting. The
     Nevada State Director, the Associate State Director, and the Deputy State
     Director- Resources told us that Nevada officials initiated this
     conference call just before a scheduled meeting between the Deputy
     Director and Del Webb's representative because Del Webb wanted to
     select and hire an appraiser to review the appraisal report prepared
     by Del Webb's appraiser. Further, the Deputy State Director -
     Resources said that she told the Deputy Director that there was no
     evidence to support Del Webb's assertions against the State Chief
     Appraiser but that if the Washington Office decided to remove the
     State Chief Appraiser from the Del Webb appraisal, there were other
     qualified Bureau State Chief Appraisers who should perform the
     review. The Deputy State Director - Resources also said that the
     Deputy Director stated that he would not make an immediate decision
     on the appraisal review.
  
     The Bureau's chronology does not note that Del Webb's representative
     directly participated in the conference call. However, the Deputy
     State Director - Resources informed us that after the initial
     discussion between the Bureau's Nevada State Office and the
     Washington Office, Del Webb's representative, who was waiting to meet
     the Deputy Director, was brought into the meeting.  Del Webb's
     representative stated that Del Webb did not
  
     March 25, 1996 (continued) generally uncomfortable in assisting
     another state to provide an impartial review of appraisals for
     another Chief Appraiser. Obtaining BLM in-house appraisal review
     expertise would have added additional delay in the land exchange
     processing. As a solution to this problem, the Washington Office
     Chief Appraiser pointed out that the regulations authorized the use
     of a contract review appraiser. The Deputy Director approved the use
     of this approach since the Washington Office was unable to provide
     another appraiser from within the Bureau. March 25, 1996 (continued)
     want the Nevada Chief Appraiser to perform the review because he was
     "biased" and did not want any other Bureau State Chief Appraisers to
     perform the review because Del Webb did not believe that they were
     qualified to evaluate a complex development approach appraisal. The
     Deputy Director said at the meeting that the Bureau would contract
     for an appraisal review.
  
     The Nevada State Director told us that she remained adamant that a
     Bureau State Chief Appraiser was needed to review and approve the
     value of the selected Federal land. We believe that the concerns
     expressed by the Nevada State Director were valid because the use of
     a Bureau State Chief Appraiser to perform the appraisal review would
     have enabled the Bureau to maintain proper oversight of the exchange.
  
  
  
     The Bureau's chronology states that the Nevada State Chief Appraiser
     was removed "because of his possible lack of objectivity to the
     appraisal process and perceived poor working relationships with Del
     Webb." However, as previously stated in our audit report, we found no
     evidence to support the allegations in the exchange file records; in
     the State Chief Appraiser's performance evaluations; or in our
     interviews with the Associate District Manager and Arizona Chief
     Appraiser, both of whom also attended the March 5, 1996, meeting with
     Del Webb's appraiser and representatives.
  
  
     March 26, 1996 Del Webb's representative sent a memorandum to the
     Washington Office Chief Appraiser requesting specific language to be
     included in the scope of work for the Bureau's appraisal review
     contract which stated that any written or verbal communication
     between the Bureau's contract review appraiser and Bureau employees
     was precluded unless Del Webb's representatives also participated. In
     addition, according to Del Webb's language for the proposed scope of
     work, the Washington Office Chief Appraiser would have been the only
     Bureau official allowed to communicate with the contractor. The
     requested language was included in the draft scope of work prepared
     by the Washington Office Chief Appraiser.
  
     March 27, 1996 Washington Office Chief Appraiser conducted telephone
     interviews with six prospective review appraisers. The IG's
     preliminary draft says five prospective contractors were contacted
     (footnote, page 14). March 27, 1996 Records from the Washington
     Office Chief Appraiser indicated that the Chief Appraiser made
     telephone calls to seven different appraisal contractors but
     conducted telephone interviews with only five of these contractors.
     Therefore, we do not believe that our report needs to be corrected.
  
     In addition, the Bureau's chronology did not identify all the parties
     involved in the telephone interviews. The Washington Office Chief
     Appraiser told us that Del Webb's representatives were allowed to
     "listen in" as the Chief Appraiser conducted these interviews.
  
     March 28, 1996 The Washington Office Chief Appraiser tentatively
     selected the appraisal firm nominated by Del Webb to perform the
     appraisal review.
  
  
     March 29, 1996 In a conference call with the Deputy Director, the
     Field Special Assistant to the Director, and the Group Manager, Lands
     and Realty Group, the Nevada State Director argued unsuccessfully
     "that a Bureau of Land Management person should review the report."
  
  
     April 3, 1996 Records of the conference call held to discuss the
     statement of work for the appraisal review contract indicated that
     the State Director was concerned about the statement of work. The
     areas of concern were (1) the number of acres that could be legally
     conveyed at that time and (2) the involvement of Del Webb's
     representatives. The Washington Office Chief Appraiser stated that he
     " underestimated" the State Director's concern that Del Webb was
     trying to "unduly influence the valuation and exchange process."
  
  
     April 5, 1996 The Washington Office Chief Appraiser changed the
     proposed statement of work to eliminate Del Webb's language regarding
     restrictions on communications (see March 26, 1996, entry).
  
  
     April 8, 1996 The Washington Office Chief Appraiser discussed the
     changes in the statement of work with Del Webb's representatives. The
     records of the Washington Office Chief Appraiser stated that Del
     Webb's representative felt that the Bureau reneged on its earlier
     agreement with Del Webb regarding the statement of work.
  
  
  
     April 11, 1996 Records of the Washington Office Chief Appraiser stated
     that Del Webb's representatives "requested a conference call to
     arbitrate their being taken out of the statement of work." The
     conference call included the Deputy Director, the Field Special
     Assistant to the Director, the Washington Office Chief Appraiser, the
     Deputy State Director- Resources, the Las Vegas District Manager, and
     Del Webb's representatives. The Washington Office Chief Appraiser's
     records stated that Del Webb's representative "was complaining" that
     because of earlier statements by the Nevada State Chief Appraiser and
     members of the State Office, it was essential that Del Webb's
     representatives be involved in observing discussions with the review
     appraiser to protect their client.
  
     April 25, 1996 On April 25, 1996, the Associate District Manager for
     the Las Vegas District and the Washington Office Chief Appraiser met
     with the prospective contract reviewers in Phoenix, Arizona. Based on
     the interview and discussion of the statement of work, a contract was
     awarded to the contract review appraisers following appropriate
     procurement procedures through the BLM National Business Center
     (Denver) on May 10, 1996. April 25, 1996 No comment.
  
     May 10, 1996 Award contract to contact review appraisers to review
     the Del Webb Appraiser's report. The Contracting Officer complied
     with all requirements for simplified acquisitions in Federal
     Acquisition Regulations (FAR) Part 13.106- 2(d)(3), which only
     required a notation to explain the absence of competition. The award
     in the amount of $12,500 was for less than the simplified acquisition
     threshold regarding competition. The Preliminary Draft IG Report (p.
     14) says FAR was not complied with. BLM also prepared a Justification
     for Other than Full and Open Competition (JOFOC), in accordance with
     portions of the Part 6.303-2 regulations. The JOFOC authorized the
     Contracting Officer to proceed with a "Sole Source" acquisition. May
     10, 1996 We have modified our report to recognize that this action
     was executed using the simplified acquisition procedures in the
     Federal Acquisition Regulation.  However, our concern is that the
     Bureau awarded this contract to a Del Webb-nominated appraiser on the
     basis of unusual and compelling urgency and cited as its
     justification the need "to avoid greater expense to the United States
     and weaken the integrity of the appraisal report."  The Bureau did
     not substantiate the urgency of this contract during the audit or in
     its response and chronology.
  
     July 16, 1996 Memorandum from Washington Office Chief Appraiser to
     Las Vegas District Manager, providing a copy of the initial appraisal
     review report prepared by the contract review appraisers. Washington
     Office Chief Appraiser advises the Las Vegas District Manager that
     some additional sales transactions are being reviewed which may
     provide some comparable sales information, and that the appraisal
     review report may need to be updated and may have an impact upon the
     appraised value. July 16, 1996 The Washington Office Chief Appraiser
     resolved any outstanding value issues by accepting the appraisal
     review, agreeing that the appraisal report and analysis reasonably
     supported the appraiser's $43 million value, and forwarding the
     appraisal and appraisal review to the District Manager for approval
     (see December 9, 1996, entry).
  
     September 10, 1996 Letter from Acting Deputy Director to Del Webb,
     advising Del Webb that appraisals may need to be revised if
     additional comparable sales information becomes available prior to
     final actions on the land exchange, to ensure that appraisals reflect
     current market value. September 10, 1996 No comment.
  
     October 14, 1996 Del Webb's appraiser completes update of earlier
     appraisal, including some comparison with comparable sales. Property
     appraised includes 4,776 acres and a separate value for Phase I only.
     Appraiser concludes $43,000,000 for entire property, and $20,285,000
     for Phase I only. October 14, 1996 As discussed in the report, this
     appraisal relied mainly on the development approach, which the
     "Uniform Appraisal Standards for Federal Land Acquisitions" states
     should be used only as a last resort or as a check on values derived
     by the more reliable comparable sales approach.
  
  
     October 31, 1996 An attachment to a December 17, 1996, letter to
     Senator McCain from the Chairman of the Board and Chief Executive
     Officer of Del Webb states: "At an October 31 meeting, one of Del
     Webb's representatives asked directly whether 'we had agreement on
     the Phase I and Phase II land values' as agreed to by the four
     appraisers. Both the Authorized Officer and the [Washington Office]
     Chief Appraiser answered 'yes.' Webb was told [by these officials]
     that the contract reviewers would be providing further information on
     the comparable sales discussed in the appraisal, but that the numbers
     [$43 million] were firm."
  
     November 4, 1996 Decision Record and Notice of Decision issued on the
     proposed land exchange, which provides for a 45 day public comment
     and protest period. November 4, 1996 The Bureau stated in its
     decision that the exchange was in the public interest and should
     proceed immediately. This followed the above-noted October 31, 1996,
     meeting between the Bureau's authorized officer, Del Webb's
     representatives, and the appraisers. We believe this indicates that
     the Bureau was willing to use the $43 million appraised value as the
     basis for proceeding with the exchange.
  
     November 21, 1996 E-Mail message from Washington Office Chief
     Appraiser to Washington Office Manager summarizing telephone
     conversations with Las Vegas District Manager and later with Del
     Webb's representatives. The District Manager expressed concern the
     values were too low and the report fails to use adequate comparable
     sales information. The Washington Office Chief Appraiser expressed
     concern with earlier drafts prepared by the reviewers. November 21,
     1996 We believe that the Bureau's comments regarding the Washington
     Office Chief Appraiser's "expressed concern with earlier drafts" were
     not consistent with his actions, since he accepted the appraisal
     review, agreed with the reviewers that the appraisal report and
     analysis reasonably supported the $43 million value, and forwarded
     the appraisal and appraisal review to the Las Vegas District Manager
     for approval (see December 9, 1996, entry).
  
     November 27, 1996 Protest letter from Sierra Club raises concern
     regarding the appraisal of lands and indicates the lands may be under
     valued. Requests an opportunity to review the appraisals. November
     27, 1996 No comment.
  
     December 5, 1996 Contract review appraisers submit appraisal review
     report. Their review includes reference to 10 potential comparable
     sales. The reviewers concluded, however, that the additional market
     analysis supported the Del Webb appraiser's opinion of value.
     December 5, 1996 No comment.
  
     December 9, 1996 The Washington Office Chief Appraiser, who was the
     contracting officer representative (COR), accepts the appraisal
     review report for purposes of authorizing payment under the contract
     only. The appraisal review prepared by the contract review appraisers
     was forwarded to the Las Vegas District Manager for approval. It was
     never approved by either the Las Vegas District Manager or the State
     Director.
  
     Washington Office Chief Appraiser, in his evaluation of the appraisal
     review report forwarded to Las Vegas District Manager, raised four
     issues: 1) A perception that the appraised values are too low; 2)
     agreement by the reviewers that the value per acre for Phase 1 is
     lower than for the entire tract; 3) the review report assumes the
     sale of the entire property and does not consider any lapse in time
     between the first and final transactions; 4) the review report
     assumes the land is free and clear of all encumbrances including
     mining claims and that any costs to clear assumed by a prospective
     buyer would be a reduction in value. Also included in the Washington
     Office Chief Appraiser's evaluation is a discussion of an option to
     prepare an additional appraisal or appraisal reviews. December 9,
     1996 In its chronology, the Bureau stated that the Washington Office
     Chief Appraiser "accepts the appraisal review report for purposes of
     authorizing payment under the contract only." When authorizing
     payment to contractors, contracting officer's representatives are
     required to ensure that the services and products provided to the
     government meet the requirements established in the purchase order.
     We believe that if the Washington Office Chief Appraiser accepted
     work that was not in full conformance with the "Standards," he did
     not fulfill his duties as the contracting officer's representative.
     In the evaluation report (page 4), the Washington Office Chief
     Appraiser states, "I agree with the reviewers that the appraisal
     report and the analysis reasonably supports the appraisers conclusion
     of value." In addition, we believe that the Chief Appraiser's
     statement that "the appraisal review is acceptable and is being
     forwarded to the authorized officer for their approval" indicates a
     recommendation to the authorized officer that the $43 million value
     should be used for the exchange.
  
     The four issues discussed by the Washington Office Chief Appraiser in
     his evaluation report involve significant deficiencies in the
     appraisal and appraisal review.  As such, we believe the Washington
     Office Chief Appraiser should not have accepted the appraisal review
     and forwarded it to the authorized officer for his approval.
  
     December 10, 1996 Protest letter from private citizen requesting an
     opportunity to review the appraisal reports and asserts that a
     competitive sale of the lands would increase values. December 10,
     1996 No comment.
  
     December 12, 1996 OIG notifies the Bureau of intent to perform a
     follow up audit of its Nevada land exchanges. This notification gave
     no indication that the ongoing Del Webb land exchange would be
     included in the follow up audit. The notification indicated only that
     "recently completed exchanges" would be reviewed. The Del Webb
     exchange was not completed at this time. December 12, 1996 The
     announcement memorandum for our audit stated that the objective of
     the audit would be "to determine whether the Nevada State Office,
     Bureau of Land Management, has complied with applicable laws and
     regulations during all phases of the land exchange process and
     whether the Bureau has received fair market value for the lands
     included in recently completed exchanges." (Emphasis added.)
  
     December 13, 1996 The Deputy Director asked the Office of Inspector
     General whether our audit would include ongoing exchanges and, in
     particular, if we would include the Del Webb exchange. During a
     telephone conversation, the auditor-in-charge of the followup audit
     informed the Bureau's Audit Liaison Officer that we intended to
     review all exchanges completed since our last audit and all exchanges
     currently in process, including the Del Webb exchange.
  
     December 16, 1996 Letter from Senator McCain to Assistant Secretary,
     Land and Minerals Management requesting information on the status of
     the Del Webb land exchange. December 16, 1996 No comment.
  
     December 17, 1996 Contract review appraisers provide a presentation
     in the BLM Washington Office on the appraisal review. Attendees were
     Department, BLM Headquarters, and field managers and staff, including
     Las Vegas District Manager and Nevada State Director . December 17,
     1996 No comment.
  
     December 18, 1996 Following the December 17 meeting, Las Vegas
     District Manager prepares handwritten comments critiquing Del Webb
     appraiser's appraisal report and review prepared by contract review
     appraisers. Copies of these comments were given to Washington Office
     Chief Appraiser and the contract review appraisers. The major issues
     raised by the Las Vegas District Manager regarded the cost approach
     for the appraisal, unsupported adjustments to price, and poor
     justification for the discount rate applied to the appraisal.
     December 18, 1996 A meeting was held on this date in the Bureau's
     Washington Office to discuss the status of the Del Webb exchange.
     Attendees consisted of the Deputy Director, the Nevada State
     Director, the Las Vegas District Manager, a representative of the
     Assistant Secretary for Lands and Minerals Management, and the
     Washington Office Chief Appraiser. According to the Chief Appraiser's
     notes of the meeting, discussions related to our followup audit
     included the following:
  
     - "IG [Inspector General] Audit -- We have indications from the IG
     that this audit may focus on appraisals and perhaps specifically the
     appraisal associated with the Del Webb exchange. The Bureau of Land
     Management will work with the Inspector General to schedule a meeting
     for the week of January 6, 1997 to discuss the subject of the audit
     in order to determine how to proceed with the Del Webb exchange."
  
     - "Appraisal -- The appraisal and the Review of the Appraisal were
     delivered to the State Director on December 10, 1996. These documents
     are under review and a decision by the authorized officer will be
     made following the meeting with the IG."
  
     - "The analysis of the appraisal, analysis and resolution of the
     protests, and all other work associated with the Del Webb exchange
     will proceed. No decisions will be made until after the meeting with
     the IG."
  
     December 18, 1996 Letter from Senator Reid to Assistant Secretary,
     Land and Minerals Management requesting information on the status of
     the Del Webb land exchange. December 18, 1996 No comment.
  
     December 19, 1996 Protest letter from Howard Hughes Corporation
     expressed concern that the appraisal documents were unavailable for
     review, and that values of the exchange lands are unknown. December
     19, 1996 No comment.
  
     December 19, 1996 Public comment period on the Notice of Decision
     ends. Seven protests are received on the land exchange. Three of
     these protests raise issues related to the appraisal of the lands
     involved in the exchange. (See the November 27, 1996, December 10,
     1996, and December 19, 1996 entries above.) December 19, 1996 No
     comment.
  
     December 23, 1996 Washington Office Chief Appraiser sends an
     electronic message to Nevada State Director, Las Vegas District
     Manager and others as a follow up to the Las Vegas District Manager's
     comments on the appraisal review. The Las Vegas District Manager's
     comments were also forwarded to contract review appraisers with a
     request for the contract review appraisers to respond to the
     comments. Washington Office Chief Appraiser concludes in the
     electronic message that: "Therefore, I still think we need an
     appraisal that relies primarily on a market analysis, which to the
     extent may be appropriate, includes a reference to the appraisal and
     appraisal review." December 23, 1996 The Washington Office Chief
     Appraiser stated in his December 9, 1996, evaluation report that he
     identified significant problems with the appraisal and review that
     could warrant obtaining a new appraisal. However, he concurred with
     the reviewer's acceptance of the value and forwarded the appraisal
     and review to the authorized officer for approval. Then, in the
     December 23, 1996, electronic mail message cited by the Bureau, the
     Washington Office Chief Appraiser stated that the Bureau should
     obtain a new appraisal which relies primarily on a market analysis.
     However, in a subsequent message to the review appraisers, the
     Washington Office Chief Appraiser stated that he wanted to "resurrect
     the appraisal and appraisal review" and that he did "not want
     management to be displeased with our efforts and flirt with trashing
     the whole thing."
  
     December 23, 1996 In response to the December 16, 1996, letter from
     Senator McCain and December 18, 1996, letter from Senator Reid, the
     Deputy Director writes to [the Senators] regarding BLM's progress in
     processing the Del Webb land exchange. The letter states that "we
     intend to follow all applicable statutes, regulations, and procedures
     in processing this exchange and to continue to involve the public, as
     appropriate, to ensure that any final exchange transaction serves the
     public interest." He also states: "Another factor which may
     potentially affect the timing of the Del Webb exchange is the
     investigation of land exchange activities in Nevada by the Office of
     Inspector General (IG)." The thought here is that if the IG
     discovered a serious deficiency, BLM would have taken the time to
     address and correct the problem. December 23, 1996 No comment.
  
  
     December 31, 1996 The Washington Office Chief Appraiser provided the
     contract review appraisers with his suggested responses to a portion
     of the District Manager's December 18, 1996, comments on the
     appraisal and appraisal review.
  
     January 2, 1997 The Chief Executive Officer, Del Webb Corporation
     writes Senator McCain criticizing BLM's handling of the land
     exchange. The letter references an upcoming meeting on January 7.
     January 2, 1997 No comment.
  
     January 6, 1997 The contract review appraiser respond to the Las
     Vegas District Manager's comments regarding the appraisal review
     report, including the concerns regarding the development cost
     approach for the appraisal. The review appraisers state: "This
     approach has current market acceptance, is very reliable given the
     depth of data available and provides subject specific value
     indicators which cannot be derived from the sales data." January 6,
     1997 No comment.
  
     January 7 and 8, 1997 The Las Vegas District Manager and Nevada State
     Director provide a briefing paper for discussions in meetings with
     BLM Washington Office, Solicitor's Office and the Assistant
     Secretary's Office of several issues concerning the appraisal report,
     the procedural error of not providing the public an opportunity to
     comment on the appraisal during the public comment period of the
     Notice of Decision, ledger imbalance, OIG audit, resolution of
     protests, and Nevada Power appeal. In a description of options, the
     Las Vegas District Manager indicates Washington Office Chief
     Appraiser recommends ordering new appraisal. Justification is the
     appraiser would be independent from first effort, fresh set of eyes,
     and an opportunity to clarify instructions. January 7 and 8, 1997 No
     comment.
  
     January 7, 1997 OIG holds entrance conference on the followup audit
     with BLM officials and informs BLM that the Del Webb land exchange
     will be included within the scope of audit. January 7, 1997 No
     comment.
  
     January 14, 1997 Letter from Deputy Director to Del Webb's Chief
     Executive Officer summarizing decisions made at a January 7-8 meeting
     of BLM and DOI officials. Officials discussed protests in response to
     the Notice of Decision (NOD) published on November 4, 1996. It was
     agreed a second appraisal would be ordered, a supplemental
     environmental assessment would be prepared, a new NOD would be
     issued, and property would be exchanged subject to Nevada Power
     right-of-way. January 14, 1997 No comment.
  
     January 21 and 22, 1997 Meetings with Del Webb in Washington, DC to
     address implementation of the January 14 letter. January 21 and 22,
     1997 No comment.
  
     January 27, 1997 BLM contracts for a second appraisal. The existing
     BLM Nevada contract list had only one appraiser from the Las Vegas
     area and we were concerned regarding the quality of his previous work
     and reports. Because the BLM Nevada Chief Appraiser had previously
     been removed from the appraisal work for this exchange (March 25,
     1996 decision), there was no consideration to bring him into the
     process again. The BLM decided to procure appraisal services from a
     reputable local firm not on the current contracting list. It was also
     decided by the State Director and Deputy Director that the Washington
     Office Chief Appraiser would review the appraisal report. The BLM
     contracted with a top Las Vegas accounting firm (second appraisers)
     that had an excellent appraisal staff. January 27, 1997 The Bureau's
     contract for a second appraisal required the appraisers to consider
     the results of the previous appraisal and appraisal review.
     Specifically, we noted that the contract statement of work prepared
     by the Washington Office Chief Appraiser included a requirement that
     the new appraisal "shall consider information, assumptions, and
     conclusions reached by [Del Webb's appraiser] in an appraisal report
     dated October 14, 1996." The statement of work also required that the
     appraiser "consider information, assumptions, and conclusions reached
     by [contract review appraisers] in their December 5, 1996 review of
     the [Del Webb's appraiser's] appraisal report."
  
     January 27, 1997 Solicitor's Office correspondence on this date stated
     that "specific concerns" remained relative to the purpose and scope
     of the second appraisal and appraisal review.
  
     During meetings with Del Webb's representatives, the Washington Office
     Chief Appraiser had stated that "the second appraisers would not
     start with a clean slate, but would be instructed to 'consider' the
     first appraisal." In the January 27, 1997, correspondence, a
     Solicitor's Office attorney disagreed with this approach, stating
     that "the purpose of the second appraisal is to truly provide a
     'second opinion' on the public land value, and to give decision
     makers information they are comfortable with. This should be clearly
     communicated to the second appraisers."
  
     The Solicitor's Office attorney was also concerned about the
     possibility of receiving another development cost approach appraisal.
     In the correspondence, the attorney stated: "Many in the Department
     are uncomfortable with the development cost approach, and the
     regulations show a clear preference for the market approach or
     comparable sales. This regulatory preference ought to be communicated
     to the appraiser, who should be instructed that if another method is
     used, the appraiser should give a clear and thorough rationale for
     not using market information."
  
     Finally, the Solicitor's Office attorney was concerned with how the
     second appraisal would be reviewed. According to the correspondence,
     the Washington Office Chief Appraiser had "expressed his belief that
     the same (outside) review appraisers should be used in the second as
     were used in the first." The Solicitor's Office attorney disagreed
     with this approach, stating that "an in-house review is called for to
     meet the goals outlined in paragraph one [to provide a second opinion
     of value and to give decision makers information they would be
     comfortable with]."
  
  
  
     January 30, 1997 Deputy Director sends a follow-up letter to the Del
     Webb Chief Executive Officer summarizing meetings with his staff on
     January 21-22, 1997. The meetings put in place procedural steps
     implementing decisions made at the January 7-8, 1997 meeting. A
     timetable prepared by Las Vegas District Manager is attached to the
     letter. January 30, 1997 No comment.
  
     February 25, 1997 Meeting with Del Webb in Washington, DC to discuss
     progress with the exchange. February 25, 1997 No comment.
  
  
     March 4, 1997 Based on a February 20, 1997, request by the Washington
     Office Chief Appraiser, the contracting officer issued a technical
     instruction which amended the contract by eliminating the requirement
     that the new appraisers should meet with the previous appraisers
     regarding their analyses and conclusions and instructing the new
     appraisers to state in their appraisal report that their conclusions
     reflected their own "independent judgement."
  
     March 21, 1997 BLM receives the second appraisal. The appraiser's
     conclusions were based on a comparable sale analysis and also
     evaluated and considered the Cost Development Approach from the
     earlier appraisal. March 21, 1997 We agree that the appraisers based
     their conclusion of value on the sales comparison approach ($52.1
     million for the entire 4,756-acre parcel assuming the exchange was
     consummated in two installments before the end of 1998 and $31.5
     million for the 2,535.5-acre Phase I land only). However, we noted
     that the appraisers evaluated and considered the cost development
     approach from the earlier appraisal "at the request of the client"
     (see discussion of January 27, 1997, regarding contract language) and
     that they concluded that "only the Sales Comparison Approach to value
     was directly applicable in this analysis."
  
     March 31, 1997 Washington Office Chief Appraiser accepts the
     appraisal report prepared by the contract appraiser. March 31, 1997
     No comment.
  
     April 8, 1997 Approval of appraised value by the Las Vegas District
     Manager and Nevada State Director. BLM letter to Del Webb providing
     copy of approved appraisal and offer of $31.5 million for Phase I of
     the Del Webb exchange. April 8, 1997 No comment.
  
     May 6, 1997 Del Webb acceptance of offer. May 6, 1997 No comment.
  
  
  
     May 21, 1997 New Notice of Decision issued for Phase I of the Del Webb
     exchange. Notice of Decision provides for public review of the
     approved appraisal.
  
     July 29, 1997 Title transfers and patents issued on the initial land
     transfers of Phase I-A of the Del Webb land exchange. May 21, 1997 No
     comment.
  
  
     July 29, 1997 No comment.
  
     


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