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Improved Oversight of the Land Exchange Process, but Additional Actions 
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Report to the Subcommittee on Interior, Environment, and Related 
Agencies, Committee on Appropriations, House of Representatives: 

United States Government Accountability Office: 
GAO: 

June 2009: 

Federal Land Management: 

BLM and the Forest Service Have Improved Oversight of the Land Exchange 
Process, but Additional Actions Are Needed: 

GAO-09-611: 

GAO Highlights: 

Highlights of GAO-09-611, a report to the Subcommittee on Interior, 
Environment, and Related Agencies, Committee on Appropriations, House 
of Representatives. 

Why GAO Did This Study: 

The Bureau of Land Management (BLM) in the Department of the Interior 
(Interior) and the Forest Service in the Department of Agriculture 
(USDA) manage millions of acres of public land. To enhance land 
management and fulfill other public objectives, they acquire and 
dispose of land using exchanges—trading federal lands for lands owned 
by willing private entities, individuals, or state or local 
governments. GAO and others have raised concerns about whether the 
public interest has always been served in these land exchanges. 

GAO was asked to (1) analyze the number, trends, and characteristics of 
BLM and Forest Service land exchanges and (2) determine the 
effectiveness of agency actions to address previously identified key 
problems. GAO interviewed and surveyed agency officials, analyzed 
agency data on recent exchanges, and reviewed documents on a 
nongeneralizable sample of 31 land exchanges representing at least 85 
percent of the acres that agencies acquired, or plan to acquire, during 
the time of GAO’s review. 

What GAO Found: 

From October 2004 through June 2008, BLM and the Forest Service 
processed 250 completed, pending, or terminated land exchanges. 
Completion times for exchanges within this period varied widely, from 2 
months to more than 12 years. These exchanges involved 628,429 federal 
acres and 621,588 nonfederal acres. According to agency officials, the 
number of exchanges since 2000 has generally declined because of the 
availability of qualified staff and funding and the lower priority 
given to land exchanges compared with other activities. Of the 250 land 
exchanges, 47 were facilitated by third parties, 9 were conducted in 
multiple phases, and 20 were specifically legislated by Congress. 

GAO, the agencies’ inspectors general, and others identified problems 
in the agencies’ land exchange programs and have made recommendations 
to correct them. The agencies have taken actions to address most of 
these problems, but the effectiveness of the actions has been mixed. 
Specifically: 

* According to most agency officials surveyed, headquarters reviews at 
least somewhat improved exchange quality; often ensured that exchanges 
complied with laws, regulations, and policies; and were processed 
properly. However, the reviews did not always document problems or 
indicate their resolution, making the process less transparent. 

* BLM stopped using interest-bearing accounts outside of the U.S. 
Treasury, according to agency officials, and issued new guidance on 
managing ledgers, which are used to track land value imbalances over 
time in multiphase exchanges. However, the agency is not always 
adhering to this guidance and, therefore, cannot fully know how much is 
owed. Specifically, BLM cannot be assured that the $2.6 million land 
value imbalance due to the United States, recorded in its ledgers as of 
June 30, 2008, is accurate. 

* Both agencies issued new guidance to require full disclosure of the 
relationship between a third-party facilitator and other parties to an 
exchange. But the guidance does not clearly define third-party 
facilitators and officials do not consistently apply the disclosure 
policy. Without consistent application, the agencies fail to obtain 
critical information and potentially risk losing the ability to control 
the exchange process. 

* The agencies updated their exchange guidance to provide clearer 
direction on exchanges and incorporated it into their training. 
However, staff generally are not required to attend this training, and 
the agencies do not systematically track staff participation. 
Therefore, the agencies cannot ensure that realty staff develop and 
maintain necessary skills. 

* The agencies took steps to improve appraisal timeliness, but the 
process, particularly for BLM, continues to delay some exchanges, 
officials said. 

Neither agency has a national strategy to guide land transactions, nor 
does either track all costs of individual exchanges. Developing 
national strategies and tracking the costs of individual exchanges will 
enhance the agencies’ ability to make informed decisions in pursuit of 
shared goals. 

What GAO Recommends: 

GAO is making recommendations to, among other things, strengthen 
agencies’ oversight of the land exchange process, realty staff 
training, planning for exchanges, and tracking of their costs. Forest 
Service generally agreed with GAO’s recommendations. Interior did not 
comment on the recommendations. 

View [hyperlink, http://www.gao.gov/products/GAO-09-611] or key 
components. For more information, contact Robin M. Nazzaro at (202) 512-
3841 or nazzaror@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

Number, Trends, and Characteristics of BLM and Forest Service Land 
Exchanges: 

Agencies' Actions to Resolve Previously Identified Key Problems Have 
Been Somewhat Effective, but Issues Remain: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Objectives, Scope, and Methodology: 

Appendix II: Prior Reviews and Audits of the BLM and Forest Service 
Land Exchange Programs: 

Appendix III: BLM Completed, Pending, or Terminated Land Exchanges, 
October 1, 2004, through June 30, 2008: 

Appendix IV: Forest Service Completed, Pending, or Terminated Land 
Exchanges, October 1, 2004, through June 30, 2008: 

Appendix V: Comments from the Department of Agriculture: 

Appendix VI: Comments from the Department of the Interior: 

Appendix VII: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: BLM and Forest Service Major Land Exchange Processing Steps 
and Responsible Party: 

Table 2: BLM and Forest Service Completed, Pending, or Terminated Land 
Exchanges, October 1, 2004, through June 30, 2008: 

Table 3: Difference between Estimated and Actual Completion Times for 
12 Exchanges in GAO's Sample: 

Table 4: Information on Multiphase Exchanges Processed by BLM Using 
Ledgers from October 1, 2004, through June 30, 2008, and Updated as of 
April 2009: 

Table 5: Twenty Legislated Land Exchanges Processed from October 1, 
2004, through June 30, 2008, and Selected Provisions That Differed from 
the Discretionary Exchange Process, if Any: 

Table 6: Previously Identified Key Problems and Agency Actions: 

Table 7: Survey Responses on the Extent to Which Headquarters Reviews 
Improved the Quality of Land Exchanges: 

Table 8: Number of Exchanges with Problems Documented by Agency Review 
Teams at the Feasibility and Decision Stages in GAO's Sample of 31 Land 
Exchanges: 

Table 9: Number of BLM Exchanges with Problems Documented in the 
Interior Solicitor's Feasibility and Decision Reviews: 

Table 10: Key Exchange Documents Provided by BLM and the Forest 
Service: 

Table 11: BLM Workgroup Recommendations and Actions Taken, as of April 
2008: 

Table 12: GAO Recommendations on Appraisal Quality and Timeliness and 
Agency Actions, as of March 2009: 

Figures: 

Figure 1: BLM Completed, Pending, or Terminated Land Exchanges, and 
Total Number of Federal and Nonfederal Acres Involved, October 1, 2004, 
through June 30, 2008: 

Figure 2: Forest Service Completed, Pending, or Terminated Land 
Exchanges, and Total Number of Federal and Nonfederal Acres Involved, 
October 1, 2004, through June 30, 2008: 

Figure 3: Location of Federal and Nonfederal Parcels Proposed for 
Exchange in the Terminated Blue Mountain Exchange in Northeastern 
Oregon: 

Abbreviations: 

ARRTS: Appraisal Request and Review Tracking System: 

ASD: Appraisal Services Directorate: 

ATI: Agreement to Initiate: 

BLM: Bureau of Land Management: 

CWALE: Central Washington Assembled Land Exchange II: 

FLPMA: Federal Land Policy and Management Act of 1976: 

FLTFA: Federal Land Transaction Facilitation Act of 2000: 

GSA: General Services Administration: 

Interior: Department of the Interior: 

NEPA: National Environmental Policy Act of 1969: 

SSFAS No. 4: Statement of Federal Financial Accounting Standards No. 4: 
Managerial Cost Accounting Concepts and Standards for the Federal 
Government: 

USDA: Department of Agriculture: 

[End of section] 

United States Government Accountability Office: Washington, DC 20548: 

June 12, 2009: 

The Honorable Norman D. Dicks:
Chairman:
The Honorable Michael K. Simpson:
Ranking Member:
Subcommittee on Interior, Environment, and Related Agencies: 
Committee on Appropriations:
House of Representatives: 

The Bureau of Land Management (BLM) and the Forest Service administer 
millions of acres of public land, and they continue to acquire and 
dispose of land in order to enhance federal land management, meet the 
needs of the public, and fulfill other public objectives. To acquire 
and dispose of lands, BLM and the Forest Service have long used land 
exchanges--trading federal lands for lands that are owned by private 
entities, individuals, states, or local governments who are willing to 
trade. Although BLM and the Forest Service have broad discretionary 
authority to conduct land exchanges with nonfederal parties, some land 
exchanges are specifically legislated by Congress. 

Generally, exchanges follow several required steps, including, among 
other things, assessing the public benefit, surveying the parcels, 
conducting resource and environmental analyses, determining market 
value, and assuring clear title to the land. In some cases, land 
exchanges are terminated before completion for a variety of reasons, 
such as public opposition. Agency realty specialists, assisted by many 
other experts, such as cultural and natural resource specialists, are 
responsible for processing these exchanges, and nonfederal landowners 
may hire third-party facilitators to assist. After agreeing to initiate 
a proposed exchange with a nonfederal party, the agencies must publish 
a notice of exchange proposal that, among other things, identifies the 
parties, describes the lands, and invites public comment. Exchanges can 
be straightforward--exchanging one land parcel for another--or more 
complex, such as multiphase exchanges where multiple parcels are 
exchanged over time to complete the exchange. If these exchanges occur 
over time, BLM regulations require the establishment of a land exchange 
ledger account to track the land value imbalances.[Footnote 1] 

The agencies' land exchange programs have often been controversial, and 
in the past, we and others have identified many concerns about how the 
agencies manage these exchanges.[Footnote 2] For example, the agencies 
have not always ensured that (1) the public interest was well served by 
the exchanges and (2) a third party facilitating an exchange has fully 
disclosed its interests in the exchange. The agencies have taken 
actions to address these problems, such as establishing headquarters 
review teams for land exchanges and revising policies and procedures. 
Although the agencies have instituted a number of reforms, the 
effectiveness of these actions has not been assessed. 

In this context, you asked us to (1) analyze the number, trends, and 
characteristics of BLM and Forest Service land exchanges, and (2) 
determine the actions BLM and the Forest Service have taken to address 
previously identified key problems and the effectiveness of these 
actions. 

To conduct our work, we reviewed relevant documents and interviewed BLM 
and Forest Service officials responsible for land exchanges at the 
field, regional or state, and headquarters offices, and other 
interested parties, including third-party facilitators and a state land 
trust official. To determine the previously identified key problems the 
agencies faced in the process of exchanging lands, we reviewed GAO 
reports, inspector general reports from the Department of the Interior 
(Interior) and the Department of Agriculture (USDA), The Appraisal 
Foundation, and BLM and Forest Service reviews. In addition, at our 
request, the agencies provided information on land exchanges processed 
from October 1, 2004, through June 30, 2008, including those that were 
pending, completed, or terminated[Footnote 3]. We reviewed a 
nongeneralizable sample of 31 exchanges, primarily selected because 
they represented 85 percent of the acres that the agencies have 
acquired or plan to acquire over the period we reviewed. For each land 
exchange in the sample, we reviewed key agency documents, such as 
headquarters and regional reviews of exchanges, to assess the agencies' 
actions to address previously identified key problems. In addition, we 
surveyed the land exchange program managers (program lead) in each of 
the 10 BLM state offices and the 9 Forest Service regions that had 
processed land exchanges over the period we reviewed to better 
understand the characteristics of land exchanges, previously identified 
key problems, and the impact of agency actions to address these 
problems. A more detailed description of our scope and methodology is 
presented in appendix I. 

We conducted this performance audit from March 2008 to June 2009 in 
accordance with generally accepted government auditing standards. Those 
standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe that 
the evidence obtained provides a reasonable basis for our findings and 
conclusions based on our audit objectives. 

Background: 

BLM and the Forest Service manage over two-thirds of the nation's 
public lands. Both agencies manage their lands for multiple uses, 
including providing sustained yield of renewable resources, such as 
timber, fish, wildlife, and forage for livestock, and supporting 
recreation. 

BLM, within Interior, manages more land--265 million acres--than any 
other federal agency. The land BLM manages is primarily located in 12 
western states, including Alaska. With a total budget of about $1 
billion, BLM also administers 700 million acres of subsurface mineral 
estates (rights) throughout the nation. BLM staff in headquarters, its 
12 state offices, and 144 field offices nationwide process land 
exchanges.[Footnote 4] 

The Assistant Director, Minerals and Realty Management, in the BLM 
headquarters office; the headquarters Lands, Realty, and Cadastral 
Survey staff; and their counterparts in the state and field offices are 
responsible for the land exchange program, among other activities. 
[Footnote 5] BLM has a headquarters land exchange program lead who 
oversees the land exchange program, and the BLM state offices have an 
exchange program lead with oversight responsibility. In addition, the 
BLM Deputy Director and Interior's Office of the Solicitor have 
oversight responsibilities for land exchanges. 

BLM operates the National Training Center in Phoenix, Arizona, which, 
in conjunction with the Forest Service, offers courses on land 
management for both agencies' staff. Three courses cover land exchanges 
in particular, among other things, for the two agencies' field realty 
staffs. 

The Forest Service, within USDA, manages 193 million acres of public 
land throughout the United States. Forest Service staff, located at 
headquarters, 9 regions, 155 national forests, and 20 grasslands, 
process land exchanges. 

At headquarters, the Forest Service's Director of Lands and Realty 
Management, the Assistant Director for Land Ownership Adjustment, and 
the National Program Leader for Land Adjustments (the headquarters 
exchange program lead) are responsible for the land exchange program, 
among other land transaction activities. Each region has a Director of 
Lands and a land ownership adjustment program manager (the regional 
exchange program lead) who oversee the work of realty staff at the 
forest level. In some cases, forests have in-house realty staff who 
conduct land exchanges; other forests have pooled realty staff from 
more than one forest in order to provide special services, such as land 
exchanges in more than one forest. 

Statutory Authority: 

The Federal Land Policy and Management Act of 1976 (FLPMA),[Footnote 6] 
as amended, authorizes both BLM and the Forest Service to exchange 
federal land for nonfederal land, when certain conditions are met, 
including the following: 

* The values of the federal and nonfederal lands to be exchanged must 
be equal, or if they are not equal, the values must be equalized by a 
cash payment so long as the payment does not exceed 25 percent of the 
federal land's value. The cash payment should be reduced to as small an 
amount as possible and, in certain circumstances, can be waived. 

* The cognizant agency must determine that the public interest will be 
well served by the exchange. 

* The lands to be exchanged must be in the same state. 

* Titles for the lands to be exchanged must be issued simultaneously 
(unless all parties to the exchange agree otherwise). 

* Land acquired within the boundaries of the national forest system, 
national park system, or any other system or area established by 
Congress immediately becomes part of that system. 

While BLM relies primarily on FLPMA to conduct exchanges, the Forest 
Service has several other exchange authorities.[Footnote 7] 

In addition to BLM's and the Forest Service's broad discretionary 
authority to conduct land exchanges, Congress sometimes enacts specific 
legislation that requires either agency to proceed with or provides 
authority to engage in a particular land exchange. This specific 
legislation may include provisions that alter the processing of the 
land exchange. For example, in describing these legislated exchanges, 
BLM's handbook advises that special legislation may prescribe certain 
aspects of the exchange process; allow for transactions not authorized 
under FLPMA (e.g., an interstate exchange); or simply direct that an 
exchange transaction be completed. The handbook states that 
transactions should be handled in a manner consistent with the specific 
legislation and, where guidance is not specified in the legislation, in 
conformance with nationally recognized appraisal standards and the 
regulations to the extent they apply. The Forest Service handbook also 
notes that legislated exchanges often include provisions that conflict 
with standard exchange authorities or regulations. 

Types of Land Exchanges: 

A land exchange involves the conveyance of public land or an interest 
in public land from a federal agency to a nonfederal party in return 
for desired nonfederal land that serves the public interest. These 
exchanges may be simple or more complex, such as a multiphase exchange. 
Specifically, a simple exchange may be a two-party transaction 
involving a single, nonfederal landowner. The agency provides a parcel 
of federal land (or interest in land) in exchange for a parcel of 
nonfederal land (or interest in land) in a single exchange transaction. 
The parcels are either of equal value, or either party may provide an 
equalization payment. 

BLM and the Forest Service conduct multiphase exchanges differently. At 
BLM, land values exchanged in each phase do not necessarily need to be 
equal, but at the final closing the land value must be equal or must be 
equalized with a cash payment. BLM uses records, called land exchange 
ledgers, to track the value conveyed by each party in the exchange and 
the balance due to the federal government or the nonfederal party after 
each phase. In contrast, the Forest Service requires that each phase of 
a multiphase exchange stand alone as equal in value. Furthermore, 
Forest Service regulations do not provide for the use of ledgers. Both 
agencies' multiphase land exchanges can range from those that involve 
multiple parcels under the same ownership, to those with multiple 
owners and involving third-party facilitators--private or nonprofit 
individuals or entities that assist nonfederal landowners by 
participating in the exchange and negotiating with the federal 
government to complete the exchange.[Footnote 8] 

In addition to exchanging land for land, the Forest Service has the 
authority to exchange land for timber.[Footnote 9] In land-for-timber 
exchanges, the agency acquires nonfederal land in exchange for the 
rights to federal timber (the nonfederal party is authorized to cut and 
remove an equal value of timber from a national forest). These 
exchanges may involve two parties, the Forest Service and a nonfederal 
party, or in the case of tripartite exchanges, three parties, when a 
timber sale contractor participates in the transaction. 

The Exchange Process: 

BLM and the Forest Service follow similar steps to process an exchange, 
including receiving or making a proposal for an exchange, conducting a 
feasibility analysis, signing a nonbinding Agreement to Initiate (ATI), 
obtaining appraisals of the land, conducting resource and environmental 
analyses, deciding on whether to complete the exchange, and preparing 
title and closing documents.[Footnote 10] The National Environmental 
Policy Act of 1969 (NEPA) generally requires the agencies to conduct 
environmental analyses.[Footnote 11] Under NEPA, agencies generally 
evaluate the likely environmental effects of projects they propose 
using an environmental assessment, or if the projects likely would 
significantly affect the environment, a more detailed environmental 
impact statement is prepared. However, if the Forest Service determines 
that an exchange falls within a category of activities the agency has 
already determined has no significant environmental impact--called a 
categorical exclusion--then the agency generally need not prepare an 
environmental assessment or an environmental impact statement.[Footnote 
12] 

BLM's land exchange handbook outlines a series of 26 major steps in the 
land exchange process. The Forest Service's handbook provides a more 
detailed series of implementation schedules for various types of 
exchanges (i.e., a land for land exchange or a Sisk Act exchange for 
cash),[Footnote 13] which include from 56 to 71 action items to reach 
completion. Table 1 lists the major steps and who is responsible for 
each of them. 

Table 1: BLM and Forest Service Major Land Exchange Processing Steps 
and Responsible Party: 

Major step: Evaluate the feasibility of the exchange proposal; 
Responsible party: Field manager and staff[A]. 

Major step: Review the feasibility analysis and grant or deny approval 
for processing the exchange; 
Responsible party: State office or region and headquarters review team; 
in addition, Interior's Solicitor reviews BLM's feasibility analyses. 

Major step: Execute the ATI; 
Responsible party: Field manager and nonfederal party. 

Major step: Publish a Notice of Exchange Proposal; 
Responsible party: Field manager. 

Major step: Conduct resource and NEPA studies and request appraisal 
services; 
Responsible party: Field manager. 

Major step: Prepare draft decision document; Responsible party: Field 
manager. 

Major step: Review and approve draft decision; 
Responsible party: State office, region, or headquarters review staff; 
in addition, Interior's Solicitor reviews BLM's draft decision 
documents. 

Major step: Issue a decision; 
Responsible party: Field manager. 

Major step: Prepare title opinions; 
Responsible party: Interior's Solicitor, USDA General Counsel, or in 
some cases, the Department of Justice. 

Major step: Execute closing documents to transfer the federal and 
nonfederal lands; 
Responsible party: Field manager and nonfederal party. 

Source: GAO's analysis of agency land exchange handbooks. 

[A] At BLM, field manager refers to a BLM Field Office Manager. At the 
Forest Service, field manager refers to a Forest Supervisor or other 
designated authorized officer. 

[End of table] 

Number, Trends, and Characteristics of BLM and Forest Service Land 
Exchanges: 

BLM and the Forest Service processed 250 land exchanges from October 1, 
2004, through June 30, 2008. Completion times for land exchanges within 
this period varied widely, from about 2 months to more than 12 years. 
Agency officials surveyed said the number of exchanges processed since 
2000 has generally declined because of the availability of qualified 
staff, changing priorities, and the availability of funding. Some of 
the exchanges had unique characteristics because they were facilitated 
by third parties, conducted in multiple phases, or were specifically 
legislated by Congress. See appendixes III and IV for detailed 
information on the 250 exchanges processed from October 1, 2004, 
through June 30, 2008, as reported by BLM state offices and Forest 
Service regional officials. 

Agencies Processed 250 Land Exchanges to Acquire about 621,600 Acres 
between 2004 and 2008: 

Of the 250 exchanges processed from October 1, 2004, through June 30, 
2008, BLM processed 76 and the Forest Service processed 174. Table 2 
provides information on the completed, pending, and terminated 
exchanges the agencies processed. 

Table 2: BLM and Forest Service Completed, Pending, or Terminated Land 
Exchanges, October 1, 2004, through June 30, 2008: 

Exchange status by agency: Completed: BLM; 
Number of exchanges: 38; 
Number of nonfederal acres acquired or planned for acquisition: 
126,105; 
Value of nonfederal acres acquired or planned for acquisition[A]: 
$41,344,844; 
Number of federal acres conveyed or planned for conveyance: 118,658; 
Value of federal acres conveyed or planned for conveyance[B]: 
$53,960,365. 

Exchange status by agency: Completed: Forest Service; 
Number of exchanges: 109; 
Number of nonfederal acres acquired or planned for acquisition: 63,293; 
Value of nonfederal acres acquired or planned for acquisition[A]: 
$101,748,556; 
Number of federal acres conveyed or planned for conveyance: 317,568; 
Value of federal acres conveyed or planned for conveyance[B]: 
$101,413,065. 

Exchange status by agency: Completed: Subtotal; 
Number of exchanges: 147; 
Number of nonfederal acres acquired or planned for acquisition: 
189,398; 
Value of nonfederal acres acquired or planned for acquisition[A]: 
$143,093,400; 
Number of federal acres conveyed or planned for conveyance: 436,226; 
Value of federal acres conveyed or planned for conveyance[B]: 
$155,373,430. 

Exchange status by agency: Pending: BLM; 
Number of exchanges: 31; 
Number of nonfederal acres acquired or planned for acquisition: 
302,522; 
Value of nonfederal acres acquired or planned for acquisition[A]: 
$47,928,988; 
Number of federal acres conveyed or planned for conveyance: 102,764; 
Value of federal acres conveyed or planned for conveyance[B]: 
$31,195,241. 

Exchange status by agency: Pending: Forest Service; 
Number of exchanges: 59; 
Number of nonfederal acres acquired or planned for acquisition: 92,701; 
Value of nonfederal acres acquired or planned for acquisition[A]: 
$37,187,575; 
Number of federal acres conveyed or planned for conveyance: 67,159; 
Value of federal acres conveyed or planned for conveyance[B]: 
$57,498,100. 

Exchange status by agency: Pending: Subtotal; 
Number of exchanges: 90; 
Number of nonfederal acres acquired or planned for acquisition: 
395,223; 
Value of nonfederal acres acquired or planned for acquisition[A]: 
$85,116,563; 
Number of federal acres conveyed or planned for conveyance: 169,923; 
Value of federal acres conveyed or planned for conveyance[B]: 
$88,693,341. 

Exchange status by agency: Terminated: BLM; 
Number of exchanges: 7; 
Number of nonfederal acres acquired or planned for acquisition: 3,583; 
Value of nonfederal acres acquired or planned for acquisition[A]: 
$118,150; 
Number of federal acres conveyed or planned for conveyance: 3,505; 
Value of federal acres conveyed or planned for conveyance[B]: $121,250. 

Exchange status by agency: Terminated: Forest Service; 
Number of exchanges: 6; 
Number of nonfederal acres acquired or planned for acquisition: 33,384; 
Value of nonfederal acres acquired or planned for acquisition[A]: 
$16,716,071; 
Number of federal acres conveyed or planned for conveyance: 18,777; 
Value of federal acres conveyed or planned for conveyance[B]: 
$16,994,071. 

Exchange status by agency: Terminated: Subtotal; 
Number of exchanges: 13; 
Number of nonfederal acres acquired or planned for acquisition: 36,967; 
Value of nonfederal acres acquired or planned for acquisition[A]: 
$16,834,221; 
Number of federal acres conveyed or planned for conveyance: 22,282; 
Value of federal acres conveyed or planned for conveyance[B]: 
$17,115,321. 

Exchange status by agency: Total: BLM total; 
Number of exchanges: 76; 
Number of nonfederal acres acquired or planned for acquisition: 
432,210; 
Value of nonfederal acres acquired or planned for acquisition[A]: 
$89,391,982; 
Number of federal acres conveyed or planned for conveyance: 224,926; 
Value of federal acres conveyed or planned for conveyance[B]: 
$85,276,856. 

Exchange status by agency: Total: Forest Service total; 
Number of exchanges: 174; 
Number of nonfederal acres acquired or planned for acquisition: 
189,378; 
Value of nonfederal acres acquired or planned for acquisition[A]: 
$155,652,202; 
Number of federal acres conveyed or planned for conveyance: 403,503; 
Value of federal acres conveyed or planned for conveyance[B]: 
$175,905,236. 

Exchange status by agency: Total; 
Number of exchanges: 250; 
Number of nonfederal acres acquired or planned for acquisition: 
621,588; 
Value of nonfederal acres acquired or planned for acquisition[A]: 
$245,044,184; 
Number of federal acres conveyed or planned for conveyance: 628,429; 
Value of federal acres conveyed or planned for conveyance[B]: 
$261,182,092. 

Source: GAO analysis of information reported by BLM state and Forest 
Service regional offices. 

[A] The values represent the number of acres planned for acquisition 
with appraised values as of June 30, 2008. Overall, the agencies 
reported appraised values for 75 percent of the acres. The remaining 
acres had not been appraised. 

[B] The values represent the number of acres planned for conveyance 
with appraised values as of June 30, 2008. The agencies reported 
appraised values for 85 percent of the acres. The remaining acres had 
not been appraised. 

[End of table] 

As table 2 shows, 13 proposed land exchanges resulted in termination 
for various reasons, according to agency officials, including 
withdrawal of either party, changes in land values, legal action, and 
public opposition. For example, according to a BLM official, the 
agency's Mesa Mood exchange in Colorado was terminated because of an 
appeal to the Interior Board of Land Appeals by the adjacent landowner, 
primarily about the appraised value of the federal land. Because of 
these actions, another appraisal had to be conducted. However, the 
landowner involved in the exchange decided to sell the property to 
another party because the exchange process was taking too long. 

As figure 1 shows, BLM's exchange activity occurred in 11 western 
states.[Footnote 14] BLM's Colorado State Office had the most activity, 
processing 18 completed, pending, or terminated exchanges. 

Figure 1: BLM Completed, Pending, or Terminated Land Exchanges, and 
Total Number of Federal and Nonfederal Acres Involved, October 1, 2004, 
through June 30, 2008: 

[Refer to PDF for image: map of the United States and associated data] 

States with BLM land exchange activity, including number of exchanges 
processed and total acreage involved: 

State: Arizona; 
Number of exchanges: 3; 
Total acreage involved: 38,693. 

State: California; 
Number of exchanges: 12; 
Total acreage involved: 178,555. 

State: Colorado; 
Number of exchanges: 18; 
Total acreage involved: 127,624. 

State: Idaho; 
Number of exchanges: 10; 
Total acreage involved: 16,624. 

State: Montana; 
Number of exchanges: 5; 
Total acreage involved: 32,674. 

State: Nevada; 
Number of exchanges: 3; 
Total acreage involved: 59,678. 

State: New Mexico; 
Number of exchanges: 8; 
Total acreage involved: 97,933. 

State: Oregon[A]; 
Number of exchanges: 4; 
Total acreage involved: 68,865. 

State: Utah; 
Number of exchanges: 6; 
Total acreage involved: 27,969. 

State: Washington[A]; 
Number of exchanges: 3; 
Total acreage involved: [Refer to Oregon total]. 

State: Wyoming; 
Number of exchanges: 4; 
Total acreage involved: 8,521. 

Sources: GAO analysis of BLM data; Map Resources (map). 

[A] BLM's Oregon State Office also manages land in Washington. The acre 
figure listed for Oregon is for both states. 

[End of figure] 

In contrast, as figure 2 shows, Forest Service Region 9 had the 
greatest number of completed, pending, or terminated exchanges. 
According to data provided by the Forest Service, 16 of these exchanges 
were small tripartite land-for-timber exchanges in which nonfederal 
land was exchanged for the rights to harvest federal timber cut by a 
third party on behalf of the exchange parties. However, the largest 
number of acres exchanged was for one exchange in Region 8. 
Specifically, this exchange, referred to as the State of Florida 
exchange, involved 316,034 federal and nonfederal acres, nearly all of 
which were subsurface acres.[Footnote 15] 

Figure 2: Forest Service Completed, Pending, or Terminated Land 
Exchanges, and Total Number of Federal and Nonfederal Acres Involved, 
October 1, 2004, through June 30, 2008: 

[Refer to PDF for image: map of the United States and associated data] 

Region: 1; 
Completed, Pending, or Terminated Land Exchanges: 19; 
* Idaho: 3[A]; 
* Montana: 16; 
Total Number of Federal and Nonfederal Acres Involved: 49,056. 

Region: 2; 
Completed, Pending, or Terminated Land Exchanges: 32; 
* Colorado: 20; 
* Nebraska: 1; 
* South Dakota: 7; 
* Wyoming: 4; 
Total Number of Federal and Nonfederal Acres Involved: 67,437. 

Region: 3; 
Completed, Pending, or Terminated Land Exchanges: 13; 
* Arizona: 13; 
* New Mexico: 1; 
Total Number of Federal and Nonfederal Acres Involved: 62,452. 

Region: 4; 
Completed, Pending, or Terminated Land Exchanges: 6; 
* Idaho: 4[A]; 
* Utah: 2; 
Total Number of Federal and Nonfederal Acres Involved: 3,413. 

Region: 5; 
Completed, Pending, or Terminated Land Exchanges: 24; 
* California: 24; 
Total Number of Federal and Nonfederal Acres Involved: 16,079. 

Region: 6; 
Completed, Pending, or Terminated Land Exchanges: 7; 
* Oregon: 3; 
* Washington: 4; 
Total Number of Federal and Nonfederal Acres Involved: 50,426. 

Region: 8; 
Completed, Pending, or Terminated Land Exchanges: 32; 
* Alabama: 1; 
* Arkansas: 10[B]; 
* Florida: 2; 
* Georgia: 5; 
* Mississippi: 3; 
* North Carolina: 2; 
* Oklahoma: 5[B]; 
* South Carolina: 1; 
* Tennessee: 2; 
* Virginia: 1; 
Total Number of Federal and Nonfederal Acres Involved: 331,613. 

Region: 9; 
Completed, Pending, or Terminated Land Exchanges: 40; 
* Illinois: 1; 
* Indiana: 2; 
* Michigan: 12; 
* Minnesota: 5; 
* Missouri: 16; 
* New Hampshire: 1; 
* Ohio: 2; 
* Vermont: 1; 
Total Number of Federal and Nonfederal Acres Involved: 9,638. 

Region: 10; 
Completed, Pending, or Terminated Land Exchanges: 1; 
* Alaska: 1; 
Total Number of Federal and Nonfederal Acres Involved: 320. 

Sources: GAO analysis of Forest Service data; Map Resources (map). 

Notes: The Forest Service does not have a Region 7. 

[A] The State of Idaho is split between Regions 1 and 4. 

[B] Region 8 reported that one exchange was located in Arkansas and 
Oklahoma. For this figure, that exchange is listed with Arkansas. 

[End of figure] 

Land Exchange Completion Times Varied Greatly and Sometimes Exceeded 
Estimated Time Frames: 

Of the 250 exchanges processed from October 1, 2004, through June 30, 
2008, 147 were completed, with completion times ranging from about 2 
months to more than 12 years between the date the ATI was signed and 
the date the titles were recorded.[Footnote 16] The time to complete 
BLM's 38 land exchanges averaged about 4 years, while the Forest 
Service's 109 land exchanges averaged about 2 years. A few of the 
completed exchanges had processing times of over a decade. For example, 
BLM's Eldorado exchange in Nevada took 11 years and 3 months to 
complete, and the Forest Service's Trust for Public Land exchange in 
North Carolina took about 12 years and 8 months. Conversely, some 
exchanges were completed in a shorter time. For instance, BLM's Blevins 
exchange in Idaho took about 10 months to complete. BLM's handbook 
provides an estimated average completion time of 18 to 24 months but 
notes that times vary widely. The Forest Service's handbook does not 
specify an average time to complete an exchange. 

In examining the 31 land exchanges in our sample, we observed that the 
agencies took much longer, in all but one case, to complete exchanges 
than they had estimated in their ATIs. For 12 of the 15 completed 
exchanges in our sample, we were able to obtain both estimated and 
actual completion dates, as table 3 shows. 

Table 3: Difference between Estimated and Actual Completion Times for 
12 Exchanges in GAO's Sample: 

Agency and state: BLM: Arizona; 
Exchange name: Phelps Dodge; 
Date ATI signed: 4/4/1995; 
Estimated completion date: 9/1/1996; 
Actual completion date: 9/16/2005; 
Years between estimated and actual completion dates: 9.04. 

Agency and state: BLM: Colorado; 
Exchange name: Emerald Mountain; 
Date ATI signed: 8/20/2004; 
Estimated completion date: 8/1/2005; 
Actual completion date: 2/22/2007; 
Years between estimated and actual completion dates: 1.56. 

Agency and state: BLM: Nevada; 
Exchange name: Indian Creek; 
Date ATI signed: 11/21/1994; 
Estimated completion date: 4/25/1995; 
Actual completion date: 1/5/2005; 
Years between estimated and actual completion dates: 9.70. 

Agency and state: BLM: New Mexico; 
Exchange name: Adobe; 
Date ATI signed: 8/25/1998; 
Estimated completion date: 12/31/1999; 
Actual completion date: 3/23/2007; 
Years between estimated and actual completion dates: 7.23. 

Agency and state: BLM: Utah; 
Exchange name: Hogup; 
Date ATI signed: 11/15/2001; 
Estimated completion date: 2/9/2001; 
Actual completion date: 12/22/2004; 
Years between estimated and actual completion dates: 3.87. 

Agency and state: BLM: Wyoming; 
Exchange name: P & M Coal; 
Date ATI signed: 12/18/2000; 
Estimated completion date: 11/1/2002; 
Actual completion date: 2/3/2005; 
Years between estimated and actual completion dates: 2.26. 

Agency and state: Forest Service: Arizona; 
Exchange name: Dry Lakes; 
Date ATI signed: 4/26/2002; 
Estimated completion date: 9/1/2004; 
Actual completion date: 7/24/2006; 
Years between estimated and actual completion dates: 1.89. 

Agency and state: Forest Service: Arizona: Gray Wolf; 
Date ATI signed: 9/24/2001; 
Estimated completion date: 9/1/2002; 
Actual completion date: 6/19/2007; 
Years between estimated and actual completion dates: 4.80. 

Agency and state: Forest Service: California; 
Exchange name: Mammoth Community Facilities; 
Date ATI signed: 1/11/2005; 
Estimated completion date: 6/16/2006; 
Actual completion date: 11/9/2007; 
Years between estimated and actual completion dates: 1.40. 

Agency and state: Forest Service: Florida; 
Exchange name: State of Florida; 
Date ATI signed: 5/4/2001; 
Estimated completion date: 4/1/2004; 
Actual completion date: 4/5/2005; 
Years between estimated and actual completion dates: 1.01. 

Agency and state: Forest Service: Oklahoma; 
Exchange name: Forest Ridge; 
Date ATI signed: 6/8/2006; 
Estimated completion date: 4/1/2007; 
Actual completion date: 2/20/2007; 
Years between estimated and actual completion dates: (0.11). 

Agency and state: Forest Service: Wyoming; 
Exchange name: Dull Center (Dilts); 
Date ATI signed: 7/30/2001; 
Estimated completion date: 11/1/2001; 
Actual completion date: 5/10/2005; 
Years between estimated and actual completion dates: 3.52. 

Source: GAO analysis of BLM state and Forest Service regional 
information. 

[End of table] 

For the 11 exchanges that took longer to complete than estimated, our 
analysis shows that they took from 1 to more than 9 years longer. 

In explaining the reasons for these delays, BLM and Forest Service 
survey respondents most frequently cited the lack of staff, the 
timeliness of appraisals, and the lack of qualified appraisers. In 
terms of the lack of staff, officials from both agencies have reported 
that owing to an increasing number of retirements and the need to work 
on higher priority activities--such as processing energy rights-of-way-
-staff may not be available to process exchanges. In commenting on a 
draft of this report, Interior stated that BLM also believes that 
protests, appeals, and litigation are reasons for delays in completing 
land exchanges. 

BLM officials also told us that issues with the appraisal process could 
inhibit the timely completion of exchanges. These issues include the 
time needed for the appraiser to obtain information on encumbrances on 
the land, the potential need for new appraisals every few months in a 
volatile market when land values change frequently, and the limited 
number of private appraisers with the necessary experience to appraise 
the undeveloped lands involved in BLM exchanges accurately. 

Forest Service regional officials cited the following other factors 
that can impede the timely completion of land exchanges: 

* Adjacent landowners may have concerns about the impact of the 
exchange on their property. Land exchange regulations require the 
agencies to publish a notice of exchange proposal. Those opposed can 
appeal or litigate land exchange decisions. 

* Land surveys to validate the legal description of land and 
environmental analyses can cause considerable delays in the process. 
Forest Service officials reported experiencing delays of 1 to 2 years 
for completing the required surveys and cited the addition and 
subtraction of land included in the exchange as delaying the exchange 
process. When land is added to the exchange midway through the process, 
this piece of land is subject to all of the steps in the exchange 
process, including notifying the public of the exchange proposal, 
updating environmental analyses, and conducting field inspections and 
other analyses. Land may also be subtracted from the exchange for many 
reasons, including the identification of a cultural site, unresolved 
title issues, and the nonfederal landowner's decision not to sell. If 
land is either added or subtracted during the exchange process, then 
the need to balance federal and nonfederal land values after the 
initial appraisals can increase the exchange processing time because 
new appraisals have to be conducted. 

* If a landowner dies before an exchange is completed, agency officials 
will have to work with new landowners. 

Since 2000, the Number of BLM and Forest Service Land Exchanges Has 
Declined for Several Reasons: 

The number of land exchanges for the period we reviewed, October 1, 
2004, through June 30, 2008, is lower than for the period we previously 
examined, fiscal years 1989 through 1999.[Footnote 17] As we reported 
in 2000, the Forest Service completed an average of 115 land exchanges 
annually from fiscal years 1989 through 1999. In contrast, for the 
period we reviewed through June 2008, the Forest Service completed an 
average of 29 exchanges annually. BLM did not provide information on 
the number of exchanges completed for our 2000 report, but instead 
reported transactions--that is, one parcel of land either conveyed or 
acquired. For the earlier period reviewed, BLM reported 238 separate 
transactions annually.[Footnote 18] For our current review, BLM 
reported completing 38 exchanges, or an average of 10 per fiscal year. 

Fourteen of the 19 BLM and Forest Service officials we surveyed 
confirmed this decrease in the number of land exchanges processed since 
2000.[Footnote 19] In order of frequency, the officials cited the 
availability of qualified staff, changes in the priority given to 
exchanges relative to other work, and the availability of agency 
funding to process exchanges as the primary reasons for the decline. 
More specifically: 

* Availability of qualified realty staff. Officials from both agencies 
stated that they have experienced significant turnover in personnel, 
largely because of retirements. In addition, they have been unable to 
replace such staff because of declining budgets. This reduction in 
qualified staff limits the agencies' ability to perform lower priority 
work, such as land exchanges. For example, according to Forest Service 
officials, the Tonto National Forest in Arizona has experienced a 50- 
percent reduction in realty staff, from four to two, in 2 years. When 
realty staff leave or retire before the exchange is completed, the 
agencies are less able to maintain consistency and effectiveness. In 
response to staff shortages, some Forest Service regions have begun 
pooling realty staff across their region to work on complex realty 
transactions, such as land exchanges, rather then specifically 
assigning them to a particular forest or ranger district exclusively. 
They refer to these pooled resources as "zone teams." According to 
BLM's land exchange program lead, newly hired realty staff require 
coaching and training on the exchange process because they often lack 
experience handling complex land exchanges. 

* Changing priorities. Because exchanges typically are discretionary 
activities, their processing often competes for staff time and 
attention with other land transactions. In particular, the agencies 
have shifted focus from processing discretionary land exchanges to 
processing energy rights-of-way, land acquisitions, administrative site 
sales, and special-use permits. We found that BLM has focused more on 
sales under the Federal Land Transaction Facilitation Act of 2000 
instead of exchanges.[Footnote 20] Indeed, an official from the BLM 
Nevada State Office told us the agency is not currently pursuing any 
land exchanges in Nevada because it is focusing on the sales program. 
As we reported in February 2008,[Footnote 21] as of May 2007, the state 
accounted for 92 percent, or $88 million, of the revenue raised under 
the Federal Land Transaction Facilitation Act through land sales. In 
addition, Forest Service officials said that enactment of the Forest 
Service Facility Realignment and Enhancement Act of 2005 caused a 
significant priority shift to administrative site sales.[Footnote 22] 
According to Forest Service officials, Regions 3 and 6 focus on 
administrative site sales instead of land exchanges because these sales 
allow the agency to generate revenue. 

* Availability of agency funding. According to agency officials we 
interviewed, the same appropriation account funds land exchanges and 
other land management activities, such as processing special-use 
permits and energy rights-of-way, sales and other land adjustments, and 
boundary and title management. Therefore, officials said, processing 
land exchanges competes for funding with other activities that 
currently have a higher priority. To compensate for the decline in 
exchange funding, the agencies have been relying more on nonfederal 
parties to pay exchange processing costs. While the agencies' guidance 
generally states that both the federal and nonfederal parties should 
share the costs associated with processing land exchanges equally, the 
agencies vary in the extent to which nonfederal parties share the cost 
of processing exchanges. According to 4 of 10 BLM and 3 of 9 Forest 
Service officials we surveyed, the agencies often give priority to 
exchanges in which the nonfederal party pays over half of the 
processing costs. One of these BLM officials said that, in some cases, 
when an exchange is supported by many different interest groups and 
there is a clear benefit to many parties, BLM may be willing to pay the 
majority of the processing costs. At the Forest Service, one survey 
respondent said his region now conducts land exchanges only if the 
nonfederal party pays 100 percent of the processing costs. According to 
Forest Service headquarters officials, however, nonfederal parties can 
never pay 100 percent of the processing costs of an exchange because 
they would not pay for certain Forest Service costs, such as the Office 
of General Counsel and regional reviews of land exchanges. One Forest 
Service regional official cautioned that when nonfederal parties pay 
more of the exchange costs, pressure increases on realty staff to 
complete exchanges. 

Some of the Land Exchanges Had Unique Characteristics: 

Some of the 250 land exchanges processed from October 1, 2004, through 
June 30, 2008, had unique characteristics. Specifically, these 
exchanges were facilitated by third parties, conducted in multiple 
phases, or legislated. In some cases, exchanges had more than one of 
these characteristics. 

Forty-seven Facilitated Land Exchanges Involved Several Private and 
Nonprofit Facilitators: 

BLM and the Forest Service processed 47 land exchanges--16 and 31, 
respectively--involving private and nonprofit third-party facilitators 
from October 1, 2004, through June 30, 2008. The for-profit 
facilitators included Clearwater Land Exchange, FLEX of Arizona, Summit 
Resources, and Western Land Group. The nonprofit facilitators included 
the Conservation Fund, the Wildlands Conservancy, and the Prickly Pear 
Land Trust. The 19 BLM state and Forest Service regional officials we 
surveyed most often cited the third-party facilitators' primary tasks 
as helping the agencies work with the nonfederal parties participating 
in the exchange, identifying nonfederal lands for the exchange, and 
submitting exchange proposals. For example: 

* BLM's Emerald Mountain exchange in Colorado involved BLM, the state, 
and private landowners and was initiated in August 2004. The third- 
party facilitator for this exchange, Western Land Group, worked with 
about 50 landowners to identify parcels available for disposal, 
obtained commitments from private parties to purchase the parcels, and 
worked with all parties to simultaneously close the exchange in 
February 2007. At the closing, BLM and the private parties received 
land, and the state received cash. 

* The Forest Service's Mammoth Community Facilities exchange in 
California involved the Forest Service, the Mammoth fire station, and a 
hospital. To help process this exchange, the fire station and hospital 
hired Western Land Group to identify and acquire parcels suitable for 
exchange for 12.52 acres of Forest Service land. This facilitator 
identified about 3,000 acres, owned by four individuals, that the 
Forest Service was interested in acquiring. The lands acquired were 
inholdings in three national forests in California--Inyo, Eldorado, and 
Tahoe.[Footnote 23] 

BLM state office and Forest Service regional officials surveyed most 
often cited third-party facilitators as benefiting the land exchange 
process. Specifically, BLM and Forest Service officials most often 
reported that third-party facilitators assured the commitment of 
nonfederal landowners to complete the land exchange, served as a 
knowledgeable party for the nonfederal landowner to work with, and 
enhanced communications between the agency and the nonfederal 
landowners. 

Conversely, a few survey respondents reported that facilitators 
sometimes have a negative impact on the exchange process. Three survey 
respondents--two from BLM and one from the Forest Service--reported 
that facilitators often increased the pressure to complete the 
exchange. One Forest Service official reported that facilitators often 
inhibit agency communication with the nonfederal landowners. 
Furthermore, a Forest Service respondent reported that in the Blue 
Mountain exchange in Oregon, the facilitator hindered the exchange 
process by being uncooperative with both the Forest Service and the 
nonfederal landowners, and the Forest Service terminated the exchange 
just before the closing. In addition, a representative of a nonprofit 
organization that monitors federal land exchanges said that 
facilitators might try to skew appraisals in order to offset the costs 
they have incurred, and they can create an unhealthy push to process 
legislated exchanges quickly, with insufficient public scrutiny. 

Eight of Nine BLM Multiphase Land Exchanges Used Ledgers to Track the 
Balance of Land Values: 

BLM processed nine multiphase exchanges during the period of our 
review. Eight of these exchanges involved seven ledgers--three open and 
four closed--to track land value imbalances from October 1, 2004, 
through June 30, 2008. Two exchanges in New Mexico--Santo Domingo II 
and Acoma/State Mineral--are both included on one ledger. The ninth 
multiphase exchange in Idaho--Birch Creek--did not have a ledger for 
its final phase. According to the ledgers associated with these 
exchanges, nonfederal parties owe approximately $2.6 million to the 
federal government, as documented in the open ledgers. Table 4 provides 
further details on the nine multiphase exchanges. 

Table 4: Information on Multiphase Exchanges Processed by BLM Using 
Ledgers from October 1, 2004, through June 30, 2008, and Updated Status 
as of April 2009: 

BLM state office and exchange name: California: Palo Verde; 
Nonfederal acres acquired or planned for acquisition: 29,538; 
Value of nonfederal acres acquired or planned for acquisition: 
$6,187,100; 
Federal acres conveyed or planned for conveyance: 2,007; 
Value of federal acres conveyed or planned for conveyance: $6,472,000; 
Status (completed, pending, or terminated): Completed; 
Date completed: 6/23/06; 
Ledger status (open or closed): Closed; 
Ledger balance (amount owed to US): $0. 

BLM state office and exchange name: State of California; 
Nonfederal acres acquired or planned for acquisition: 123,423; 
Value of nonfederal acres acquired or planned for acquisition: 
$12,232,316; 
Federal acres conveyed or planned for conveyance: 2,290; 
Value of federal acres conveyed or planned for conveyance: $14,314,091; 
Status (completed, pending, or terminated): Pending; 
Date completed: [Empty]; 
Ledger status (open or closed): Open; 
Ledger balance (amount owed to U.S.): $2,154,675. 

BLM state office and exchange name: Idaho: Birch Creek; 
Nonfederal acres acquired or planned for acquisition: 315; 
Value of nonfederal acres acquired or planned for acquisition: 
$283,500; 
Federal acres conveyed or planned for conveyance: 272; 
Value of federal acres conveyed or planned for conveyance: $79,105; 
Status (completed, pending, or terminated): Completed; 
Date completed: 3/25/05; 
Ledger status (open or closed): None[A]; 
Ledger balance (amount owed to U.S.): 0. 

BLM state office and exchange name: Montana: Pumpkin Creek; 
Nonfederal acres acquired or planned for acquisition: 12,229; 
Value of nonfederal acres acquired or planned for acquisition: 
$2,568,122; 
Federal acres conveyed or planned for conveyance: 14,326; 
Value of federal acres conveyed or planned for conveyance: $2,589,700; 
Status (completed, pending, or terminated): Pending; 
Date completed: [Empty]; 
Ledger status (open or closed): Open; 
Ledger balance (amount owed to U.S.): $21,578. 

BLM state office and exchange name: Nevada: Indian Creek; 
Nonfederal acres acquired or planned for acquisition: 35,914; 
Value of nonfederal acres acquired or planned for acquisition: 
$2,872,156; 
Federal acres conveyed or planned for conveyance: 22,681; 
Value of federal acres conveyed or planned for conveyance: $3,288,142; 
Status (completed, pending, or terminated): Completed; 
Date completed: 1/05/05; 
Ledger status (open or closed): Closed; 
Ledger balance (amount owed to U.S.): 0. 

BLM state office and exchange name: New Mexico: Santo Domingo II; 
Nonfederal acres acquired or planned for acquisition: 2,264; 
Value of nonfederal acres acquired or planned for acquisition: 
$5,293,000; 
Federal acres conveyed or planned for conveyance: 7,148; 
Value of federal acres conveyed or planned for conveyance: $5,744,000; 
Status (completed, pending, or terminated): Completed; 
Date completed: 1/11/08; 
Ledger status (open or closed): Open[B]; 
Ledger balance (amount owed to U.S.): $450,988. 

BLM state office and exchange name: New Mexico: Acoma/State Mineral; 
Nonfederal acres acquired or planned for acquisition: 12,836; 
Value of nonfederal acres acquired or planned for acquisition: 
$256,717; 
Federal acres conveyed or planned for conveyance: 9,155; 
Value of federal acres conveyed or planned for conveyance: $183,097; 
Status (completed, pending, or terminated): Completed; 
Date completed: 6/26/06; Ledger status (open or closed): [B]; 
Ledger balance (amount owed to U.S.): [Empty]. 

BLM state office and exchange name: Oregon/Washington: Columbia Basin 
Shrubb Steppe; 
Nonfederal acres acquired or planned for acquisition: 45,053; 
Value of nonfederal acres acquired or planned for acquisition: 
$5,732,150; 
Federal acres conveyed or planned for conveyance: 4,805; 
Value of federal acres conveyed or planned for conveyance: $6,030,940; 
Status (completed, pending, or terminated): Completed; 
Date completed: 10/08; 
Ledger status (open or closed): Closed; 
Ledger balance (amount owed to U.S.): 0. 

BLM state office and exchange name: Oregon/Washington: Central 
Washington Assembled Land Exchange II; 
Nonfederal acres acquired or planned for acquisition: 11,433; 
Value of nonfederal acres acquired or planned for acquisition: 
$1,958,200; 
Federal acres conveyed or planned for conveyance: 4,599; 
Value of federal acres conveyed or planned for conveyance: $2,582,400; 
Status (completed, pending, or terminated): Completed; 
Date completed: 10/08; 
Ledger status (open or closed): Closed; 
Ledger balance (amount owed to U.S.): 0. 

BLM state office and exchange name: Total; 
Nonfederal acres acquired or planned for acquisition: 273,005; 
Value of nonfederal acres acquired or planned for acquisition: 
$37,383,261; 
Federal acres conveyed or planned for conveyance: 67,283; 
Value of federal acres conveyed or planned for conveyance: $41,283,475; 
Ledger balance (amount owed to U.S.): $2,627,241. 

Source: GAO analysis of information reported by BLM state offices. 

[A] The BLM Idaho State Office told us that they did not prepare a 
ledger for the final phase of the Birch Creek exchange. In commenting 
on a draft of this report, Interior stated that there was a ledger for 
the prior phases of the exchange. 

[B] The New Mexico land exchanges are both reflected in one ledger for 
the state. 

[End of table] 

Over the period we reviewed, BLM's multiphase exchanges accounted for 
63 percent, or 273,005 acres, of the total 432,210 acres BLM acquired 
or planned to acquire. BLM's largest multiphase exchange--the State of 
California exchange--although still pending, consists of 123,423 
nonfederal acres valued at $12.2 million and 2,290 federal acres valued 
at $14.3 million. 

Five of the 10 BLM state office officials surveyed used ledgers during 
the period of our review. According to these officials, there are a 
number of advantages and disadvantages to using ledgers to track land 
value imbalances. In terms of advantages, among the five respondents 
who provided comments, one BLM state official said a ledger allows a 
balance to be carried over for up to three years from the date of the 
first transaction closing before the values must be equalized with a 
cash equalization payment. Another noted that it is critical to use a 
ledger when the state is the nonfederal party because states may be 
constitutionally prohibited from providing cash to equalize the values 
of the lands exchanged. A third BLM state office official remarked that 
ledgers are invaluable because they enable the agency to move forward 
with NEPA compliance, hazardous materials assessments, surveys and 
other work needed to exchange some of the parcels, rather than waiting 
for this work to be completed on all parcels. In terms of disadvantages 
to using ledgers, three BLM state officials provided comments. For 
example, one official stated that multiphase exchanges are complex and 
convoluted and imply that BLM may not have fully planned the exchange 
transaction. Regarding the future use of ledgers, the responses were 
evenly split, with five saying that they would definitely or probably 
use ledgers in future exchanges and five saying they would not. 

Although the agency policy allows for multiphase exchanges using 
ledgers, BLM headquarters and state office officials told us that this 
practice is discouraged, except for exchanges with a state as a 
nonfederal party, because of past problems with these exchanges and 
their length and complexity. Multiphase exchanges with states continue 
because states have significant amounts of land and can act as long- 
term exchange partners. 

As previously stated, the Forest Service does conduct multiphase 
exchanges, but only when each phase can be completed with the federal 
and nonfederal values in balance. Furthermore, the Forest Service 
regulations do not allow for the use of ledgers. The headquarters 
program lead said that, even if allowed, the agency would not want to 
use ledgers because of the risk that the exchange would not be 
completed, and the Forest Service would be owed funds for lands already 
conveyed. 

Processing the 20 Legislated Land Exchanges Sometimes Differed from 
Processing Discretionary Land Exchanges: 

From October 1, 2004, through June 30, 2008, BLM and the Forest Service 
reported processing 20 land exchanges that were specifically legislated 
by Congress. Of these, BLM processed 5 and the Forest Service processed 
11. The agencies processed the remaining 4 exchanges jointly because 
the legislation involved lands under each agency's jurisdiction. BLM 
and the Forest Service have or are expected to acquire 276,000 acres of 
nonfederal land and to convey 76,000 acres of federal land through 
these exchanges. 

According to our analysis, 17 of the 20 legislated exchanges we 
reviewed were not processed in the same way as BLM's and the Forest 
Service's discretionary exchanges. Table 5 identifies select provisions 
contained in specific exchange laws that differed from the 
discretionary exchanges processed from October 1, 2004, through June 
30, 2008. As shown in table 5, the most frequent differences between 
processing legislated and discretionary exchanges were (1) identifying 
specific lands to be exchanged, (2) requiring the agencies to conduct 
exchanges if requested by the nonfederal party, and (3) establishing 
time frames for the completion of the exchanges. 

Table 5: Twenty Legislated Land Exchanges Processed from October 1, 
2004, through June 30, 2008, and Selected Provisions That Differed from 
the Discretionary Exchange Process, if Any: 

Agency, state, and exchange: BLM: California: State of California; 
Requires agency to initiate exchange upon nonfederal party request: 
[Check]; 
Identifies specific lands to be exchanged: [Empty]; 
Establishes time frame for exchange completion: [Empty]; 
Assigns certain costs to be borne by either the agency or nonfederal 
party: [Empty]; 
Places conditions on the federal land once conveyed: [Empty]; 
Alters appraisal requirements: [Check]. 

Agency, state, and exchange: BLM: California: Palo Verde; 
Requires agency to initiate exchange upon nonfederal party request: 
[Empty]; 
Identifies specific lands to be exchanged: [Empty]; 
Establishes time frame for exchange completion: [Empty]; 
Assigns certain costs to be borne by either the agency or nonfederal 
party: [Empty]; 
Places conditions on the federal land once conveyed: [Empty]; 
Alters appraisal requirements: [Empty]. 

Agency, state, and exchange: BLM: Colorado: Great Sand Dunes National 
Park/Baca National Wildlife Refuge; 
Requires agency to initiate exchange upon nonfederal party request: 
[Empty]; 
Identifies specific lands to be exchanged: [Empty]; 
Establishes time frame for exchange completion: [Empty]; 
Assigns certain costs to be borne by either the agency or nonfederal 
party: [Empty]; 
Places conditions on the federal land once conveyed: [Empty]; 
Alters appraisal requirements: [Empty]. 

Agency, state, and exchange: BLM: New Mexico: Santo Domingo II; 
Requires agency to initiate exchange upon nonfederal party request: 
[Empty]; 
Identifies specific lands to be exchanged: [Check][A]; 
Establishes time frame for exchange completion: [Check][B]; 
Assigns certain costs to be borne by either the agency or nonfederal 
party: [Empty]; 
Places conditions on the federal land once conveyed: [Empty]; 
Alters appraisal requirements: [Empty]. 

Agency, state, and exchange: BLM: New Mexico: Acoma/State Mineral; 
Requires agency to initiate exchange upon nonfederal party request: 
[Empty]; 
Identifies specific lands to be exchanged: [Empty]; 
Establishes time frame for exchange completion: [Check]; 
Assigns certain costs to be borne by either the agency or nonfederal 
party: [Check]; 
Places conditions on the federal land once conveyed: [Empty]; 
Alters appraisal requirements: [Empty]. 

Agency, state, and exchange: Forest Service: Arizona: Montezuma Castle; 
Requires agency to initiate exchange upon nonfederal party request: 
[Check]; 
Identifies specific lands to be exchanged: [Check]; 
Establishes time frame for exchange completion: [Check]; 
Assigns certain costs to be borne by either the agency or nonfederal 
party: [Check]; 
Places conditions on the federal land once conveyed: [Empty]; 
Alters appraisal requirements: [Empty]. 

Agency, state, and exchange: Forest Service: Arizona: Northern Arizona; 
Requires agency to initiate exchange upon nonfederal party request: 
[Check]; 
Identifies specific lands to be exchanged: [Check]; 
Establishes time frame for exchange completion: [Check]; 
Assigns certain costs to be borne by either the agency or nonfederal 
party: [Check]; 
Places conditions on the federal land once conveyed: [Check]; 
Alters appraisal requirements: [Check]X. 

Agency, state, and exchange: Forest Service: California: Greg D. 
Biagi[C]; 
Requires agency to initiate exchange upon nonfederal party request: 
[Check]; 
Identifies specific lands to be exchanged: [Check]; 
Establishes time frame for exchange completion: [Check][D]; 
Assigns certain costs to be borne by either the agency or nonfederal 
party: [Check]; 
Places conditions on the federal land once conveyed: [Empty]; 
Alters appraisal requirements: [Empty]. 

Agency, state, and exchange: Forest Service: California: Lost Valley; 
Requires agency to initiate exchange upon nonfederal party request: 
[Check]; 
Identifies specific lands to be exchanged: [Check]; 
Establishes time frame for exchange completion: [Empty]; 
Assigns certain costs to be borne by either the agency or nonfederal 
party: [Empty]; 
Places conditions on the federal land once conveyed: [Empty]; 
Alters appraisal requirements: [Empty]. 

Agency, state, and exchange: Forest Service: California: Mill Creek[E]; 
Requires agency to initiate exchange upon nonfederal party request: 
[Empty]; 
Identifies specific lands to be exchanged: [Check]; 
Establishes time frame for exchange completion: [Check]; 
Assigns certain costs to be borne by either the agency or nonfederal 
party: [Empty]; 
Places conditions on the federal land once conveyed: [Empty]; 
Alters appraisal requirements: [Empty]. 

Agency, state, and exchange: Forest Service: California: Sierra 
National Forest; 
Requires agency to initiate exchange upon nonfederal party request: 
[Check]; 
Identifies specific lands to be exchanged: [Check]; 
Establishes time frame for exchange completion: [Check][F]; 
Assigns certain costs to be borne by either the agency or nonfederal 
party: [Check]; 
Places conditions on the federal land once conveyed: [Check]; 
Alters appraisal requirements: [Check]. 

Agency, state, and exchange: Colorado: Campbell/Miles; 
Requires agency to initiate exchange upon nonfederal party request: 
[Check]; 
Identifies specific lands to be exchanged: [Check]; 
Establishes time frame for exchange completion: [Empty]; 
Assigns certain costs to be borne by either the agency or nonfederal 
party: [Empty]; 
Places conditions on the federal land once conveyed: [Empty]; 
Alters appraisal requirements: [Check]. 

Agency, state, and exchange: Idaho: Yale Creek; 
Requires agency to initiate exchange upon nonfederal party request: 
[Empty]; 
Identifies specific lands to be exchanged: [Check]; 
Establishes time frame for exchange completion: [Empty]; 
Assigns certain costs to be borne by either the agency or nonfederal 
party: [Empty]; 
Places conditions on the federal land once conveyed: [Empty]; 
Alters appraisal requirements: [Empty]. 

Agency, state, and exchange: Montana: Lost Creek[G]; 
Requires agency to initiate exchange upon nonfederal party request: 
[Check]; 
Identifies specific lands to be exchanged: [Check]; 
Establishes time frame for exchange completion: [Check][H]; 
Assigns certain costs to be borne by either the agency or nonfederal 
party: [Empty]; 
Places conditions on the federal land once conveyed: [Empty]; 
Alters appraisal requirements: [Check]. 

Agency, state, and exchange: New Mexico: Pine Springs; 
Requires agency to initiate exchange upon nonfederal party request: 
[Check]; 
Identifies specific lands to be exchanged: [Check]; 
Establishes time frame for exchange completion: [Empty]; 
Assigns certain costs to be borne by either the agency or nonfederal 
party: [Check]; 
Places conditions on the federal land once conveyed: [Empty]; 
Alters appraisal requirements: [Empty]. 

Agency, state, and exchange: Utah: OSPG (Timpanagos); 
Requires agency to initiate exchange upon nonfederal party request: 
[Empty]; 
Identifies specific lands to be exchanged: [Check]; 
Establishes time frame for exchange completion: [Empty]; 
Assigns certain costs to be borne by either the agency or nonfederal 
party: [Empty]; 
Places conditions on the federal land once conveyed: [Empty]; 
Alters appraisal requirements: [Check]. 

Agency, state, and exchange: BLM and Forest Service: California: Agua 
Caliente Band of Cahuilla Indians (Santa Rosa and San Jacinto Mountains 
National Monument); 
Requires agency to initiate exchange upon nonfederal party request: 
[Empty]; 
Identifies specific lands to be exchanged: [Empty]; 
Establishes time frame for exchange completion: [Empty]; 
Assigns certain costs to be borne by either the agency or nonfederal 
party: [Empty]; 
Places conditions on the federal land once conveyed: [Empty]; 
Alters appraisal requirements: [Empty]. 

Agency, state, and exchange: Colorado: Pitkin County; 
Requires agency to initiate exchange upon nonfederal party request: 
[Check]; 
Identifies specific lands to be exchanged: [Check]; 
Establishes time frame for exchange completion: [Check]; 
Assigns certain costs to be borne by either the agency or nonfederal 
party: [Empty]; 
Places conditions on the federal land once conveyed: [Check]; 
Alters appraisal requirements: [Empty]. 

Agency, state, and exchange: Idaho: Boise Foothills; 
Requires agency to initiate exchange upon nonfederal party request: 
[Check]; 
Identifies specific lands to be exchanged: [Check]; 
Establishes time frame for exchange completion: [Check]; 
Assigns certain costs to be borne by either the agency or nonfederal 
party: [Check]; 
Places conditions on the federal land once conveyed: [Check]; 
Alters appraisal requirements: [Check]. 

Agency, state, and exchange: Total; 
Requires agency to initiate exchange upon nonfederal party request: 11; 
Identifies specific lands to be exchanged: 14; 
Establishes time frame for exchange completion: 10; 
Assigns certain costs to be borne by either the agency or nonfederal 
party: 7; 
Places conditions on the federal land once conveyed: 4; 
Alters appraisal requirements: 7. 

Source: GAO analysis of legislation identified by the agencies. 

[A] The law specified the nonfederal lands to be acquired but not the 
federal lands to be conveyed. 

[B] The law required the exchange to be completed not later than 
November 1, 2002. 

[C] The law requires the Forest Service to convey federal lands to a 
private party and to receive the appraised fair market value of the 
land from the private party. 

[D] The law established a deadline for the conveyance of federal land 
to occur. 

[E] The law requires the Forest Service to convey federal lands to a 
private party and to receive the appraised fair market value of the 
land from the private party. The legal authority for this transaction 
expired on December 8, 2006. 

[F] The authority for this exchange terminated on December 7, 2007. 

[G] In addition to conveying federal land, the Forest Service must 
grant the nonfederal landowner the right to harvest timber on certain 
land in national forests. 

[H] The law established deadlines for Forest Service to complete 
certain phases of the land exchange process. 

[End of table] 

In addition, we found the following provisions of legislated exchanges 
that differed from the discretionary exchanges processed from October 
1, 2004, through June 30, 2008. 

* The Lost Creek and the Campbell/Miles exchange legislation declared 
the values of the federal and nonfederal lands and interests in land to 
be equal, and the Sierra National Forest exchange legislation 
established the land values, so the regular process of conducting an 
appraisal to determine land values was not required. 

* The OSPG Timpanogos exchange legislation allowed the cash 
equalization payment to exceed FLPMA's cap of 25 percent of the total 
value of the federal land conveyed. 

In some cases, the agencies' interpretation of the enacted legislation 
led it to implement the exchange differently from the typical process. 
BLM and Forest Service survey respondents identified one and five 
exchanges, respectively, in which the agency did not conduct NEPA 
analyses because of their interpretation of the enacted legislation. 
The following illustrates why the agencies either did not conduct NEPA 
analyses or did so to a more limited extent: 

* BLM's Boise Foothills/Northern Idaho exchange. The Solicitor's Office 
determined that BLM did not need to conduct NEPA analyses for this 
exchange because the statutory language requiring the exchange removed 
any discretion by the Secretary of the Interior to approve or 
disapprove the exchange or impose additional terms and conditions. 
Under these circumstances, courts have found no purpose in conducting 
the NEPA analyses. Furthermore, the Solicitor's Office found that "the 
strict and short time frame provided by Congress to complete the 
exchange (180 days) precludes the Secretary from complying with NEPA." 

* Forest Service's Montezuma Castle exchange in Arizona. According to a 
Forest Service official, the agency interpreted the enacted legislation 
as requiring it to conduct limited environmental analyses, rather than 
full NEPA analyses. The official said this ensured that the exchange 
could be completed by the statutory deadline. 

Agencies' Actions to Resolve Previously Identified Key Problems Have 
Been Somewhat Effective, but Issues Remain: 

In the past, we, the Inspectors General for Interior and USDA, the 
agencies themselves, and other organizations have identified problems 
that spanned many aspects of the BLM and Forest Service land exchange 
programs, from ensuring that the public interest was well served to 
providing appropriate guidance and training. The agencies have taken 
actions to address most of these problems. However, we found that the 
effectiveness of these actions has been mixed. Table 6 summarizes 
previously identified key problems, organizations identifying these 
problems, and agency actions taken to address them. Appendix II lists 
the organizations' reports that detail these problems. 

Table 6: Previously Identified Key Problems and Agency Actions: 

Previously identified key problem: Some exchanges did not meet 
regulatory requirements (e.g., ensuring the public interest was well 
served); 
Entity identifying the problem: GAO; Interior Office of Inspector 
General; USDA Office of Inspector General; 
Agency action: In 1998, BLM and the Forest Service instituted 
headquarters reviews of exchanges at two critical stages. 

Previously identified key problem: BLM inappropriately used escrow 
accounts to hold and earn interest on funds that resulted from value 
imbalances in multiphased exchanges; 
Entity identifying the problem: GAO; 
Agency action: In 2000, BLM issued guidance to discontinue the use of 
escrow accounts for the purpose of holding and earning interest on 
funds. 

Previously identified key problem: Third-party facilitators did not 
fully disclose their relationships with landowners; 
Entity identifying the problem: USDA Office of Inspector General; BLM 
Workgroup; Forest Service Regional Review; 
Agency action: In 2005 and 2006, BLM and the Forest Service issued 
guidance requiring full disclosure of the third-party relationships. 

Previously identified key problem: BLM did not have a national, 
comprehensive policy or statement of management direction that 
addresses land transactions, including land exchanges; 
Entity identifying the problem: BLM Workgroup; 
Agency action: BLM drafted but did not complete a national land tenure 
strategy.[A] 

Previously identified key problem: Agencies did not know the cost of 
individual exchanges; 
Entity identifying the problem: GAO; 
Agency action: No action taken because BLM did not agree and the Forest 
Service did not express a position on our recommendation to track such 
costs. 

Previously identified key problem: Agencies did not have adequate 
exchange guidance and training; 
Entity identifying the problem: BLM Workgroup; USDA Office of Inspector 
General; 
Agency action: In 2004 and 2005, BLM and the Forest Service revised 
exchange handbooks and updated exchange-related training. 

Previously identified key problem: Agencies' appraisers lacked 
independence and BLM appraisals were not timely; 
Entity identifying the problem: The Appraisal Foundation[B]; GAO; 
Agency action: In 2003, Interior moved the appraisal function from its 
agencies to a new department-level appraisal unit, the Appraisal 
Services Directorate; In 2000, the Forest Service restructured its 
appraisal function. 

Sources: GAO analysis of reports issued by GAO, the Appraisal 
Foundation, USDA's and Interior's Offices of Inspector General, 2003 
BLM Exchange and Appraisal Workgroup, Forest Service Headquarters 
Reviews of Regional Exchange Programs, a regional review of an 
exchange, and BLM and Forest Service information on actions taken. 

[A] Land tenure refers to changes in the status of public land 
ownership through transactions such as land exchanges, purchases, 
sales, and donations. 

[B] The Appraisal Foundation, a nonprofit educational organization 
dedicated to the advancement of professional valuation, was established 
in 1987 and authorized by Congress as the source of appraisal standards 
and appraiser qualifications. 

[End of table] 

Agencies' Reviews Help Ensure That Exchanges Meet Requirements and 
Agency Guidance, but They Lack Documentation and Forest Service 
Oversight Is Inconsistent: 

As table 6 notes, BLM and the Forest Service instituted reviews to 
ensure that exchanges meet requirements and agency guidance. The review 
process appears to have addressed some of the past concerns by 
correcting problems early in the process and filtering out undesirable 
proposals. However, we found that the reviews were not always well 
documented, and therefore, it is difficult to determine if all problems 
were identified and resolved. Furthermore, the Forest Service 
headquarters has not sufficiently overseen the regional reviews of land 
exchanges. 

Agencies Initiated Headquarters Reviews to Better Ensure Compliance: 

In the past, we, the Inspectors General for Interior and USDA, and 
others have identified a number of instances in which the agencies did 
not ensure that land exchanges were in the public interest. For 
example, in 2000, we reported that in BLM's Cache Creek Management Area 
exchange, BLM California officials did not specifically describe the 
parcels of land that would be exchanged and did not specifically state 
the benefits of acquiring the nonfederal parcels.[Footnote 24] We also 
noted that the Ninth Circuit Court of Appeals found that, in processing 
the Huckleberry Forest exchange in Washington state, the Forest Service 
did not adequately prepare its environmental analysis.[Footnote 25] 

To ensure that exchanges were meeting requirements and agency guidance, 
both agencies established headquarters exchange review teams in 1998 
and required the teams to review most exchanges at two critical stages 
during the exchange process--the feasibility and the decision stages. 
[Footnote 26] At these two stages, agency field staff had to submit 
detailed documentation supporting the exchange, such as a feasibility 
analysis and draft decision. At first, the headquarters review teams 
only reviewed exchanges that were controversial or valued at over 
$500,000. Review thresholds changed over time. 

Under current BLM policy, the headquarters review team and Interior's 
Solicitor review all exchanges.[Footnote 27] The BLM Deputy Director 
reviews and renders a decision on every exchange. However, according to 
the BLM headquarters review lead, the agency is considering delegating 
the review responsibility to select BLM state offices.[Footnote 28] 
Although no details had been worked out as of January 2009, the BLM 
lead said that headquarters might delegate review responsibilities to 
states based on the value of the exchange and other factors, such as 
the level of staff expertise in the state. 

While BLM still maintains a headquarters review function, the Forest 
Service began delegating this function to some of its regional offices 
before March 2006, when the agency issued a new policy.[Footnote 29] 
According to this policy, after 9 years of headquarters review, it was 
now appropriate to shift the primary exchange oversight role from 
headquarters to the regions. The policy further stated that the 
headquarters review of individual exchanges would be replaced by a 
headquarters inspection of regional exchange programs at least once 
every 3 years;[Footnote 30] a review schedule proposed three reviews 
per year from 2007 through 2009. Although the policy stated that the 
regional offices would oversee the exchanges, it did not establish any 
specific guidance for regional reviews. 

Reviews Have Addressed Some Past Concerns but Were Not Always Well 
Documented: 

As table 7 shows, 8 of the 10 BLM and 7 of the 9 Forest Service 
officials we surveyed responded that the headquarters reviews have at 
least somewhat improved the quality of exchanges their offices 
processed. 

Table 7: Survey Responses on the Extent to Which Headquarters Reviews 
Improved the Quality of Land Exchanges: 

BLM: 
Very greatly: 1; 
Greatly: 3; 
Moderately: 3; 
Somewhat: 1; 
Did not improve: 1; 
Don't know: 1; 
Total: 10. 

Forest Service: 
Very greatly: 0; 
Greatly: 2; 
Moderately: 1; 
Somewhat: 4; 
Did not improve: 1; 
Don't know: 1; 
Total: 9. 

Total: 
Very greatly: 1; 
Greatly: 5; 
Moderately: 4; 
Somewhat: 5; 
Did not improve: 2; 
Don't know: 2; 
Total: 19. 

Source: GAO analysis of survey results. 

Note: BLM responses were for exchanges processed for the period from 
2000 through 2008. Forest Service responses were for exchanges 
processed for the period from October 1, 2004, through March 17, 2006, 
when Forest Service delegated the reviews to the regions. 

[End of table] 

In addition to improving quality, survey respondents most often cited 
that the headquarters review process ensured that exchanges (1) 
complied with statutory and regulatory requirements and policy, (2) 
were processed properly, and (3) met all documentation policies. For 
example, one Forest Service respondent commented that the Forest 
Service headquarters review had "significantly enhanced" oversight of 
the exchange program and that this enhanced oversight, combined with 
other efforts, had "generally resulted in better decision making and 
improved case processing." A BLM respondent remarked that BLM 
headquarters' "oversight and exceptional guidance has resulted in a 
better process and improved trust from the public." In addition, 7 of 
the 10 BLM survey respondents found that the Solicitor review at least 
somewhat improved the quality of exchanges they had processed, and 2 of 
these said there was great improvement. 

Other officials from both agencies also told us that headquarters 
review processes improved the quality of the exchanges. A BLM 
California official said, "The mere existence of the [headquarters] 
review has improved the quality of land exchange packages." 
Additionally, a Forest Service regional official said that the reviews 
are often helpful in identifying technical issues, such as incorrect 
title details, and in ensuring that exchanges comply with policies that 
change over time. 

Our analysis of feasibility and decision reviews for the 19 BLM and 12 
Forest Service exchanges in our nongeneralizable sample of 31 exchanges 
processed from October 1, 2004, through June 30, 2008, showed that 
headquarters review teams did report problems with one or more of the 
applicable statutory and regulatory requirements and policies.[Footnote 
31] Furthermore, the number of exchanges with problems documented was 
significantly lower for decision reviews than for feasibility reviews, 
suggesting that earlier problems were resolved. Table 8 summarizes the 
number of exchanges with documented problems. 

Table 8: Number of Exchanges with Problems Documented by Agency Review 
Teams at the Feasibility and Decision Stages in GAO's Sample of 31 Land 
Exchanges: 

Number of exchanges with a documented problem: 

Statutory and regulatory requirements or agency policy: Land 
description; 
Feasibility review: BLM: 0; 
Feasibility review: Forest Service: 8; 
Decision review: BLM: 0; 
Decision review: Forest Service: 2. 

Statutory and regulatory requirements or agency policy: Conformance 
with land use plans; 
Feasibility review: BLM: 3; 
Feasibility review: Forest Service: 4; 
Decision review: BLM: 0; 
Decision review: Forest Service: 0. 

Statutory and regulatory requirements or agency policy: Public interest 
determination; 
Feasibility review: BLM: 3; 
Feasibility review: Forest Service: 7; 
Decision review: BLM: 0; 
Decision review: Forest Service: 3. 

Statutory and regulatory requirements or agency policy: Dollar values 
of the lands to be exchanged, including whether the values are within 
25 percent of each other; 
Feasibility review: BLM: 4; 
Feasibility review: Forest Service: 7; 
Decision review: BLM: 2; 
Decision review: Forest Service: 4. 

Statutory and regulatory requirements or agency policy: Title for the 
properties involved; 
Feasibility review: BLM: 1; 
Feasibility review: Forest Service: 3; 
Decision review: BLM: 0;
Decision review: Forest Service: 2. 

Statutory and regulatory requirements or agency policy: NEPA issues; 
Feasibility review: BLM: [A]; 
Feasibility review: Forest Service: [A]; 
Decision review: BLM: 0; 
Decision review: Forest Service: 2. 

Statutory and regulatory requirements or agency policy: Other; 
Feasibility review: BLM: 6; 
Feasibility review: Forest Service: 8; 
Decision review: BLM: 0; 
Decision review: Forest Service: 4. 

Statutory and regulatory requirements or agency policy: Total; 
Feasibility review: BLM: 17; 
Feasibility review: Forest Service: 37; 
Decision review: BLM: 2; 
Decision review: Forest Service: 17. 

Source: GAO analysis of BLM and Forest Service exchange documentation. 

Notes: Numbers listed by statutory and regulatory requirements or 
agency policy are not mutually exclusive. For example, one exchange 
review might have identified problems with both conformance with the 
land use plan and title for the properties involved. 

[A] Compliance with NEPA does not occur until after the feasibility 
stage. 

[End of table] 

Although table 8 indicates that, in the 31 exchanges in our sample, the 
Forest Service had more documented problems in its exchange program 
than did BLM, this may not be the case because BLM officials do not 
always document the identified problems. As the BLM exchange lead 
explained, before a formal review, BLM reviewers generally identified 
and addressed problems through conversations or e-mails with the staff 
processing the exchange. Survey respondents and others we interviewed 
concurred, with 9 of the 10 BLM officials surveyed saying that BLM 
reviewers always, usually, or often provided substantive informal 
comments by telephone, e-mail, fax, or visits that were not documented 
in the formal review. Furthermore, in many cases, for the formal review 
itself, field office officials prepared the reviews, which essentially 
summarized the exchange proposal, and the review team would edit this 
summary as necessary. 

Table 9 shows the number of exchanges with problems documented in the 
Interior Solicitor's feasibility and decision reviews. In comparison to 
headquarters reviews presented in table 8, the Interior Solicitor 
documented problems it identified in more exchanges at the decision 
review stage. According to a BLM headquarters official, the reason the 
Solicitor may document more problems is because the Solicitor generally 
reviews the exchanges before the headquarters review team. 

Table 9: Number of BLM Exchanges with Problems Documented in the 
Interior Solicitor's Feasibility and Decision Reviews: 

Number of exchanges with a documented problem: 

Statutory and regulatory requirements or agency policy: Land 
description; 
Feasibility review: 0; 
Decision review: 4. 

Statutory and regulatory requirements or agency policy: Conformance 
with land use plans; 
Feasibility review: 4; 
Decision review: 0. 

Statutory and regulatory requirements or agency policy: Public interest 
determination; 
Feasibility review: 2; 
Decision review: 1. 

Statutory and regulatory requirements or agency policy: Dollar values 
of the lands to be exchanged, including whether the values are within 
25 percent of each other; 
Feasibility review: 2; 
Decision review: 5. 

Statutory and regulatory requirements or agency policy: Title for the 
properties involved; 
Feasibility review: 4; 
Decision review: 1. 

Statutory and regulatory requirements or agency policy: NEPA issues; 
Feasibility review: [A]; 
Decision review: 2. 

Statutory and regulatory requirements or agency policy: Other; 
Feasibility review: 5; 
Decision review: 4. 

Statutory and regulatory requirements or agency policy: Total; 
Feasibility review: 17; 
Decision review: 17. 

Source: GAO analysis of BLM exchange documentation. 

Notes: Numbers listed by statutory and regulatory requirements or 
agency policy are not mutually exclusive. For example, one exchange 
review might have identified a problem with conformance with the land 
use plan and title for the properties involved. 

[A] Compliance with NEPA does not occur until after the feasibility 
stage. 

[End of table] 

Through our analysis of the agencies' reviews, we found documentation 
of 37 problems. Some appeared, in our opinion, to be substantive, and 
others seemed to be more technical. Examples of the apparent 
substantive problems included the following: 

* BLM's Central Washington Assembled Land Exchange II (CWALE). 
Headquarters reviewers questioned, among other things, the use of bulk 
discount value adjustments--an appraisal practice of grouping parcels 
at a discounted value--for the federal lands but not for the nonfederal 
lands. According to the reviewers, this bulk discounting would have 
resulted in a 28 percent decrease in the overall value of the federal 
lands--a loss of $576,620 to the taxpayer. Another exchange in 
Washington state--Columbia Basin Shrubb Steppe--also proposed using 
bulk discounting. Because of the bulk discounting and other issues, the 
BLM Deputy Director suspended further action until the issues were 
resolved. The Deputy Director eventually approved these exchanges for 
processing without the use of bulk discounting, and both exchanges were 
completed in 2008. 

* Forest Service's State of Florida exchange. Headquarters reviewers 
found that the field staff had not adequately explained why this 
exchange would benefit the public. The reviewers also found that the 
proposed exchange did not discuss how the future use of the conveyed 
federal land would be compatible with the Forest Service's management 
of adjacent lands. From the documentation provided, it is unclear 
whether and how these problems were resolved. 

In contrast, examples of the apparent technical problems included the 
following: 

* Forest Service's DNRC-Lolo exchange in Montana. The Forest Service 
found a minor error in the description of one parcel. 

* Forest Service's Camp Tatiyee exchange in Arizona. The Forest Service 
found some small inconsistencies in numbers in various documents. 

* BLM's Dees exchange in Utah. BLM's reviews found two minor problems 
related to the draft ATI--lack of documentation on the potential 
compensation to the nonfederal landowner for certain functions 
performed and lack of action to ensure that a timetable and associated 
responsibilities for processing were current. 

In addition to finding that BLM documented problems less frequently 
than the Forest Service, we found that both agencies (1) could not in 
all cases provide copies of key documents, including the reviews, as 
well as the documents subject to those reviews, and (2) did not always 
document how problems were resolved. 

First, neither BLM nor the Forest Service could provide all of the 
feasibility and decision reviews associated with the 19 BLM and 12 
Forest Service exchanges we examined. As table 10 shows, key documents 
were missing at both the feasibility and decision stages. 

Table 10: Key Exchange Documents Provided by BLM and the Forest 
Service: 

Review: Feasibility review;
BLM: Provided: 14; 
BLM: Not provided: 3; 
BLM: Not applicable[A]: 2; 
Forest Service: Provided: 11; 
Forest Service: Not provided: 1; 
Forest Service: Not applicable[A]: 0. 

Review: Interior Solicitor review at feasibility; 
BLM: Provided: 9; 
BLM: Not provided: 7; 
BLM: Not applicable[A]: 3; 
Forest Service: Provided: [B]; 
Forest Service: Not provided: [B]; 
Forest Service: Not applicable[A]: [B]. 

Review: Decision review; 
BLM: Provided: 12; 
BLM: Not provided: 3; 
BLM: Not applicable[A]: 4; 
Forest Service: Provided: 7; 
Forest Service: Not provided: 0; 
Forest Service: Not applicable[A]: 5. 

Review: Interior Solicitor review at decision; 
BLM: Provided: 9; 
BLM: Not provided: 6; 
BLM: Not applicable[A]: 4; 
Forest Service: Provided: [B]; 
Forest Service: Not provided: [B]; 
Forest Service: Not applicable[A]: [B]. 

Review: Key documents subject to review: Feasibility analysis; 
BLM: Provided: 17; 
BLM: Not provided: 1; 
BLM: Not applicable[A]: 1; 
Forest Service: Provided: 11; 
Forest Service: Not provided: 1; 
Forest Service: Not applicable[A]: 0. 

Review: Key documents subject to review: ATI; 
BLM: Provided: 17; 
BLM: Not provided: 2; 
BLM: Not applicable[A]: 0; 
Forest Service: Provided: 12; 
Forest Service: Not provided: 0; 
Forest Service: Not applicable[A]: 0. 

Review: Key documents subject to review: Draft decision record; 
BLM: Provided: 12; 
BLM: Not provided: 3; 
BLM: Not applicable[A]: 4; 
Forest Service: Provided: 4; 
Forest Service: Not provided: 3; 
Forest Service: Not applicable[A]: 5. 

Review: Key documents subject to review: Final decision record; 
BLM: Provided: 11; 
BLM: Not provided: 2; 
BLM: Not applicable[A]: 6; 
Forest Service: Provided: 6; 
Forest Service: Not provided: 1; 
Forest Service: Not applicable[A]: 5. 

Source: GAO analysis of documents provided by BLM and Forest Service 
state and regional officials. 

[A] In some cases, key documents were not applicable because the stage 
of the exchange predated the policy or the exchange had not reached 
that stage in the process. 

[B] The Forest Service does not require reviews by the USDA Office of 
General Counsel at the feasibility and decision stages. However, it 
does require an Office of General Counsel review of title documentation 
on all exchanges. 

[End of table] 

Based on our review, BLM's guidance does not clearly state the 
retention policy for land exchange documents and appears to provide 
some discretion for how long such documents need to be retained. 
[Footnote 32] The four subsections pertaining to land exchanges do not 
always provide clear time frames for how long documents are to be 
retained. Furthermore, two senior lands and realty officials provided 
different interpretations of the policy. One stated that, in practice, 
completed exchange case files are retained for 3 years and then sent to 
a Federal Records Center. The second official stated retention varies 
depending on the final disposition of a proposal and he was unclear on 
certain aspects of the policy. The Forest Service guidance provides 
similar discretion for document retention. The guidance states that 
general exchange files not specific to an exchange are to be retained 
on-site for 3 years, while specific exchange files may be "destroy[ed] 
after [the] title file is created and [the] administrative or legal use 
ceases." The Forest Service's National Records Manager said that the 
retention time frame is not specific and that the Forest Service 
planned to review the policy this year and set specific retention 
periods that would be implemented in fiscal year 2010. 

Second, while we did find some instances in which the agencies 
documented the resolution of problems identified in reviews, neither 
agency documented all of the resolutions. We identified 37 apparent 
problems cited in decision reviews within our sample--2 identified by 
BLM and 35 identified by the Forest Service. Both problems cited in BLM 
decision reviews refer to the use of bulk discounting in the CWALE and 
Columbia Basin Shrubb Steppe exchanges. Although both reviews approved 
the processing of the exchanges without bulk discounting, only the 
CWALE review stated that the field office planned to implement this 
recommendation. Because it was not clearly documented, we followed up 
with field officials to confirm that bulk discounting was, in fact, not 
used. For the Forest Service, we were unable to determine the 
resolution of the four problems identified in the regional review of 
the Gray Wolf exchange decision from the final decision and other 
documents provided. In addition, we found the resolution of only a 
portion of the 16 apparent technical problems identified in the 
headquarters review of the State of Florida exchange. 

Forest Service Oversight Has Not Been Sufficient: 

After delegating review responsibilities to its regional offices in 
March 2006, the Forest Service planned to continue national-level 
oversight with reviews of regional exchange programs to be conducted 
once every 3 years. However, as of January 2009, the Forest Service 
headquarters review team had completed only three of the six reviews 
scheduled for completion by the end of 2008. According to a Forest 
Service official, the team is behind schedule because of staff 
shortages, a lack of funds, and competing priorities. 

Of our sample of 12 Forest Service exchanges, 3 exchanges were being 
processed after the Forest Service headquarters review had been 
delegated to the regions. For these exchanges, the regional review 
teams generally documented problems found. For example, the Region 3 
review of the Gray Wolf exchange in Arizona found that the public 
interest determination needed to be added to a key document. 
Furthermore, Region 5's review of the Mammoth Community Facilities 
exchange in California found that some wording on a geothermal 
reservation needed to be verified with BLM before proceeding. 

Only four of the nine regional offices--Regions 2, 3, 5, and 9--had 
formally documented their review policy and process, according to 
regional officials. However, these documents simply stated that the 
region would review exchanges at the feasibility and decision stages. 
Of greater concern, in some regions, reviewers were reviewing the 
feasibility and decision documents they also were responsible for 
preparing or assisted in preparing. This lack of independent review 
occurred about 2 years ago, according to headquarters reviews of 
Regions 1 and 2. Specifically, the reviews stated that the regions need 
to ensure that "adequate regional office oversight is conducted when 
staffs with oversight responsibilities are carrying out the subject 
work directly." The reviews further stated, "there must be a separation 
between the persons who conduct the activity from the person that 
performs oversight of the activity" and that "true oversight can not be 
self-performed." Both reviews recommended that either (1) an alternate 
headquarters or regional reviewer be identified to review any work 
conducted by regional staff that would otherwise be responsible for the 
oversight review of that work or (2) regional reviewers limit their 
mission delivery work to coaching and instructing, rather than 
conducting the activity themselves. More recently, in January 2009, a 
Region 4 official told us that regional staff are responsible for both 
preparing and reviewing all exchanges in the region. In commenting on a 
draft of this report, the Forest Service said that the region is 
organized in such a way that there is separation between those 
preparing the exchange documents and those that review them. 

Asked how the Forest Service follows up on the implementation of the 
headquarters review recommendations, the land exchange program lead 
said they have not yet done any follow-up on the prior recommendations. 
Therefore, they do not know if past headquarters review recommendations 
have been implemented. 

BLM Stated It Has Discontinued Use of Escrow Accounts in Multiphase 
Exchanges, but BLM Is Not Following Ledger Guidance, and Statutory 
Authority for Some Multiphase Exchanges Remains Unclear: 

In 2000, we reported that for multiphase land exchanges, BLM was 
inappropriately depositing funds into interest-bearing escrow accounts 
outside of the U.S. Treasury and later using those funds to acquire 
nonfederal lands.[Footnote 33] According to BLM officials, the agency 
discontinued its use of escrow accounts and issued new guidance on how 
to use land exchange ledgers to track land value imbalances in 
multiphase exchanges. While BLM officials told us that no funds 
currently were held in an escrow account outside of the U.S. Treasury, 
we found that cash from at least one multiphase exchange we reviewed 
was deposited in an escrow account and later transferred to the U.S. 
Treasury. We also found that the agency is not adhering to its own 
guidance for maintaining land exchange ledgers so that it can know how 
much is owed. As a result, BLM cannot be assured that its total balance 
of about $2.6 million due to the United States, as of June 30, 2008, is 
accurate. In addition, one BLM multiphase exchange we reviewed 
presented problems similar to those we identified in our 2000 report. 
Specifically, the statutory authority for the exchange remains 
questionable. 

BLM Stated It Has Stopped Using Escrow Accounts, and Multiphase Land 
Exchanges Have Continued: 

As we reported in 2000, in conducting multiphase exchanges, BLM was 
inappropriately selling land, depositing funds into interest-bearing 
escrow accounts outside of the U.S. Treasury, and using these funds to 
acquire nonfederal lands directly or through third parties. We further 
reported that FLPMA did not authorize BLM to retain sales proceeds for 
land acquisitions, but rather required BLM to deposit such funds into 
the Treasury and to use appropriated funds to acquire nonfederal land. 
We recommended that BLM end the use of nonfederal escrow accounts. We 
further recommended that BLM identify and immediately discontinue 
multiphase exchanges under which BLM was--either directly or through 
third-party facilitators--following the unauthorized practice of 
selling federal land, retaining the sales proceeds, and using these 
proceeds to buy nonfederal land. BLM responded that multiphase 
exchanges are necessary and permissible. BLM agreed with our 
recommendations on escrow accounts and issued guidance in 2000 to, 
among other things, discontinue their use and incorporated this 
guidance into its 2005 land exchange handbook. Select provisions of the 
revised handbook include the following: 

* A ledger is an accounting mechanism that may be used only for 
tracking the differential in dollar value of lands conveyed in a series 
of transactions. 

* The BLM state director must provide written approval of the 
establishment of a ledger and a determination on the need to secure an 
imbalance. If needed, the nonfederal party must provide a financial 
assurance to secure the imbalance.[Footnote 34] 

* The difference between the value of federal and nonfederal lands 
cannot exceed 25 percent of the federal land value conveyed up to and 
including the current transaction. 

* The cash equalization waiver provision only applies to the final 
transaction of the multiphase exchange. 

* Any funds being held by BLM as financial assurance are held in a "BLM 
suspense account" in the U.S. Treasury.[Footnote 35] 

* Ledgers must reach zero balance every 3 years. 

* Lands acquired by means other than a land exchange transaction (i.e., 
acquisition or donation) are not to be reported on the ledger. 

* The ATI for a multiphase exchange should document how the exchange 
will be processed using a ledger. 

* A standard ledger format must be used. 

The BLM handbook does not call for ledgers to be submitted to the 
headquarters review team as part of the exchange feasibility or draft 
decision package, and therefore, ledgers are not regularly reviewed 
above the state director level. 

BLM Is Not Adhering to Its Guidance on Managing Land Exchange Ledgers 
to Track Value Imbalances in Multiphase Land Exchanges: 

Our review of the seven open and closed land exchange ledgers processed 
from October 1, 2004, through June 30, 2008, found instances of 
noncompliance in several areas: (1) documenting the decision to require 
financial assurances, (2) balancing ledgers at zero every 3 years, (3) 
documenting the use of a ledger in the ATI, (4) adhering to the 
standard ledger format, and (5) using a ledger. While BLM reported nine 
multiphase exchanges in our time frame, they also noted that two of the 
exchanges were accounted for in a single ledger, and the office 
processing the ninth exchange said they did not prepare a final ledger 
for one of the closed exchanges. Together these omissions reduce the 
opportunity for management to provide appropriate oversight of each 
transaction and help ensure that exchange program objectives are 
achieved. Specifically: 

* Financial assurances. Three of the seven ledgers were still open and 
had balances due to the federal government totaling about $2.6 million, 
but did not have financial assurances to secure the balances due. Two 
of these open ledger balances were owed by state agencies (California 
and New Mexico). The 2005 handbook does allow exemptions from its 
financial assurance provisions with the written approval of the BLM 
state director. All three of these ledgers did have the written 
documentation as to why financial assurances were not needed. However, 
for one of the open ledgers with written documentation--the Pumpkin 
Creek exchange in Montana--the justification was dated about 1 year 
after the imbalance was created and after we requested the document. 
Three of these four closed ledgers did have financial assurances, but 
the BLM state directors did not document the determination on the need 
for financial assurances. One state office reported a fourth ledger as 
closed, but the officials said no final ledger document was prepared. 

* Balancing land exchange ledgers every 3 years. Six of the seven 
ledgers were over 3 years old, and state office officials reported that 
none of the six were balanced at zero at least every 3 years, as 
required. Officials offered explanations for the failure to balance the 
ledger to zero every 3 years. Specifically, one state office program 
lead said that the requirement to balance the ledger to zero is not 
realistic because there will never be a time when a ledger can balance 
with exactly equal land value. In addition, because multiphase 
exchanges tend to take longer than anticipated, another state office 
program lead said that balancing ledgers to zero has been deferred 
beyond 3 years. The seventh ledger was established in 2007 and was not 
due to balance until 2010. 

* Documenting the use of the land exchange ledger in the ATI. Of the 
multiphase exchanges we reviewed, only four had documented an agreement 
to establish a ledger in the ATI, as required. 

* Land exchange ledger format. None of the seven ledgers we reviewed 
had followed the format that BLM had prescribed in the handbook. Since 
the ledgers' formats were inconsistent and not self-explanatory, and 
the ledgers were not current, determining when balances were zero and 
when ledgers were closed was not always possible from the document 
itself. Based on our reviews of actual ledgers and prescribed format in 
the BLM handbook, key facts about the exchange--that is, whether the 
balance was at zero every 3 years or whether the ledger was closed-- 
were not readily apparent from the ledgers as prepared or as 
prescribed. We therefore had to interview state program leads to obtain 
this information. 

* Use of ledgers. Although required, one multiphase exchange in Idaho--
Birch Creek--did not have a final ledger. 

In addition to noncompliance with guidance on how to manage land 
exchange ledgers, we found the following problems with multiphase 
exchanges using ledgers: 

* Large ledger imbalance and other concerns. The ledger for the ongoing 
State of California multiphase exchange shows that the federal 
government has been owed $2.2 million since 2003. Furthermore, this 
exchange does not have a financial assurance in place to cover this 
balance owed if the state does not pay. According to BLM officials, the 
California Desert Protection Act of 1994 authorizes this 
exchange.[Footnote 36] Because of the concerns about lands to be 
exchanged under the act, the California State Lands Commission and the 
General Services Administration (GSA) entered into a memorandum of 
agreement with BLM, in lieu of an ATI. Under the memorandum and related 
agreements, if the State Land Commission did not want the surplus 
federal property, GSA was to sell surplus federal properties to third 
parties and deposit the sale proceeds in a U.S. Treasury suspense 
account. After BLM received title to the State Land Commission 
properties located within wilderness areas or national park units, as 
identified in the 1994 act, GSA was to transfer the money to the 
commission. According to BLM California State Office officials, the 
exchange has been on hold since 2003, when the BLM headquarters review 
team and Interior's Office of the Solicitor raised concerns about the 
memorandum of agreement. In commenting on a draft of this report, 
Interior said that it would be more accurate to state that the exchange 
has been delayed because BLM and the state have been unable to reach an 
agreement on value after three appraisals, the latest in 2008. None of 
the appraisals were acceptable to both parties, and the state and BLM 
have been discussing ways to resolve the appraisal issue and balance 
the ledger. In March 2009, a GSA official reported that GSA was still 
holding $7.8 million in a Treasury account for the purpose of acquiring 
land under the California Desert Protection Act. This report does not 
address questions relating to the underlying legal authority for these 
transactions. We are exploring this issue separately with Interior's 
Solicitor and GSA's Office of General Counsel. 

* Value imbalances not clearly shown. A recently closed ledger for a 
large multiphase exchange processed by the BLM Oregon State Office--the 
Central Washington Assembled Land Exchange II (CWALE), worth a total of 
$5 million in federal and nonfederal land value--could not be used to 
track the land value imbalances due to BLM because the numbers in the 
document did not clearly show value imbalances. After we made inquiries 
to the Oregon State Office program lead, we learned that there were 
errors in the original ledger's presentation. Although the program lead 
provided a revised ledger, the revision did not show a zero balance on 
its bottom line. Rather, a footnote stated that the $290,200 balance 
due to BLM had been received and deposited in the U.S Treasury. 

Statutory Authority for Some BLM Multiphase Exchanges with Ledgers 
Remains Unclear: 

One multiphase exchange we reviewed, CWALE, presented problems similar 
to those we identified with the unauthorized exchanges discussed in our 
2000 report. Specifically, BLM conveyed federal land to various private 
parties and received cash equal to the federal land's fair market value 
from those private parties. The cash was then deposited into an escrow 
account for the purpose of closing and sometimes was later transferred 
to a U.S. Treasury deposit fund account.[Footnote 37] BLM would then 
use this cash to pay landowners the fair market value of the nonfederal 
lands BLM acquired from them. These transactions appear to be similar 
to the unauthorized exchanges discussed in our 2000 report.[Footnote 
38] 

BLM officials state that the CWALE multiphase exchange was conducted 
pursuant to the applicable statutory and regulatory requirements. 
However, as we said in our 2000 report, BLM was not authorized to sell 
federal land, retain the proceeds, and subsequently use the proceeds to 
buy other lands under the umbrella of a land exchange. In 2000, shortly 
after we issued our report, Congress passed the Federal Land 
Transaction Facilitation Act (FLTFA).[Footnote 39] Under FLTFA, the 
gross proceeds from certain exchanges or sales carried out under FLPMA 
are deposited into a special account, known as the Federal Land 
Disposal Account. Funds in this account are available to BLM and other 
land management agencies without further appropriation to purchase 
privately owned land meeting certain qualifications, generally referred 
to as "inholdings." While the federal lands conveyed in CWALE meet 
FLTFA's requirements, it appears that the lands BLM acquired with the 
gross proceeds do not. Moreover, instead of depositing the gross 
proceeds into the Federal Land Disposal Account, BLM used some of the 
proceeds to acquire private lands that were not FLTFA inholdings, and 
only later deposited the remaining proceeds in the Federal Land 
Disposal Account. 

BLM officials further maintain that any money received served as either 
a cash equalization payment or a financial assurance to secure the 
ledger's imbalance. However, a cash equalization payment is intended to 
fulfill the requirement that the values of the land exchanged be equal 
after all reasonable efforts to equalize land by adding or excluding 
land from the exchange. A payment from a nonfederal party that equals 
the federal land's value appears more likely to be a purchase price 
than a cash equalization payment. With respect to the financial 
assurance characterization, the documents we obtained from BLM are not 
consistent with this characterization. BLM's Land Exchange Handbook 
specifies the approved methods for securing ledger imbalances. For cash 
or personal bonds, the handbook says that BLM should obtain a personal 
bond, cash, and book entry deposits form from the nonfederal party. BLM 
was unable to provide us any such forms for the CWALE transactions. 
Furthermore, the escrow instructions and related documents (1) refer to 
the cash BLM received as "full consideration for the purchase of 
property," (2) provide that the cash would become federal funds once 
that transaction's conveyance documents were recorded, and (3) state 
that the money would be utilized as payment for a subsequent 
transaction. 

In addition to CWALE, other multiphase exchanges we reviewed 
potentially appear to have resulted in transfers of cash that should 
have been regarded as sale or exchange proceeds or payments for land 
acquisitions. As such, each of these multiphase exchanges, including 
CWALE, may have resulted in violations of fiscal laws, including the 
Antideficiency Act and the Miscellaneous Receipts Statute, as well as 
the Department of the Treasury's policies and procedures for accounting 
and reporting of receipts and disbursements of the U.S. government. We 
are exploring these issues separately with Interior's Office of the 
Solicitor. 

The Agencies Issued Guidance on the Use of Third-Party Facilitators, 
but Need to Clarify and Consistently Apply Disclosure Policies: 

As internal agency reviews have reported, guidance on using third-party 
facilitators was inadequate and facilitators did not always disclose 
important information to the agencies during the course of an exchange. 
As a result, some exchanges failed or were not in the public interest. 
Both BLM and the Forest Service have issued new guidance that requires 
full disclosure of the relationship between the facilitator and other 
parties to an exchange. However, we found that the agencies do not 
clearly define third-party facilitators in their guidance and are not 
consistently applying disclosure policy to them. Moreover, agencies' 
policies do not require disclosures to be examined during the review 
process. 

Agencies Enhanced Guidance and Required Full Disclosure from Third- 
Party Facilitators to Correct Past Problems: 

According to reports by a BLM workgroup, the USDA Inspector General, 
and an internal Forest Service review, the agencies lacked guidance on 
dealing with third-party facilitators, and facilitators withheld 
important information on their relationships with landowners. For 
example, a 2003 BLM workgroup review highlighted the value of 
facilitators, but also acknowledged the growing public perception that 
facilitators may have an inappropriate level of influence over the 
exchange process. It recommended that BLM develop policy and guidance 
related to facilitators. In response, BLM revised its land exchange 
handbook in 2005 to expand its guidance and provide more detail on 
working with facilitators. The earlier handbook had only called for 
facilitators to disclose to the sellers their intent to transfer 
acquired lands and to disclose to BLM their purchase price of 
nonfederal lands to be included in an exchange. 

In contrast, the 2005 handbook states that third-party facilitators 
must disclose all agreements and additional fees, costs, or surcharges 
to be added to the appraised exchange property values to cover the cost 
of the facilitator's participation in the exchange and must make these 
disclosures before requesting an appraisal. In addition, the disclosure 
provision ensures that BLM has the right to inspect the facilitator's 
records for up to 7 years after an exchange is completed. BLM policy 
also includes a template for full disclosure language that must be used 
in the ATI if a facilitator is involved. 

At the Forest Service, in 1998, the USDA Inspector General reported 
that there were no guidelines for evaluating exchanges that 
facilitators had proposed. Indeed, the report found that Forest Service 
staff at the Humbolt-Toiyabe National Forest in Nevada had an 
"accommodating relationship" with one facilitator, and gave the 
facilitator's proposed exchanges a higher priority than other proposed 
exchanges. Furthermore, forest staff improperly bargained with this 
facilitator and the landowner it represented, which resulted in a loss 
of $5.9 million to the federal government. The Inspector General 
recommended that the Forest Service develop additional direction for 
dealing with facilitators and instruct all Forest Service lands staff 
on the new policies. To respond to these problems, the Forest Service 
said it planned to issue national guidance defining the roles and 
responsibilities of Forest Service staff and facilitators in 1999. In 
addition, the agency said it would provide training on the new 
policies. 

The Forest Service's problems with third-party facilitators continued, 
however, as evidenced by the agency's failed Blue Mountain exchange in 
2006. The Blue Mountain exchange, initiated in 1998, involved a trade 
of about 18,000 federal acres valued at $16 million for about 32,000 
nonfederal acres valued at $15.7 million located in northeastern 
Oregon.[Footnote 40] The nonfederal acres were owned by approximately 
40 separate landowners. Figure 3 shows the multiple parcels involved in 
this large exchange involving three national forests and spanning six 
counties. 

Figure 3: Location of Federal and Nonfederal Parcels Proposed for 
Exchange in the Terminated Blue Mountain Exchange in Northeastern 
Oregon: 

[Refer to PDF for image: map of northeastern Oregon] 

This map contains the following information: 

Blue Mountain Land Exchange Map Locator: 
* Cities; 
* Highways; 
* Parcels. 

National Forest Boundaries: 
* Malheur; 
* Umatilla; 
* Wallowa-Whitman. 

Source: GAO adaptation of map from the Final Environmental Impact 
Statement for the Blue Mountain Land Exchange-Oregon, dated September 
2006. 

[End of figure] 

This large and complex land exchange failed for several reasons, 
according to Forest Service officials and documents we reviewed. First, 
the Forest Service worked only with the third-party facilitator and did 
not communicate with the nonfederal landowners about their willingness 
to participate in the exchange. Second, the facilitator and the Forest 
Service could not agree on the appraised values. Third, in the final 
stages of the exchange, as the appraisals were about to expire, the 
facilitator proposed dropping several land parcels of high value to the 
government, opting instead to pay a higher cash equalization payment. 
The facilitator proposed this change because, as the Forest Service 
later learned, several landowners represented by the facilitator were 
no longer willing to exchange their property. The officials said that 
while the planned cash equalization payment--$3.6 million--would have 
been within the legal threshold of 25 percent of the federal land 
value, such a large payment would have gone against FLPMA's provision 
to keep such payments as low as possible. Moreover, a regional official 
said that the exchange was premised on the government receiving certain 
high-resource value lands and when some of these lands dropped out, the 
agency decided the public interest would no longer be served. 

A subsequent Forest Service internal regional review of the Blue 
Mountain exchange indicated a number of problems with the facilitator. 
Specifically, the review stated that the facilitator (1) tried to work 
on passing federal legislation without the Forest Service's knowledge, 
(2) was very secretive about its agreements with landowners, and (3) 
wanted to control the outcome of the exchange instead of working as a 
partner with the Forest Service to ensure an outcome that was in the 
public interest. In addition, the review said that the facilitator 
never provided the Forest Service with written documentation that 
landowners had granted Forest Service staff permission to enter the 
landowners' properties to conduct appraisals, surveys, and other 
studies, which made it difficult for Forest Service staff and others to 
conduct this work. While the Forest Service did not track the costs of 
processing this land exchange, it estimated that it spent $1.4 million 
from 1998 to 2006. In June 2008, Forest Service officials told us that 
they planned to salvage parts of this exchange by working directly with 
landowners and they will not involve a third-party facilitator. 

Following the failure of the Blue Mountain exchange in Oregon, in 
December 2006, the Forest Service revised its guidance to its staff. 
The revised guidance required staff to, among other things, obtain (1) 
written permission to access properties for appraisals, inspections, 
and other necessary activities; (2) written disclosure of the 
relationship between the facilitator and nonfederal landowner; and (3) 
copies of purchase options, agreements, or other financial arrangements 
affecting the value of the appraised property. This documentation must 
be obtained before processing a facilitated exchange. 

Agencies Do Not Clearly Define Third-Party Facilitators and Are Not 
Consistently Applying Disclosure Policy: 

Although both agencies require disclosure from third-party facilitators 
on, among other things, any interests the party might have in the 
exchange, agency officials told us that disclosure is applicable only 
when facilitators sign key documents, such as the ATI or the exchange 
agreement, and are included on the title of lands exchanged. The 
officials added that it is more common that facilitators do not sign 
such documents and serve more in the capacity of a "consultant" or 
"advisor." However, neither agency's handbook makes this distinction in 
applying the disclosure policy. 

Both BLM's and the Forest Service's enhanced guidelines for third-party 
facilitators appear to have had little impact on obtaining 
documentation on third parties facilitating exchanges. Indeed, although 
the BLM exchange program lead agreed that field offices must have the 
disclosure provision in the ATI, he questioned whether field staff 
processing exchanges had to actually obtain supporting documentation. 
Furthermore, because there is no clear definition of a third-party 
facilitator, and because most entities assisting landowners do not sign 
the key documents, the Forest Service exchange program lead questioned 
the impact of the Forest Service's revised 2006 disclosure policy on 
avoiding problems with facilitated land exchanges. In addition, two 
Forest Service regional officials we interviewed stated that the Forest 
Service's 2006 guidance has had no impact on their work with 
facilitators because those entities do not sign key documents. Absent 
specificity about who a facilitator is and, thus, who should be 
complying with disclosure, BLM and Forest Service staff processing 
exchanges have been determining when to apply the disclosure policy. 

One of the third-party facilitators we interviewed agreed with these 
assessments, stating that the disclosure guidelines BLM and the Forest 
Service issued have had no impact on his operations because his company 
does not sign the documents. He added that his company's relationships 
are "open and clear" and that the agencies should have no questions 
about whom they are dealing with. This facilitator worked on 17 of the 
47 facilitated exchanges pending, completed, or terminated from October 
1, 2004, through June 30, 2008. 

In the absence of disclosure, a Forest Service official said that staff 
recently experienced a problem completing the Montezuma Castle exchange 
in Arizona. Specifically, the facilitator misrepresented its ownership 
of the nonfederal land to be acquired in the exchange, stating that it 
owned all the land. However, the facilitator only held a 1-year option 
to purchase part of the nonfederal land. The option expired during the 
exchange process, requiring additional negotiations with the landowner 
to acquire that land. The exchange was eventually completed in December 
2007. 

Thirteen survey respondents had worked with a third-party facilitator 
during the period we reviewed--7 from BLM and 6 from the Forest 
Service. These respondents worked on seven facilitated exchanges that 
were subject to compliance with the disclosure guidelines.[Footnote 41] 
These respondents reported that the facilitator in four exchanges did 
not comply with the disclosure guidelines and two did comply, and in 
one case, the respondent was not sure whether the facilitator complied. 
Of the two cases where the facilitator was reported to have complied, 
BLM and Forest Service officials provided incomplete supporting 
documentation. Specifically, the BLM official provided us with an ATI 
that contained the required provisions on disclosure but no 
documentation of the disclosure, including agreements involving the 
facilitator and landowner, copies of purchase options, or other 
financial arrangements affecting the value of the appraised property. 
The Forest Service official provided us with a letter from the 
landowner to the Forest Service outlining the role of the facilitator 
in the exchange. The letter provides the name and role of the 
facilitator and states that the facilitator has no ownership rights to 
any of the nonfederal lands proposed for exchange. It further states 
that the landowner would be signing all key documentation. Again, 
however, the Forest Service official did not provide copies of any 
financial arrangements affecting the value of the appraised property. 

In addition to the agencies' inconsistent collection of required 
documentation, neither BLM nor the Forest Service guidelines call for 
land exchange review teams to obtain and examine full disclosure 
documentation. 

BLM and the Forest Service Do Not Have National Land Tenure Strategies: 

Neither BLM nor the Forest Service has a national land tenure strategy. 
According to a 2003 BLM report, BLM needs such a strategy to guide its 
land transactions, and BLM agreed to develop a strategy but has not yet 
done so. Internal Forest Service reviews have also noted that some 
Forest Service regions lack proper planning documentation. As we have 
previously reported, the most important element in results-oriented 
management is an agency's effort to define what it seeks to accomplish, 
identify the strategies it will use to achieve desired results, and 
then determine how well it succeeds in reaching results-oriented goals 
and achieving objectives.[Footnote 42] 

BLM Has Not Completed An Agreed-to National Land Tenure Strategy, but 
Three BLM State Offices Have Completed State-Level Strategies: 

According to BLM's 2003 workgroup review, BLM lacks a national, 
comprehensive policy or a statement of management direction that 
addresses land transactions, including land exchanges. Furthermore, the 
workgroup said it may be time to develop a policy to address public 
land ownership patterns because of the complex land ownership pattern 
of public lands and the potential influence of these patterns on local 
and regional land use issues. To address these problems, the workgroup 
recommended, among other things, that BLM establish a national land 
tenure strategy and direct state offices to develop state-level 
strategies based on the national strategy.[Footnote 43] 

The BLM Director agreed to implement these recommendations, but BLM has 
not yet done so. According to the BLM exchange lead, BLM staff 
developed a national land tenure strategy and submitted it for review 
and approval by BLM's executive leadership team in 2003, but no action 
has since been taken.[Footnote 44] As a result, BLM has not directed 
state offices to develop state-level strategies and has not integrated 
the national strategy into its land use planning handbook and manual. 
The BLM land exchange lead said that the strategy has not been 
completed primarily because of changes in agency priorities. 

Although BLM headquarters had not provided direction to the state-level 
offices, 4 of the 10 BLM state offices had developed, or were 
developing, state-level strategies. Three of the offices responding to 
our survey--Arizona, Montana, and New Mexico--reported that they had 
completed a strategy, and one, California, reported it was developing a 
strategy. From our reviews of these strategies and interviews with BLM 
officials from these states, we learned the following: 

* Arizona. The 2008 state office strategy's primary goal is to better 
administer public lands by acquiring lands with high-resource values 
and disposing of lands that are difficult and uneconomical to manage. 
[Footnote 45] According to the BLM Arizona exchange lead, prior to this 
strategy, BLM Arizona staff made decisions in a "haphazard" way. For 
example, in some cases, field office staff worked extensively on 
exchange proposals without early state office input, only to later have 
these proposals terminated by the state office for various reasons. 
Furthermore, this strategy establishes a consistent methodology for 
evaluating land transaction decisions, helps ensure decisions are 
properly made, and improves communication among offices. 

* Montana. According to the BLM Montana exchange lead, because the 
state office foresees considerable exchange opportunities with the 
state of Montana, the development of a state exchange strategy, which 
was completed in 2004, was "imperative." The strategy established a 
prescreening process for exchanges to ensure that BLM resources, 
including staff and funding, are allocated to exchanges with the 
greatest benefits.[Footnote 46] 

* New Mexico. The 2004 state office strategy states that because land 
management goals had been established at the field office level, some 
priority transactions from a statewide perspective were passed over. 
[Footnote 47] To address this problem, the strategy established 
statewide priorities for land transactions, among other things. It also 
created a statewide land tenure steering committee to review all land 
transactions in the state, including exchanges. The state director 
issued the committee's charter in 2005 to clarify how the committee 
will function. 

According to BLM survey respondents in the remaining six states, two 
states--Idaho and Oregon--had not started a strategy;[Footnote 48] one--
Wyoming--did not know the strategy's status; and three--Colorado, 
Nevada, and Utah--said they did not need a strategy because they rely 
on land use plans to make decisions. 

Independent of actions taken in response to the BLM workgroup, in 2003, 
a congressional committee directed the Secretaries of the Interior and 
Agriculture to develop jointly a long-term national plan outlining the 
acreage goals and conservation objectives for federal land 
acquisition.[Footnote 49] In response, the agencies, including BLM and 
the Forest Service, issued a National Land Acquisition Plan in February 
2005.[Footnote 50] While this plan does provide information on the 
various agencies' goals, objectives, and land acquisition strategies, 
among other things, it does not appear to offer a specific strategy on 
making exchange and other land transaction decisions on a national 
basis. In fact, the report states that BLM's national land tenure 
strategy, which is under development, will focus on a better balance 
between land exchanges and disposal actions, acknowledging that such a 
plan will offer more detailed planning with regard to exchanges. 

Forest Service Does Not Have a National Land Tenure Strategy: 

Like BLM, the Forest Service does not have a national land tenure 
strategy. According to the Forest Service exchange lead, the agency 
relies on its agencywide strategic plan and policies to guide land 
exchange decisions. The Forest Service's policy manual does recognize 
the importance of planning for land transactions by requiring the 
regions and forests to prepare documents that can adequately guide the 
long-range (5 to 10 year) landownership adjustment program. These 
planning documents, which supplement required forest plans, include, 
among other things, more detailed guidance for making land exchange 
decisions and are required if a region delegates certain 
responsibilities to forest staff, such as signing off on key exchange 
documents. 

Although these plans are required, only one of the nine regions 
reported having a regional-level plan, and the official from that 
region reported that the plan, completed in 2005, needs to be revised. 
Furthermore, according to Forest Service headquarters reviews of land 
transaction programs in Regions 1, 2, and 8 in 2007, these regions were 
delegating responsibilities to national forests that did not have these 
plans.[Footnote 51] The reviews therefore recommended that the regional 
directors of lands ensure that all national forests receiving delegated 
authority either have adequate forest-level land transaction plans or 
are using regional-level plans. As noted earlier, the land exchange 
program lead said headquarters has not done any follow-up on the prior 
headquarters review team recommendations. Therefore, they do not know 
if the recommendations on planning have been implemented. 

Agencies Do Not Track the Costs of Processing Individual Exchanges: 

BLM and the Forest Service did not implement our 1987 recommendation to 
account for all costs associated with individual land exchanges. 
[Footnote 52] Nevertheless, BLM's guidance on land exchanges recognizes 
the importance of monitoring and tracking costs to make informed 
resource management decisions. The Forest Service's guidance does not 
address this issue. In our current review, we found that the agencies 
typically do not track the largest cost associated with individual land 
exchanges--personnel costs--although they do track certain other costs. 
Without complete knowledge of the cost of each land exchange, BLM and 
the Forest Service cannot weigh the costs of processing land exchanges, 
compare the benefits of land exchanges with other priorities, or 
provide complete and accurate information to assist congressional 
oversight and inform the public. 

BLM and the Forest Service Did Not Implement GAO's Recommendation to 
Track Costs: 

In 1987, we reported that neither BLM nor the Forest Service had 
reliable and consistent information on the cost of individual land 
exchanges and recommended that the agencies institute a system to 
account for all costs associated with land exchanges. However, BLM 
disagreed because of concerns about the need for, and the additional 
cost of, collecting this information.[Footnote 53] The Forest Service 
did not express a position on the recommendation, but stated that it 
had the necessary guidance for recording exchange costs. 

Agencies Do Not Have Cost Information to Help Manage Land Exchanges: 

The Chief Financial Officers' Act of 1990 states, among other things, 
that an agency's chief financial officer should develop and maintain an 
integrated accounting and financial management system that provides for 
the development and reporting of cost information and systematic 
performance measurement. The Statement of Federal Financial Accounting 
Standards No. 4: Managerial Cost Accounting Concepts and Standards for 
the Federal Government (SSFAS), effective in fiscal year 1998, 
establishes the fundamental elements for managerial cost accounting in 
government agencies.[Footnote 54] Among other things, agencies are to 
gather and report the cost of agency activities. This information can 
be used by federal executives for budgeting and cost control; 
performance measurement; reimbursement determinations; the setting of 
fees and prices; program evaluations; and decisions that involve 
economic choices, such as monitoring and comparing the costs of 
individual land exchanges. Congress can also use cost information to 
determine how to fund programs and monitor agency performance, as well 
as to analyze the merits of proposals advocated by different parties. 
The public, in turn, can benefit from greater transparency about 
program performance. 

As we have reported, BLM has made more progress than the Forest Service 
in implementing managerial cost accounting,[Footnote 55] but neither 
agency currently tracks the cost of individual exchanges to provide 
useful management information. BLM does have program elements, or 
codes, that BLM staff charge when working on land exchange activities: 
one for all activities associated with land disposals and one for all 
activities associated with acquisitions.[Footnote 56] Although BLM 
cannot report how much it has spent on individual exchanges, it 
reported that its lands and realty staff and other involved units 
charged the disposal and acquisition program codes a total of about 
$1.8 million for the land exchange program in fiscal year 2007. BLM 
budget staff told us that while field staff could track the cost of 
individual exchanges, they do not often do so because management has 
not asked about the costs of individual land exchanges and Congress has 
not asked specific questions regarding land exchange costs. 

Nevertheless, BLM has emphasized the importance of estimating and 
tracking the costs associated with an individual land exchange. 
According to BLM's land exchange handbook, processing land exchanges 
requires substantial multiyear commitments of both funding and 
staffing. Therefore, an accurate projection of these funding and 
staffing commitments must be completed before initiating work on an 
exchange. Managers will have to assess the costs of processing 
exchanges and evaluate how the commitment to process an exchange will 
affect other workloads, especially over several years. Furthermore, 
once staff starts to process an exchange, the handbook states that it 
is important to track and monitor the costs and time frame commitments 
to keep the exchange moving and to document any midcourse adjustments 
to the projected time frames or cost commitments. 

The Forest Service's manual does not discuss the importance of tracking 
the costs of individual land exchanges. According to Forest Service 
officials, the agency charges realty activities to a large 
appropriations account--National Forest System Landownership 
Management, which received $91.3 million in fiscal year 2008--and, 
therefore, cannot identify the cost of individual land exchanges or the 
total spent on land exchanges. This account funds many land management 
activities in addition to exchanges, such as issuing special-use 
permits and maintaining boundaries. However, according to the Forest 
Service program lead, more cost information on land exchanges would be 
helpful because the agency is asked by outside parties, including 
Members of Congress, their staffs, and others, about individual 
exchange costs. 

National forests report estimated exchange costs on completed exchanges 
to headquarters, but headquarters officials said this information is of 
limited use because it is an estimate and not the actual costs. 
Instead, a headquarters budget official said the best estimate of how 
much the land exchange program costs is based on the allocations made 
from the National Forest System Landownership Management appropriation 
account. Headquarters allocates the funds to the regions, and the 
regions, in turn, establish workplans that distribute the funds to 
various activities like land exchanges. However, this estimate does not 
inform officials about the actual cost of land exchanges because 
allocations do not necessarily represent expenditures. For example, 
while Forest Service records show that regions planned $13.2 million 
for land exchange activity in fiscal year 2008, the regions do not know 
the amount actually spent. 

In response to our survey, 5 of the 10 BLM and 3 of the 9 Forest 
Service respondents stated that information about the cost of each 
individual land exchange is available to some extent. Most frequently, 
BLM and Forest Service officials said they could provide the cost of 
contracted work and the costs funded by nonfederal proponents for some 
exchanges.[Footnote 57] However, the agencies do not typically track 
staff costs for an exchange, and these are usually the largest costs in 
processing exchanges. 

While BLM and the Forest Service do not track all land exchange costs, 
both agencies' land exchange handbooks call for the ATI to specify the 
division of costs between the agency and nonfederal partners of the 
proposed exchange. All but one of the 29 ATIs that were available for 
our review specified the costs to be borne by the agency and by the 
nonfederal partner.[Footnote 58] However, the breakdown of agency and 
nonfederal costs in ATIs are for specific tasks or steps before the 
work is done and typically do not break out agency personnel costs. For 
example, the 2006 ATI for the Santo Domingo II exchange--which involved 
the New Mexico State Land Office, the Pueblo of Santo Domingo, BLM, and 
a nonprofit organization--listed 16 major tasks for processing the 
exchange and the division of costs for these tasks among the four 
parties. Costs totaled $190,250, of which BLM was to fund $37,500, 
including $15,000 toward the preparation of the environmental 
documentation, $8,000 toward the final appraisals, and $3,000 toward 
title documents. 

BLM's and the Forest Service's Revised Guidance and Training Have 
Helped Address Past Problems, but Participation in Training Is 
Generally Not Mandatory or Systematically Tracked: 

Internal agency reviews found that BLM and the Forest Service needed to 
improve guidance and training on the land exchange process for realty 
staff in order to ensure that exchange requirements, such as 
determining the public interest, were adequately documented. In 
response, BLM and the Forest Service updated their guidance and 
incorporated this guidance into relevant training courses. While the 
agencies' revisions to the guidance provided clearer direction, staff 
are generally not required to participate in training, and the agencies 
do not systematically track staff participation. 

Agencies Revised Guidance and Training to Address Past Problems: 

In past reports, BLM's 2003 workgroup, USDA's Office of the Inspector 
General, and others found that BLM and the Forest Service provided 
limited guidance and training on the land exchange process. The 2003 
BLM workgroup confirmed that BLM was not adequately documenting why 
proposed land exchanges were in the public interest. Furthermore, the 
workgroup found that BLM's guidance and policy did not discuss how to 
exchange lands with some state governments that had legal restrictions 
on conducting land exchanges. 

The BLM Director agreed to implement some of the workgroup's 
recommendations. Table 11 shows these recommendations and the actions 
taken. 

Table 11: BLM Workgroup Recommendations and Actions Taken, as of April 
2008: 

Recommendation: Review guidance to ensure documentation accurately and 
adequately addresses public interest determinations; 
Action taken: The handbook more explicitly calls for documentation that 
the exchange is in the public interest. This documentation must 
demonstrate the following: 
* The resource values and the public objectives that the federal land 
or interests to be conveyed may serve if retained in federal ownership 
are not more than the resource values of the nonfederal lands or 
interest and the public objectives they could serve if acquired; 
* The intended use of the conveyed federal land will not significantly 
conflict with established management objectives on adjacent federal 
land and Indian trust land. 

Recommendation: Grant new or expanded authority for state land 
exchanges; 
Action taken: The handbook contains a new section laying out how land 
exchanges should be processed in states that have constitutional 
limitations on land exchanges, particularly with respect to states' 
ability to provide cash equalization payments. 

Recommendation: Revise training curriculum to ensure it conveys an 
understanding of the importance of fully evaluating and documenting the 
public interest determination; 
Action taken: The headquarters review team said it reviewed the 
curriculum and incorporated this guidance into the training courses. 

Recommendation: Selectively make training mandatory; 
Action taken: No action taken. 

Recommendation: Develop a tool for conducting successful exchanges that 
can be integrated into the exchange handbook and used in training; 
Action taken: A specific tool has not been developed, but the concept 
has been fully incorporated into the handbook and training courses, 
according to agency officials. In addition, the headquarters review 
team implemented other actions to fulfill this recommendation, such as 
developing an internal Web site containing examples of feasibility and 
decision review checklists. 

Source: GAO. 

[End of table] 

The Forest Service has also experienced problems in providing adequate 
land exchange guidance. In 2002, USDA’s Inspector General reported that 
although Forest Service headquarters staff had drafted numerous 
revisions to the exchange manual and handbook, none of those revisions 
had been made final. The report recommended these revisions be made 
final to expand direction and guidance on the exchange program. In 
response, the Forest Service incorporated interim policy changes 
addressing past problems into the agency’s 2004 handbook. Specifically, 
the revised handbook provides new guidance on (1) developing a land 
exchange proposal, (2) preparing feasibility analyses, and (3) 
conducting oversight and reviews associated with exchanges. 

In general, BLM’s 2005 Land Exchange Handbook is more comprehensive 
than the 1999 version of the handbook. Specially, the 2005 handbook 
provides realty staff with more detailed instructions. For example, the 
handbook provides detailed guidance on how the public interest 
determination should be supported. 

To incorporate new guidance on processing land exchanges, BLM and the 
Forest Service revised three training courses offered to BLM and Forest 
Service realty staff—Lands and Realty Academy, National Lands Training 
for Line Officers and Program Managers, and Complex Land Tenure 
Adjustment.[Footnote 59] The courses alert students to past problems 
with the land exchange program, provide students with an overview of 
the new land exchange handbook directives, and raise awareness of 
potential problems when processing an exchange, according to Interior 
training officials. 

The Agencies’ Enhanced Guidance and Training Has Helped Address Past 
Problems, but Participation in Training Is Generally Not Mandatory or 
Systematically Tracked: 

Asked about the usefulness of the agencies’ revised written guidance, 
the majority of survey respondents—9 of the 10 BLM state officials and 
7 of the 9 Forest Service regional officials—reported that the guidance 
provides at least moderately useful information on how to process land 
exchanges, and a few offered suggestions for improvement. For example: 

* BLM respondents suggested providing more examples of relevant 
exchange documents and examples of exchange success stories on BLM’s 
internal land exchange Web site. 

* Forest Service respondents thought the exchange handbook could be 
updated to (1) improve the format of exchange documents, such as the 
ATI and the exchange agreement, and (2) provide guidance on how to work 
with third parties when they work with more than one region. In 
addition, the respondents said that the Forest Service should add more 
timely updates on agency guidance to ensure consistency among the 
regions. 

With regard to training, we have reported that training is essential to 
developing the knowledge and skills needed to administer agency 
programs properly.[Footnote 60] Therefore, encouraging employee 
participation in training can go a long way toward ensuring effective 
program management. The agencies’ guidance does encourage BLM state and 
Forest Service regional officials to provide realty staff with 
training, as needed, in order to ensure staff develop the necessary 
skills to effectively and efficiently process land exchanges. 

While both agencies encourage participation in training, none of the 
three available training courses on land exchanges are mandatory for 
BLM staff, and the Forest Service only requires participation in the 
National Lands Training for Line Officers and Program Managers once 
every 5 years. As a result, agency staff may be processing land 
exchanges without completing training. 

Asked about the availability of the three training courses, the 
officials surveyed reported the following: 

* Lands and Realty Academy. Nine of 10 BLM and 5 of 9 Forest Service 
respondents said that this class was readily available. 

* Complex Land Tenure Adjustment. Nine of 10 BLM and all 9 Forest 
Service respondents reported that this course was readily available. 

* National Lands Training for Line Officers and Program Managers. All 
10 BLM and 8 of 9 Forest Service respondents reported that this 
training was readily available. 

While these officials reported that the training was readily available, 
other factors may affect attendance. According to a BLM official we 
spoke with, the agency restricts the number of staff from each state 
office that may attend the training annually. In addition, a Forest 
Service regional official told us that staff may be reluctant to attend 
lengthy out-of-town training courses for personal reasons. For example, 
the Lands and Realty Academy is an 18-week course, in one 10-week 
segment and two 4-week segments.[Footnote 61] Furthermore, in April 
2009, a Forest Service headquarters official said that there is limited 
travel funding for training. 

The agencies are not required to systematically track staff 
participation in training courses, but 6 of the 10 BLM and all 9 Forest 
Service officials surveyed reported that they informally monitor 
participation in each of the training courses. Generally, the BLM and 
Forest Service respondents stated that because they are responsible for 
nominating participants for the courses, they keep internal records 
showing staff participation in the courses. However, it may be 
difficult to maintain these records. For example, one Forest Service 
regional official said that he tracks staff participation in training, 
but the region’s line officers frequently change positions, making it 
difficult to know who needs training. Although the National Training 
Center can determine which staff have attended training courses through 
an online system,[Footnote 62] it does not maintain a list of staff 
that should enroll in any given training course. 

Agencies Restructured Their Appraisal Functions, but BLM Officials 
Report Appraisals Continue to Delay Land Exchanges: 

As we and others have reported, problems with the appraisal process 
produced appraisals that shortchanged taxpayers and were not timely. 
The agencies restructured their appraisal functions to assure the 
independence of appraisers and BLM took steps to improve appraisal 
timeliness, but the appraisal process, particularly for BLM, continues 
to delay the completion of some land exchanges. The agencies must rely 
on timely appraisals to complete exchanges on schedule. 

Agencies Restructured Their Appraisal Functions to Enhance 
Independence, and BLM Took Some Measures to Ensure More Timely 
Appraisals: 

As far back as 1987, our reports and others issued by Interior’s 
Inspector General and the Appraisal Foundation found that BLM and 
others used procedures that did not comply with recognized appraisal 
standards. For example, Interior’s Inspector General reported in 2003, 
that for a BLM land exchange, BLM officials negotiated away a 
substantial interest in potentially valuable resources and improperly 
valued other federal and state lands.[Footnote 63] According to the 
U.S. Office of Special Counsel,[Footnote 64] BLM’s own internal 
estimates showed that the federal government stood to lose between $97 
million and $117 million on this exchange. In a different report on 
this exchange,[Footnote 65] the Appraisal Foundation concluded that 
appraisers at BLM lacked the institutional independence necessary to 
conduct objective appraisals and faced heavy political pressure from 
their realty managers to conduct appraisals that would expedite land 
transactions. Interior’s Inspector General reports have reached similar 
conclusions about appraiser independence, and our reports have 
highlighted multiple cases of land transactions that inappropriately 
valued land. 

In response to these problems, Interior reorganized its appraisal 
function. Before November 2003, appraisals for land transactions in BLM 
and other Interior land management agencies were conducted by staff 
reporting to realty managers in each of these management agencies. 
[Footnote 66] Beginning in November 2003, Interior removed appraisers 
from the realty offices in each of the agencies and consolidated them 
in a new office, the Appraisal Services Directorate (ASD). Interior 
took this action primarily to insulate appraisers from institutional 
pressure. Under this new organization, appraisers report to, and 
receive performance evaluations from, other appraisers, rather than 
managers responsible for completing land transactions in their 
respective land management agencies. Interior also shifted 
administrative functions associated with appraisals—previously 
conducted by each land management agency’s realty office—to other units 
within Interior. Contracting for land appraisals was one such function. 

In 2006, we reviewed ASD to determine, among other things, (1) the 
extent to which Interior’s appraisal policies and procedures ensure 
compliance with recognized appraisal standards and (2) what, if 
anything, affects ASD’s working relationships with its client agencies 
and its overall efficiency in providing appraisal services.[Footnote 
67] We found that although the quality of appraisals had improved since 
ASD’s inception, Interior needed to take several other steps to ensure 
that land transactions are based on appraised values that adhere to 
recognized appraisal standards and to establish a better accountability 
framework for ASD to help meet Interior agencies’ appraisal needs. 
Table 12 describes our recommendations on quality and timeliness and 
the actions Interior has taken to address them. 

Table 12: GAO Recommendations on Appraisal Quality and Timeliness and 
Agency Actions, as of March 2009: 

GAO recommendation: Ensure that ASD assigns appraisals requiring 
specialized skills to appraisers and reviewers with these skills; 
Agency actions: In July 2007, ASD developed and implemented a Statement 
of Work for appraisals, requiring appraisers submitting proposals for 
appraisal work to include evidence of competence in appropriate skills. 

GAO recommendation: Establish and implement standard review procedures 
for ASD’s review appraisers;
Agency actions: In July 2007, ASD implemented a documentation checklist 
to be used for all appraisal reports. 

GAO recommendation: Establish and implement a compliance inspection 
program, focusing particularly on appraisals with a higher likelihood 
of noncompliance;
Agency actions: In November 2006 and January 2007, ASD completed pilot 
reviews under its newly established compliance inspection program. ASD 
established this program as an internal management and quality control 
process to ensure that appraisals and appraisal reviews conducted on 
behalf of Interior agencies are performed in compliance with appraisal 
standards. 

GAO recommendation: Require ASD appraisers and land management agency 
realty specialists requesting work to negotiate and reach agreement on 
completion dates for appraisal requests, and hold ASD accountable for 
meeting these dates; 
Agency actions: In March 2009, ASD reported that it has implemented the 
following: (1) formed a National Appraisal Coordination Team consisting 
of appraisers and agency realty staff that meets quarterly to discuss 
appraisal priorities and ASD resources; (2) developed a function in the 
Appraisal Request and Review Tracking System (ARRTS) that sends an e-
mail to the requesting realty specialist soon after the appraisal 
request is received by ASD through ARRTS if the requested appraisal 
completion date is unreasonable and therefore cannot be met; and (3) 
developed a 1.5-day training course for BLM realty specialists that 
includes training on appraisal time frames. This is expected to help 
realty specialists request appraisals in more realistic time frames. 

GAO recommendation: Develop a system to rank appraisal requests that 
allows higher priority and more time-sensitive land transactions to be 
appraised in a timely fashion; 
Agency actions: In July 2007, Interior’s National Business Center 
established department policy on setting workload priorities for 
appraisal services. This policy requires ASD to coordinate with 
Interior agencies and advise as to the most efficient and timely 
approach to completing appraisal projects that are competing for 
appraisal resources. ASD management also established quarterly meetings 
between ASD and Interior agencies at the management level so that they 
can continue to work toward a solution to setting priorities for 
appraisal assignments. 

Source: GAO. 

[End of table] 

As table 12 shows, Interior has taken steps to act on our 
recommendations. However, it has only recently acted on our 
recommendation to establish dates for completing appraisals and to hold 
ASD accountable for meeting these dates. We will monitor BLM's 
implementation of this recommendation because we continue to believe 
that appraisals need to be timely to meet schedules for completing land 
exchanges. 

The Appraisal Foundation also reviewed the Forest Service's appraisal 
policies and procedures in 2000.[Footnote 68] It found that, like BLM, 
Forest Service staff appraisers lacked independence. Specifically, the 
foundation stated that staff appraisers reported to line officers, who 
also control hiring, advancement, and other personnel decisions. As a 
result, the staff appraisers were not independent of the line officer 
to whom he or she reports. Moreover, the line officer is in a position 
to influence or overrule an appraiser's professional judgment. The 
report recommended that appraisers report directly to the regional 
appraiser, and the regional appraiser report to the chief appraiser. 

The Forest Service did not fully agree with the recommendation, stating 
that implementing this recommendation would require it to create an 
independent organization within the Forest Service that would be 
difficult to administer, to establish work priorities, and to hold 
accountable. However, in 2000, the Forest Service did partially 
implement this recommendation by placing all staff appraisers within 
the regions under the direct supervision of the regional appraiser and 
by placing the regional appraiser under the direct supervision of the 
regional director with land program responsibilities. Moreover, the 
Forest Service charged the chief appraiser with completing the annual 
performance evaluations for regional appraisers and providing these to 
the regional director. According the Forest Service Chief Appraiser, as 
of April 2009, he does not complete an annual performance evaluation 
for regional appraisers, but rather provides comments to the regional 
director, who prepares the evaluation. The Chief Appraiser added that 
he does complete a Valuation Compliance Inspection of each regional 
appraiser once every 3 years. 

BLM Officials Report Appraisals Continue to Cause Problems with the 
Timeliness of Land Exchanges: 

Eight of the 10 BLM officials, but only 1 of the 9 Forest Service 
officials, surveyed found the timeliness of appraisals to be 
problematic. As noted earlier, officials had cited the timeliness of 
appraisals as one of the most commonly cited reasons for delays in 
completing land exchanges. 

In terms of the valuation process itself, BLM and Forest Service survey 
respondents most frequently cited problems with the contracting process 
for appraisals, the unavailability of contracted appraisers, and the 
unavailability of in-house appraisers (5 of 19 in each case) as 
problems their office had experienced with the valuation process. 
Again, BLM respondents accounted for four of the five in each case. 

BLM and Forest Service survey respondents elaborated on these problems. 
For example, two BLM respondents called the ASD contracting process 
"cumbersome," and one of those respondents further characterized the 
ASD process as "significantly more costly and very delayed." Another 
BLM respondent reported that ASD staff "did not work well with our 
agency" and that the process is "ambiguous and confusing." Forest 
Service respondents also commented on the problems with the valuation 
process that affect appraisal timeliness. For example, one Forest 
Service respondent commented that appraisers are "overcommitted and 
rarely meet delivery commitments," and another reported that the 
availability of qualified appraisers "remains somewhat limited." 

ASD appraisals may not be timely, in part because ASD has difficulty 
identifying qualified contractors. ASD officials we interviewed cited 
several reasons for this difficulty, including the limited number of 
contractors qualified to conduct specific appraisal requests and 
qualified contractors' lack of interest in conducting government 
appraisals. On the second point, the ASD officials stated that 
contractors might not be interested in conducting appraisals for ASD 
because of the long time frames associated with exchanges and the 
resulting delay in receiving payment for services, the high level of 
public scrutiny surrounding exchange appraisals, and the opportunities 
of more lucrative nongovernment appraisal assignments. 

Conclusions: 

The federal land management agencies hold a public trust: to manage and 
preserve millions of acres of land in pursuit of multiple national 
goals. While land exchanges can be an effective tool for acquiring 
lands in the public interest, the process is complex and may be lengthy 
and costly. It is important, therefore, that BLM and the Forest Service 
effectively manage and oversee the land exchange process to ensure that 
they are using their limited resources wisely. 

Responding to criticisms that their land exchanges have not always 
served the public interest or returned fair value to the federal 
government, BLM and the Forest Service have taken actions intended to 
make the land exchange process more transparent and accountable in 
order to better assure that U.S. taxpayers are well served. Increased 
oversight of the land exchange process has resulted in problems being 
identified and resolved earlier in the exchange process. Furthermore, 
BLM's policy to discontinue use of escrow accounts and the two 
agencies' revised guidance and training have contributed to better 
management of the land exchange programs. However, these actions have 
not always been fully implemented or are not fully adequate to ensure 
the agencies are adhering to their requirements and policies and 
effectively using their resources to serve the public interest. 

Given the complexity of the land exchange process, recent policy 
changes, and staff turnover in both agencies, it is critical that the 
agencies continue to take actions to effectively oversee and manage 
land exchanges. Improvements to the agencies' reviews would provide for 
a more transparent decision-making process and provide critical 
information for management and new staff on how past problems were 
overcome. A clearly stated records retention policy and adherence to 
that policy would help manage and oversee land exchanges. Furthermore, 
Forest Service headquarters oversight of regional review programs will 
better ensure the regions provide adequate review of land exchanges. In 
addition, better management and oversight of BLM ledgers would help 
ensure that they are complying with agency policy and are accurate. 
Clearly defining third-party facilitators, consistently applying 
disclosure policies to them, and including them in the review process 
will provide more incentive for realty staff to obtain required 
disclosure documentation, thereby helping the agencies maintain control 
of the exchange process. Developing national land tenure strategies at 
BLM and the Forest Service could help clarify organizational priorities 
and unify agency staff in the pursuit of shared goals for land 
exchanges. We continue to believe that better data on the cost of land 
exchanges will help the agencies decide whether a proposed land 
exchange is affordable and worthwhile. Finally, by making select 
training mandatory and developing a formal system to track individuals' 
training, the agencies can better ensure that realty staff develop and 
maintain the skills necessary to process exchanges. 

Recommendations for Executive Action: 

We recommend that the Secretary of the Interior and the Secretary of 
Agriculture take the following 15 actions in order to build on the 
improvements to the land exchange programs BLM and the Forest Service 
have made. 

We recommend that the Secretary of the Interior and the Secretary of 
Agriculture direct the heads of BLM and the Forest Service to 
strengthen the review process by: 

* assuring that key problems identified and their resolutions are 
systematically recorded, and: 

* clarifying the retention policy for key exchange documents and 
ensuring staff follow the policy. 

We further recommend that the Secretary of Agriculture direct the Chief 
of the Forest Service to improve the review process by: 

* making it a priority for the headquarters land exchange review team 
to review regional exchange programs and follow up on implementation of 
their recommendations, and: 

* ensuring that the regions provide consistent oversight of land 
exchanges. 

We also recommend that the Secretary of the Interior direct the 
Director of BLM to better manage value imbalances in multiphase 
exchanges and protect federal funds by: 

* ensuring that BLM state offices document their decision and 
supporting rationale for whether and how to secure land exchange 
imbalances; 

* ensuring that an ATI documents how the ledger will be used to process 
a multiphase exchange; 

* revising the standard format for ledgers prescribed in the exchange 
handbook to assure that each ledger clearly demonstrates that the 
ledger (1) is balanced at least every 3 years and (2) is either open or 
closed; 

* ensuring that offices prepare ledgers and follow the ledger format, 
including revisions cited above; 

* including ledgers in feasibility and decision reviews to ensure 
quality; and: 

* providing copies of ledger updates to agency headquarters for 
tracking of balances due to the United States. 

Finally, we recommend that the Secretary of the Interior and the 
Secretary of Agriculture direct the heads of BLM and the Forest Service 
to: 

* clarify the definition of a third-party facilitator, ensure that 
disclosure guidelines are consistently applied to all third-party 
facilitators, and include disclosure documentation in the review 
process; 

* develop and issue national land tenure strategies for each agency and 
encourage the BLM state and Forest Service regional offices to develop 
their own plans to help guide land exchange decisions; 

* track the agencies' costs of processing individual land exchanges; 

* determine the elements of current training that should be mandatory 
to ensure that staff are able to process exchanges in conformance to 
agency guidance, create a formal system to track attendance at 
training, and determine how often training should be retaken; and: 

* ensure that staff have completed this mandatory training before 
working on land exchanges. 

Agency Comments and Our Evaluation: 

We provided a draft of this report to USDA for review and comment. In 
written comments, the Chief of the U.S. Forest Service generally agreed 
with the report and 6 of the 9 recommendations for the Forest Service; 
it partially agreed with the other 3 recommendations. First, the Forest 
Service agreed in part with our recommendation to develop and issue a 
national land tenure strategy, stating that the department's National 
Land Acquisition Plan and agency's Strategic Plan provide sufficient 
overarching guidance in the development of regional and forest plans. 
It did agree that some of the regional or forest plans on land 
adjustment activities were out of date or inadequate. We maintain that 
the Forest Service's guidance does not include national strategies that 
could help clarify organizational priorities and unify staff in the 
pursuit of shared goals. Second, the Forest Service partially agreed 
with our recommendation to track the cost of individual exchanges 
because it recognizes that tracking the costs of individual exchanges 
may provide some benefit. However, it stated that the cost of 
developing and implementing a tracking system would outweigh the 
benefit. The Forest Service added that it is planning to test a 
database designed to centralize information on the rough costs of 
individual land exchanges to help make decisions, track changes, and 
report to stakeholders and Congress. We commend the Forest Service for 
taking steps to collect data on the cost of land exchanges. However, it 
is unclear from the Forest Service's comments whether this proposed 
database will enable tracking of costs as we have recommended. We 
continue to believe that better data on the cost of land exchanges will 
help the agencies decide whether a proposed land exchange is affordable 
and worthwhile. Finally, the Forest Service agreed in part with our 
recommendation to ensure that its staff has completed training before 
working on land exchanges. It stated that it agrees with the intent of 
the recommendation to clearly describe and implement training and 
supervisory requirements. However, it did not believe that the 
recommendation gave it the flexibility to allow inexperienced employees 
to work on exchanges with supervision. While we acknowledge the need 
for flexibility, we believe that the Forest Service will ensure that 
realty staff develop the necessary skills to process an exchange if it 
selectively makes training mandatory and requires the training to be 
completed before handling land exchanges. Appendix V provides the 
Forest Service's written comments, along with our detailed evaluation 
of those comments. In addition, the Forest Service provided technical 
comments on the draft report, which we have incorporated as 
appropriate. 

We also provided a draft of this report to Interior for review and 
comment. In written comments, the Acting Assistant Secretary for Land 
and Minerals Management did not directly comment on whether the 
department agreed or disagreed with our recommendations. It did state 
that the department does not concur with some of the report's findings. 
Interior's letter highlighted two areas of concern: (1) the document 
retention policy and (2) the use of ledgers to track value imbalances. 

Interior disagrees with our finding that BLM's guidance does not 
clearly state the document retention policy for land exchange 
documents. We continue to believe that the BLM policy for records 
retention is not clear regarding land exchange records. The four 
subsections pertaining to land exchanges do not always provide clear 
time frames for how long documents are to be retained. In response to 
Interior's comments, we revised the report to highlight the different 
interpretations of this policy by two senior lands and realty managers. 
We believe these differing interpretations underscore the confusion 
inherent in the current policy. Our assessment of the policy, along 
with program officials' differing interpretations, support our 
conclusion that the retention policy is unclear. 

Although we found that the agency is not adhering to its guidance for 
maintaining ledgers, Interior stated that BLM believes that the land 
exchange case files as a whole document the values of lands conveyed 
and any resulting imbalances. Nevertheless, BLM's land exchange 
handbook states, and we concur, that ledgers should completely and 
accurately reflect the balances due so that values owed are easily 
identified. Indeed, as Interior stated, BLM cannot now verify the 
cumulative imbalance. We continue to believe better management and 
oversight of BLM ledgers would help ensure that the ledgers are 
complying with regulations and policy and that the imbalances reported 
are accurate. 

Interior also provided technical comments. Most significantly, it 
disagrees with our statement that the authority for certain multiphase 
exchanges cited in the draft report remains questionable and that these 
exchanges appear to have resulted in transfers of cash that should have 
been regarded as sale or exchange proceeds or payments for land 
acquisitions. We are exploring these issues separately with Interior's 
Office of the Solicitor. 

Appendix VI presents Interior's letter and our detailed response. 

We are sending copies of this report to the Secretary of the Interior, 
the Secretary of Agriculture, the Director of Bureau of Land 
Management, the Chief of the Forest Service, and other interested 
parties. In addition, the report will be available at no charge on the 
GAO Web site at [hyperlink, http://www.gao.gov]. 

If you or your offices have questions about this report, please contact 
me at (202) 512-3841 or nazzaror@gao.gov. Contact points for our 
Offices of Congressional Relations and Public Affairs may be found on 
the last page of this report. Key contributors to this report are 
listed in appendix VII. 

Singed by: 

Robin M. Nazzaro: 
Director, Natural Resources and Environment: 

[End of section] 

Appendix I: Objectives, Scope, and Methodology: 

This appendix details the methods we used to examine the Department of 
the Interior's (Interior) Bureau of Land Management (BLM) and the 
Department of Agriculture's (USDA) Forest Service land exchange 
programs. We were asked to (1) analyze the number, trends, and 
characteristics of BLM and Forest Service land exchanges, and (2) 
determine the actions BLM and the Forest Service have taken to address 
previously identified key problems and the effectiveness of these 
actions. 

For both of our objectives, we reviewed relevant documents and 
interviewed BLM and Forest Service officials responsible for land 
exchanges at headquarters, state or regional offices, and field 
offices, and an official from the Colorado State Land Board. We also 
interviewed officials from two for-profit, third-party facilitators-- 
Western Land Group based in Denver, Colorado, and Summit Resources 
based in Phoenix, Arizona--as well as officials from the Western Lands 
Project, a nonprofit organization that tracks land exchanges. To learn 
about the exchange process in detail, we visited with BLM state and 
Forest Service regional officials in Arizona, Colorado, and New Mexico. 
We also met with BLM officials at the Royal Gorge Field Office in 
Colorado and with Forest Service officials at the Tonto National Forest 
in Arizona and the combined Grand Mesa, Uncompahgre, and Gunnison 
National Forests in Colorado. We primarily selected these sites because 
they were processing many land exchanges. We attended several sessions 
of the Complex Land Tenure Adjustment training course at the BLM 
National Training Center in Phoenix, Arizona, in June 2008. 

To address both objectives, we also conducted a Web-based survey of 10 
BLM state land exchange program managers and all 9 Forest Service 
regional program managers. The BLM managers were located in Arizona, 
California, Colorado, Idaho, Montana, Nevada, New Mexico, Oregon, Utah, 
and Wyoming. The nine Forest Service managers were located in Regions 
1, 2, 3, 4, 5, 6, 8, 9, and 10.[Footnote 69] We surveyed these managers 
because their offices were processing land exchanges during the period 
we reviewed. In this survey, we asked program managers about trends and 
reasons for overall exchange activity, legislated land exchanges, third-
party facilitators, BLM and Forest Service land exchange proposal 
reviews, the land exchange ledgers and financial assurances BLM uses to 
account for land value imbalances, BLM's land tenure strategy plans, 
the timeliness of land exchanges, the valuation process, land exchange 
training and guidance, and the cost of exchanges. To develop the draft 
survey, we obtained and incorporated comments from the BLM and Forest 
Service land exchange program leads as appropriate. We also pretested 
the survey with BLM state office and Forest Service regional office 
land exchange program leads and made changes in the survey's questions 
as appropriate. Information about accessing our survey was provided via 
e-mail for all survey participants. We provided survey respondents 
access to the survey via e-mail in December 2008 and encouraged them to 
use all available resources in their office to provide the most 
complete and accurate answers possible. To ensure security and data 
integrity, we provided all participants with a user name and a personal 
password that allowed them to access the survey and ensure that no one 
else could edit the answers. We achieved a 100 percent response rate 
for our survey. 

For our first objective, to analyze the number, trends, and 
characteristics of BLM and Forest Service land exchanges, we requested 
that the agencies' headquarters land exchange program leads collect 
information on the universe of pending, completed, or terminated land 
exchanges processed from October 31, 2004, through June 30, 2008. The 
data collected included the identity and vital statistics on the 
exchanges, which encompassed the number of federal and nonfederal 
acres, parcels, and landowners; the appraised land values; the cash 
equalization payment; the type of interests to be exchanged; the 
Agreement to Initiate (ATI) date; the current exchange status; the 
completion date (if applicable); the third-party facilitator involved; 
specific legislation (if any); and BLM land exchanges with ledgers. We 
assessed the reliability of these data by reviewing them for 
inconsistencies and missing information, and then followed up with BLM 
state and Forest Service regional contacts as necessary to make 
corrections. From the data provided, we calculated the average time to 
complete exchanges using the date the ATI was signed and the completion 
date.[Footnote 70] Furthermore, to determine the reasons for any trends 
in land exchanges, we interviewed agency officials at each level and 
used our Web-based survey to ask BLM and Forest Service land exchange 
program leads about the overall trends in exchanges since 2000 and the 
reasons for these trends. In addition to our survey, we gathered more 
detailed information from agency officials on selected characteristics 
of these exchanges: (1) multiphase exchanges, including those using a 
ledger; (2) exchanges assisted by a third-party facilitator; and (3) 
specifically legislated exchanges. For specifically legislated 
exchanges, our Office of General Counsel summarized the provisions of 
the laws, and then we compared the provisions with exchanges conducted 
pursuant to the agencies' broad discretionary authority to determine 
how they differed, if at all. 

See appendixes III and IV for selected information on BLM and Forest 
Service land exchanges processed from October 1, 2004, through June 30, 
2008. 

For our second objective, to determine the effectiveness of actions BLM 
and the Forest Service have taken to address previously identified 
problems, we determined the (1) previously identified problems, (2) 
actions agencies took in response to those problems, and (3) 
effectiveness of those actions. 

First, we reviewed GAO reports issued since 1985, Interior and USDA 
inspector general reports, Appraisal Foundation reports, and BLM and 
Forest Service internal reviews (see appendix II for a list of these 
reports). For each of these reports, we identified the problems cited 
and recommendations. We placed these problems and recommendations into 
seven categories: (1) assure that certain requirements are met, (2) use 
of escrow accounts, (3) work with third-party facilitators, (4) 
planning, (5) guidance and training, (6) cost of exchanges, and (7) 
appraisals. Of the 115 problems identified in the past reports, we 
choose to follow up on 34 problems--each of which fell within one of 
the seven categories. We selected these problems for follow-up based on 
the frequency of the problem cited, and whether they were related to 
statutory and regulatory requirements. Although the category with the 
most problems--50--was the appraisal category, we conducted limited 
work on appraisals because we reviewed Interior's Appraisal Services 
Directorate in September 2006.[Footnote 71] 

Second, to identify actions taken in response to the seven categories 
of problems, we interviewed land exchange program managers at BLM and 
the Forest Service and obtained and analyzed related documentation on 
the actions these officials cited. We also obtained and reviewed agency 
responses to the recommendations and agency status reports. 

Third, to determine the effectiveness of the agencies' actions to 
address the key problems earlier reports had identified, we analyzed 
the available key documents for a sample of land exchanges processed 
from October 2004 through June 2008 to determine (1) whether the 
previously identified problems were addressed, (2) whether internal BLM 
and Forest Service reviews documented these problems, and (3) the 
resolution of the documented problems. We selected a nongeneralizable 
sample of 31 land exchanges out of the 250 exchanges processed from 
October 2004 through June 2008, comprised of 27 exchanges that 
accounted for 85 percent of acres that the agencies have or plan to 
acquire, and 4 others that we reviewed during the course of our site 
visits. We based our selection on acreage rather than land value 
because values were not available for all of the exchanges and because 
acreage is a better indicator of land area affected. We added the 
remaining 4 exchanges--1 by BLM and 3 by the Forest Service--because 
they were available for our review during our site visit with the BLM 
state office and Forest Service regional office in New Mexico. Of the 
31 exchanges in our sample, 19 were BLM and 12 were Forest Service 
exchanges. We then developed a data collection instrument to record the 
results of our review of key documents associated with each exchange. 

To examine the sample of 31 exchanges in detail, we identified the 
following nine key documents for our review: 

* Five documents pertinent to the exchange, including the feasibility 
analysis, the ATI, the draft decision, the final decision, and any land 
exchange ledgers used in BLM multiphase exchanges. 

* Four agency reviews of the exchange documents at two stages, 
including BLM or Forest Service headquarters or regional review team 
reviews at the feasibility and decision stages, and Interior's Office 
of the Solicitor review of BLM exchanges at the feasibility and 
decision stages. 

The BLM and Forest Service exchange program leads confirmed that these 
were the key documents in processing a land exchange. 

The data collection instrument we developed to record our review of the 
31 exchanges focused on six requirements or guidelines selected on the 
basis of our and other prior reports citing problems in meeting these 
requirements or guidelines, interviews with the BLM and Forest Service 
land exchange leads and other agency staff, document reviews, and the 
information provided in the land exchange training sessions we 
attended. The six requirements or guidelines were to (1) properly 
describe the lands subject to an exchange; (2) ensure that the proposed 
exchange conforms with the land use plan; (3) determine that the public 
interest will be well served; (4) determine the dollar values of the 
lands to be exchanged, including whether the values are within 25 
percent of each other; (5) ensure parties provide title to the 
properties involved; and (6) ensure compliance with the National 
Environmental Policy Act.[Footnote 72] 

In addition to our review of land exchange documents, we surveyed BLM 
and Forest Service officials about the effectiveness of certain actions 
related to the categories of past problems we identified: (1) assure 
that certain requirements or guidelines are met, (2) use of escrow 
accounts, (3) work with third-party facilitators, (4) planning, (5) 
guidance and training, (6) cost of exchanges, and (7) appraisals. 

Finally, for the 31 exchanges in our sample, we obtained and reviewed 
(1) documents on third-party facilitators' compliance with certain 
requirements or guidelines to disclose their relationships with 
nonfederal landowners involved in the exchanges, and (2) seven land 
exchange ledgers used within our time frame to determine how ledgers 
were implemented and conducted follow-up interviews with the BLM state 
offices responsible for managing the ledgers. 

We conducted this performance audit from March 2008 to June 2009 in 
accordance with generally accepted government auditing standards. Those 
standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe that 
the evidence obtained provides a reasonable basis for our findings and 
conclusions based on our audit objectives. 

[End of section] 

Appendix II: Prior Reviews and Audits of the BLM and Forest Service 
Land Exchange Programs: 

The Appraisal Foundation: 

Evaluation of the Appraisal Organization of the Department of Interior 
Bureau of Land Management. Washington, D.C., October 9, 2002. 

Evaluation of the Appraisal Organization of the USDA Forest Service. 
Washington, D.C., March 28, 2000. 

Department of Agriculture, Office of Inspector General: 

Forest Service National Landownership Adjustment Team, Washington, D.C. 
Report No. 08601-27-SF. Washington, D.C., March 28, 2002. 

Forest Service Siuslaw National Forest Land Adjustment Program, 
Corvallis, Oregon. Report No. 08003-7-SF. Washington, D.C., September 
10, 2001. 

Forest Service Pacific Southwest Region Zephyr Cove Land Exchange, Lake 
Tahoe Basin Management Unit, South Lake Tahoe, California. Report No. 
08003-6-SF. Washington, D.C., July 14, 2000. 

Forest Service Pacific Southwest Region Thunderbird Lodge Land 
Exchange, Lake Tahoe Basin Management Unit, South Lake Tahoe, 
California. Report No. 08801-5-SF. Washington, D.C., April 30, 1999. 

Forest Service Humboldt-Toiyabe National Forest Land Adjustment 
Program, Fiscal Years 1990-1997, Sparks, Nevada. Report No. 08003-02- 
SF. Washington, D.C., September 11, 1998. 

Forest Service Pacific Southwest Region Title To Physical Improvements 
On The Zephyr Cove Land Exchange, Lake Tahoe Basin Management Unit, 
South Lake Tahoe, California. Report No. 08003-4-SF. Washington, D.C., 
August 26, 1998. 

Department of the Interior, Bureau of Land Management: 

Appraisal and Exchange Workgroup Final Report. Washington, D.C., May 
2003. 

Department of the Interior, Office of Inspector General: 

Land Exchange and Acquisitions, Bureau of Land Management Utah State 
Office: Independent Review Will Help Protect Integrity of Appraisal 
Process. Report No. 2001-I-413. Sacramento, CA, July 31, 2001. 

Nevada Land Exchange Activities, Bureau of Land Management. Report No. 
96-I-1025. Washington, D.C., July 15, 1996. 

GAO: 

Interior's Land Appraisal Services: Actions Needed to Improve 
Compliance with Appraisal Standards, Increase Efficiency, and Broaden 
Oversight. [hyperlink, http://www.gao.gov/products/GAO-06-1050]. 
Washington, D.C.: September 28, 2006. 

Federal Land Exchange: Assessment of Mount Hood Land Appraisal Reports. 
[hyperlink, http://www.gao.gov/products/GAO-06-1135R]. Washington, 
D.C.: September 26, 2006. 

BLM and the Forest Service: Land Exchanges Need to Reflect Appropriate 
Value and Serve the Public Interest. [hyperlink, 
http://www.gao.gov/products/GAO/RCED-00-73]. Washington, D.C.: June 22, 
2000. 

Federal Land Acquisition: Land Exchange Process Working But Can Be 
Improved. [hyperlink, http://www.gao.gov/products/GAO/RCED-87-9]. 
Washington, D.C.: February 5, 1987. 

[End of section] 

Appendix III: BLM Completed, Pending, or Terminated Land Exchanges, 
October 1, 2004, through June 30, 2008: 

State, field office, and other offices: Arizona: Safford; 
Exchange name: Phelps Dodge Dos Pobres; 
Status: Completed; 
Number of nonfederal acres: 3,866.57; 
Total value of federal interests conveyed: $6,252,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 16,296.88; 
Total value of federal interests conveyed: $5,232,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 4/4/1995; 
Date exchange completed, if applicable: 9/16/2005; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 10.45. 

State, field office, and other offices: Arizona: Safford; 
Exchange name: Asarco Ray; 
Status: Pending; 
Number of nonfederal acres: 7,300.00; 
Total value of federal interests conveyed: $1,224,200; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 10,976.00; 
Total value of federal interests conveyed: @1,292,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 1/9/1998; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

State, field office, and other offices: Arizona: Yuma; 
Exchange name: Harvey's Fishing Hole; 
Status: Pending; 
Number of nonfederal acres: 225.85; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 27.82; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 4/14/2008; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

State, field office, and other offices: Arizona total: 
Status: 1 completed, 2 pending; 
Number of nonfederal acres: 11,392.42; 
Total value of federal interests conveyed: $7,476,200; 
Equalization payment by nonfederal party: $0; 
Number of federal acres: 27,300.70; 
Total value of federal interests conveyed: $6,524,000; 
Equalization payment by U.S.: $0. 

State, field office, and other offices: California: Arcata; 
Exchange name: Etter-Lake Ridge; 
Status: Completed; 
Number of nonfederal acres: 40.00; 
Total value of nonfederal interests acquired: $18,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 40.00; 
Total value of federal interests conveyed: $18,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 1/25/2001; 
Date exchange completed, if applicable: 8/18/2006; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 5.56. 

State, field office, and other offices: California: Bakersfield; 
Exchange name: Sprague Ranch; 
Status: Completed; 
Number of nonfederal acres: 960.26; 
Total value of nonfederal interests acquired: $946,000; 
Equalization payment by nonfederal party: $4,964; 
Number of federal acres: 5,993.59; 
Total value of federal interests conveyed: $950,964; 
Equalization payment by U.S.: [Empty];
Date ATI signed[A]: 8/31/2004; 
Date exchange completed, if applicable: 2/28/2006; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 1.49. 

State, field office, and other offices: California: Bakersfield; 
Exchange name: West King Min Estate; 
Status: Completed; 
Number of nonfederal acres: 32.50; 
Total value of nonfederal interests acquired: $10,700; 
Equalization payment by nonfederal party: $802; 
Number of federal acres: 2,775.45; 
Total value of federal interests conveyed: $11,502; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 9/25/2002; 
Date exchange completed, if applicable: 2/18/2006; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 3.40. 

State, field office, and other offices: California: California Desert 
District Office; 
Exchange name: Palo Verde; 
Status: Completed; 
Number of nonfederal acres: 29,537.74; 
Total value of nonfederal interests acquired: $6,187,100; 
Equalization payment by nonfederal party: $183,886; 
Number of federal acres: 2,006.87; 
Total value of federal interests conveyed: $6,472,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 9/12/1997; 
Date exchange completed, if applicable: 6/23/2006; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 8.78. 

State, field office, and other offices: California: California Desert 
District Office; 
Exchange name: State of California; 
Status: Pending; 
Number of nonfederal acres: 123,423.02; 
Total value of nonfederal interests acquired: $12,232,316; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 2,289.60; 
Total value of federal interests conveyed: $14,314,091; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 11/17/1995; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

State, field office, and other offices: California: Redding; 
Exchange name: Comingdeer; 
Status: Completed; 
Number of nonfederal acres: 42.40; 
Total value of nonfederal interests acquired: $345,000; 
Equalization payment by nonfederal party: $97,000; 
Number of federal acres: 225.00; 
Total value of federal interests conveyed: $442,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 2/20/2002; 
Date exchange completed, if applicable: 11/15/2004; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 2.74. 

State, field office, and other offices: California: Redding; 
Exchange name: Salmon Creek Resources; 
Status: Completed; 
Number of nonfederal acres: 566.00; 
Total value of nonfederal interests acquired: $763,000; 
Equalization payment by nonfederal party: $137,000; 
Number of federal acres: 215.85; 
Total value of federal interests conveyed: $900,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 3/8/2005; 
Date exchange completed, if applicable: 10/15/2007; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 2.60. 

State, field office, and other offices: California: Redding; 
Exchange name: Keswick; 
Status: Pending; 
Number of nonfederal acres: 960.00; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 104.22; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 10/5/2007; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

State, field office, and other offices: California: Redding; 
Exchange name: Jaxon-Baker; 
Status: Pending; 
Number of nonfederal acres: 275.74; 
Total value of nonfederal interests acquired: $367,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 101.55; 
Total value of federal interests conveyed: $378,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 9/17/2007; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

State, field office, and other offices: California: Palm Springs So. 
Coast; 
Exchange name: Flat Top; 
Status: Pending; 
Number of nonfederal acres: 585.77; 
Total value of nonfederal interests acquired: $543,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 128.17; 
Total value of federal interests conveyed: $616,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 4/20/2005; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

State, field office, and other offices: California: Palm Springs So. 
Coast; 
Exchange name: Agua Caliente Band of Cahuilla Indians (Santa Rosa/San 
Jacinto NM's); 
Status: Pending; 
Number of nonfederal acres: 1,440.00; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 5,783.00; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 7/31/2002; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

State, field office, and other offices: California: Ukiah; 
Exchange name: Black Forest II; 
Status: Completed; 
Number of nonfederal acres: 37.19; 
Total value of nonfederal interests acquired: $84,700; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 990.66; 
Total value of federal interests conveyed: $84,700; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 10/25/2002; 
Date exchange completed, if applicable: 3/10/2006; 
Third-party facilitator name, if any: CAL-BMX; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 3.37. 

State, field office, and other offices: California total: 
Status: 7 completed, 5 pending; 
Number of nonfederal acres: 157,900.62; 
Total value of nonfederal interests acquired: $21,496,816; 
Equalization payment by nonfederal party: $423,652; 
Number of federal acres: 20,653.96; 
Total value of federal interests conveyed: $24,187,257; 
Equalization payment by U.S.: $0. 

[End of table] 

Note: This table contains 13 columns, which are divided across two 
pages. 

State, field office, and other offices: Colorado: Glenwood Springs; 
Exchange name: Diamond S Ranch; 
Status: Completed; 
Number of nonfederal acres: 60.95;
Total value of nonfederal interests acquired: $640,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 160.00
Total value of federal interests conveyed: $640,000
Equalization payment by U.S.: [Empty] 
Date ATI signed[A]: 10/6/1997; 
Date exchange completed, if applicable: 1/25/2008; 
Third-party facilitator name, if any: Western Land Group, Inc. 
Average time to complete exchange from date ATI signed to date 
completed (in years): 10.30. 

State, field office, and other offices: Colorado: Glenwood Springs; 
Exchange name: King Creek; 
Status: Terminated; 
Number of nonfederal acres: 640.00
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 1,005.00; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 3/17/1998; 
Date exchange completed, if applicable: 
Third-party facilitator name, if any: Western Land Group, Inc. 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

State, field office, and other offices: Colorado: Grand Junction; 
Exchange name: Mesa Mood (Schroder); 
Status: Terminated; 
Number of nonfederal acres: 768.18; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 773.00
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 12/18/2001; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

State, field office, and other offices: Colorado: Gunnison; 
Exchange name: Trout Creek; 
Status: Terminated; 
Number of nonfederal acres: 640.55; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 554.89
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 8/2/2006; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: Mountain West Land Services; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 

State, field office, and other offices: Colorado: Kremmling; 
Exchange name: Blue Valley Ranch; 
Status: Pending; 
Number of nonfederal acres: 2,005.39; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 1,651.85; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 6/23/2005; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: Western Land Group, Inc. 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

State, field office, and other offices: Colorado: Kremmling; 
Exchange name: Smith Creek Mesa Phantom Canyon; 
Status: Completed; 
Number of nonfederal acres: 719.00; 
Total value of nonfederal interests acquired: $1,150,000; 
Equalization payment by nonfederal party: $53,000; 
Number of federal acres: 485.31; 
Total value of federal interests conveyed: $1,203,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 10/29/2002; 
Date exchange completed, if applicable: 9/22/2005; 
Third-party facilitator name, if any: Shepard & Associates; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 2.90. 

State, field office, and other offices: Colorado: Kremmling; 
Exchange name: Windy Gap; 
Status: Pending; 
Number of nonfederal acres: 342.76; 
Total value of nonfederal interests acquired: [Empty];
Equalization payment by nonfederal party: [Empty];
Number of federal acres: 574.14; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 9/18/2000; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]; 

State, field office, and other offices: Colorado: Little Snake; 
Exchange name: Emerald Mountain; 
Status: Completed; 
Number of nonfederal acres: 4,138.52; 
Total value of nonfederal interests acquired: $11,630,000; 
Equalization payment by nonfederal party: $20,200. 
Number of federal acres: 15,408.27; 
Total value of federal interests conveyed: $11,650,200; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 8/20/2004; 
Date exchange completed, if applicable: 2/22/2007; 
Third-party facilitator name, if any: Western Land Group, Inc. 
Average time to complete exchange from date ATI signed to date 
completed (in years): 2.51. 

State, field office, and other offices: Colorado: Royal Gorge; 
Exchange name: High Rollin' Ranch; 
Status: Completed; 
Number of nonfederal acres: 1,428.40; 
Total value of nonfederal interests acquired: $1,015,000; 
Equalization payment by nonfederal party: $85,900; 
Number of federal acres: 4,059.29; 
Total value of federal interests conveyed: $1,100,900; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 11/18/2002; 
Date exchange completed, if applicable: 12/20/2005; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 3.09. 

State, field office, and other offices: Colorado: Royal Gorge; 
Exchange name: Morley Cooper Mtn.; 
Status: Completed; 
Number of nonfederal acres: 2,242.43; 
Total value of nonfederal interests acquired: $1,345,000; 
Equalization payment by nonfederal party: $4,000; 
Number of federal acres: 1,904.09; 
Total value of federal interests conveyed: $1,349,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 5/18/2005; 
Date exchange completed, if applicable: 3/6/2007; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 1.80. 

State, field office, and other offices: Colorado: Royal Gorge; 
Exchange name: Lake County/City of Longmont; 
Status: Completed; 
Number of nonfederal acres: 120.00; 
Total value of nonfederal interests acquired: $300,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 50.04; 
Total value of federal interests conveyed: $300,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 8/7/2003; 
Date exchange completed, if applicable: 8/27/2007; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 4.05. 

State, field office, and other offices: Colorado: Royal Gorge; 
Exchange name: Great Sand Dunes NP/Baca NWR; 
Status: Pending; 
Number of nonfederal acres: 56,415.00; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 25,336.00; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 2/11/2005; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

State, field office, and other offices: Colorado: Royal Gorge; 
Exchange name: City of Blackhawk; 
Status: Pending; 
Number of nonfederal acres: 1,600.00; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 359.52; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 4/24/2006; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

State, field office, and other offices: Colorado: San Juan Public Lands 
Center; 
Exchange name: Sackman; 
Status: Completed; 
Number of nonfederal acres: 1,080.00; 
Total value of nonfederal interests acquired: $756,000; 
Equalization payment by nonfederal party: $82,500; 
Number of federal acres: 280.08; 
Total value of federal interests conveyed: $838,500; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 10/29/2004; 
Date exchange completed, if applicable: 10/29/2007;
Third-party facilitator name, if any: Mountain West Land Services; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 3.00. 

State, field office, and other offices: Colorado: San Juan Public Lands 
Center; 
Exchange name: Sunnyside Gold; 
Status: Pending; 
Number of nonfederal acres: 222.61; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 80.00; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 6/26/2007; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

State, field office, and other offices: Colorado: San Luis Valley 
Public Lands Center; 
Exchange name: Anderson Ditch/Del Norte; 
Status: Pending; 
Number of nonfederal acres: 0.00; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 2,151.15; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 5/31/2007; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

State, field office, and other offices: Colorado: Uncompahgre; 
Exchange name: Gunnison Gorge NCA (Selig); 
Status: Pending; 
Number of nonfederal acres: 5.27; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 2.21; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: [Empty]; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

State, field office, and other offices: Colorado: Uncompahgre; 
Exchange name: Three Creeks/Kelly; 
Status: Completed; 
Number of nonfederal acres: 280.32; 
Total value of nonfederal interests acquired: $308,000
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 80.00; 
Total value of federal interests conveyed: $264,000; 
Equalization payment by U.S.: $44,000; 
Date ATI signed[A]: 5/1/2002; 
Date exchange completed, if applicable: 12/12/2005; 
Third-party facilitator name, if any: Mountain West Land Services; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 3.62. 

State, field office, and other offices: Colorado total; 
Status: 8 completed, 7 pending, 3 terminated; 
Number of nonfederal acres: 72,709.38; 
Total value of nonfederal interests acquired: $5,514,000; 
Equalization payment by nonfederal party: $245,600.
Number of federal acres: 54,914.84; 
Total value of federal interests conveyed: $17,345,600; 
Equalization payment by U.S.: $44,000. 

State, field office, and other offices: Idaho: Birds of Prey National 
Conservation Area; 
Exchange name: Shenk; 
Status: Completed; 
Number of nonfederal acres: 40.00; 
Total value of nonfederal interests acquired: $$7,800; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 40.00; 
Total value of federal interests conveyed: $7,800; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 1/21/2004; 
Date exchange completed, if applicable: 5/2/2006; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 2.28. 

State, field office, and other offices: Idaho: Birds of Prey National 
Conservation Area; 
Exchange name: U.S. Ecology; 
Status: Completed; 
Number of nonfederal acres: 169.55; 
Total value of nonfederal interests acquired: $92,500; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 309.47
Total value of federal interests conveyed: $77,500; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 10/25/2004; 
Date exchange completed, if applicable: 3/8/2006; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 1.37. 

State, field office, and other offices: Idaho: Coeur d’Alene; 
Exchange name: Forest Capital Partners; 
Status: Completed; 
Number of nonfederal acres: 360.00; 
Total value of nonfederal interests acquired: $1,095,000; 
Equalization payment by nonfederal party: $65,000; 
Number of federal acres: 480.60; 
Total value of federal interests conveyed: $1,160,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 4/22/2003; 
Date exchange completed, if applicable: 2/13/2006; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 2.81. 

State, field office, and other offices: Idaho: Four Rivers; 
Exchange name: Blevins
Status: Completed
Number of nonfederal acres: 160.00
Total value of nonfederal interests acquired: $96,000
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 160.39; 
Total value of federal interests conveyed: $96,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 8/30/2005; 
Date exchange completed, if applicable: 7/5/2006; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 0.85. 

State, field office, and other offices: Idaho: Four Rivers; 
Exchange name: IDL/Rocky Canyon; 
Status: Terminated; 
Number of nonfederal acres: 730.32; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 341.54; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 12/8/2003; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

State, field office, and other offices: Idaho: Four Rivers; 
Exchange name: Nicholson; 
Status: Completed; 
Number of nonfederal acres: 2,135.13; 
Total value of nonfederal interests acquired: $534,000; 
Equalization payment by nonfederal party: $31,000; 
Number of federal acres: 1,445.60; 
Total value of federal interests conveyed: $565,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 7/2/2006; 
Date exchange completed, if applicable: 4/16/2008; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 1.79. 

State, field office, and other offices: Idaho: Four Rivers/Coeur 
d’Alene; 
Exchange name: Boise Foothills - Northern Idaho; 
Status: Pending; 
Number of nonfederal acres: 7,655.42; 
Total value of nonfederal interests acquired: $21,129,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 604.74; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 1,037,000; 
Date exchange completed, if applicable: 4/26/2005; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

State, field office, and other offices: Idaho: Four Rivers/Owyhee; 
Exchange name: IDT/Summercamp; 
Status: Completed; 
Number of nonfederal acres: 1.40; 
Total value of nonfederal interests acquired: $50,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 17.78; 
Total value of federal interests conveyed: $50,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 3/1/2004; 
Date exchange completed, if applicable: 5/2/2006; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 2.17. 

State, field office, and other offices: Idaho: Salmon; 
Exchange name: Birch Creek; 
Status: Completed; 
Number of nonfederal acres: 315.00; 
Total value of nonfederal interests acquired: $283,500; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 271.59; 
Total value of federal interests conveyed: $79,105
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 8/30/2003; 
Date exchange completed, if applicable: 3/25/2005; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 1.57. 

State, field office, and other offices: Idaho: Pocatello; 
Exchange name: Simplot/Blackrock; 
Status: Pending; 
Number of nonfederal acres: 666.92; 
Total value of nonfederal interests acquired: $535,000; 
Equalization payment by nonfederal party: $
Number of federal acres: 718.56; 
Total value of federal interests conveyed: $540,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 5/15/2006; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

State, field office, and other offices: Idaho: Total; 
Status: 7 completed, 2 pending, 1 terminated; 
Number of nonfederal acres: 12,233.74; 
Total value of nonfederal interests acquired: $$23,822,800; 
Equalization payment by nonfederal party: $$96,000; 
Number of federal acres: 4,390.27
Total value of federal interests conveyed: $$3,612,405; 
Equalization payment by U.S.: $0. 

State, field office, and other offices: Montana: Butte; 
Exchange name: Buckner; 
Status: Terminated; 
Number of nonfederal acres: 405.87; 
Total value of nonfederal interests acquired: $118,150; 
Equalization payment by nonfederal party: $
Number of federal acres: 404.13; 
Total value of federal interests conveyed: $121,250; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 3/8/2004; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

State, field office, and other offices: Montana: Butte; 
Exchange name: Hauser Lake-Helena Causeway; 
Status: Pending; 
Number of nonfederal acres: 34.00; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 20.00; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 5/15/2007; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: TCF; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

State, field office, and other offices: Montana: Lewistown; 
Exchange name: Surenough; 
Status: Completed; 
Number of nonfederal acres: 161.30; 
Total value of nonfederal interests acquired: $136,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 160.00; 
Total value of federal interests conveyed: $136,000
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 4/10/2002; 
Date exchange completed, if applicable: 12/16/2004
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 2.69. 

State, field office, and other offices: Montana: Malta; 
Exchange name: North Chinook; 
Status: Completed; 
Number of nonfederal acres: 2,380.00; 
Total value of nonfederal interests acquired: $466,592; 
Equalization payment by nonfederal party: $2,113; 
Number of federal acres: 2,553.24; 
Total value of federal interests conveyed: $468,705; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 5/31/2002; 
Date exchange completed, if applicable: 5/25/2006; 
Third-party facilitator name, if any: Inman (real); 
Average time to complete exchange from date ATI signed to date 
completed (in years): 3.98. 

State, field office, and other offices: Montana: Miles City; 
Exchange name: Pumpkin Creek; 
Status: Pending; 
Number of nonfederal acres: 12,229.15; 
Total value of nonfederal interests acquired: $2,568,122; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 14,325.83; 
Total value of federal interests conveyed: $2,589,700; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 3/28/2005; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: TCF; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

State, field office, and other offices: Montana: Total; 
Status: completed, 2 pending, 1 terminated; 
Number of nonfederal acres: 15,210.32; 
Total value of nonfederal interests acquired: $3,288,864; 
Equalization payment by nonfederal party: $2,113; 
Number of federal acres: 17,463.20; 
Total value of federal interests conveyed: $3,315,655; 
Equalization payment by U.S.: $0. 

State, field office, and other offices: New Mexico: Albuquerque; 
Exchange name: Acoma/State Mineral; 
Status: Completed; 
Number of nonfederal acres: 12,835.84; 
Total value of nonfederal interests acquired: $256,717; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 9,154.85; 
Total value of federal interests conveyed: $183,097
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 9/3/2003; 
Date exchange completed, if applicable: 6/26/2006; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 2.81. 

State, field office, and other offices: New Mexico: Albuquerque; 
Exchange name: Ojito-La Lena; 
Status: Pending; 
Number of nonfederal acres: 1,920.00; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 1,306.65; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 3/18/2008; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

State, field office, and other offices: New Mexico: Albuquerque; 
Exchange name: Santo Domingo II; 
Status: Completed; 
Number of nonfederal acres: 2,263.55; 
Total value of nonfederal interests acquired: $5,293,000; 
Equalization payment by nonfederal party: $326,000; 
Number of federal acres: 7,147.62; 
Total value of federal interests conveyed: $5,744,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 11/20/2006; 
Date exchange completed, if applicable: 1/11/2008; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 1.14. 

State, field office, and other offices: New Mexico: Carlsbad; 
Exchange name: Intrepid Mining (Mississippi Potash); 
Status: Pending; 
Number of nonfederal acres: 1,837.00; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 4,156.88; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 11/19/2004; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

State, field office, and other offices: New Mexico: Farmington; 
Exchange name: Bisti/Ah-shi-sle-pah; 
Status: Pending; 
Number of nonfederal acres: 9,955.07; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 10,608.89; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 3/18/2008; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

State, field office, and other offices: New Mexico: Las Cruces District 
Office; 
Exchange name: Organ Mtns.; 
Status: Terminated; 
Number of nonfederal acres: 297.21; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 346.53; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 6/21/2004; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

State, field office, and other offices: New Mexico: Las Cruces District 
Office; 
Exchange name: Santa Teresa; 
Status: Pending; 
Number of nonfederal acres: 13,298.00; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 7,701.83; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 3/18/2008; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

State, field office, and other offices: New Mexico: State Office; 
Exchange name: Adobe Land Exchange; 
Status: Completed; 
Number of nonfederal acres: 5,957.19; 
Total value of nonfederal interests acquired: $2,075,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 9,145.61; 
Total value of federal interests conveyed: $2,100,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 8/25/1998; 
Date exchange completed, if applicable: 3/23/2007; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 8.57. 

State, field office, and other offices: New Mexico: Total; 
Status: 3 completed, 5 pending, 1 terminated; 
Number of nonfederal acres: 48,363.86; 
Total value of nonfederal interests acquired: $7,624,717; 
Equalization payment by nonfederal party: $326,000; 
Number of federal acres: 49,568.86; 
Total value of federal interests conveyed: $8,027,097; 
Equalization payment by U.S.: $0. 

State, field office, and other offices: Nevada: Carson City; 
Exchange name: El Dorado; 
Status: Completed; 
Number of nonfederal acres: 873.72; 
Total value of nonfederal interests acquired: $312,764; 
Equalization payment by nonfederal party: $236; 
Number of federal acres: 162.06; 
Total value of federal interests conveyed: $313,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 8/1/1995; 
Date exchange completed, if applicable: 10/31/2006; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 11.25. 

State, field office, and other offices: Nevada: Elko; 
Exchange name: City of Elko; 
Status: Completed; 
Number of nonfederal acres: 9.89; 
Total value of nonfederal interests acquired: $423,000; 
Equalization payment by nonfederal party: $1,000; 
Number of federal acres: 37.50; 
Total value of federal interests conveyed: $424,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 12/2/1994; 
Date exchange completed, if applicable: 11/8/2005; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 10.93. 

State, field office, and other offices: Nevada: Elko; 
Exchange name: Indian Creek; 
Status: Completed; 
Number of nonfederal acres: 35,914.36; 
Total value of nonfederal interests acquired: $2,872,156; 
Equalization payment by nonfederal party: $415,986; 
Number of federal acres: 22,680.86; 
Total value of federal interests conveyed: $3,288,142; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 11/21/1994; 
Date exchange completed, if applicable: 1/5/2005; 
Third-party facilitator name, if any: John Eade; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 10.12. 

State, field office, and other offices: Nevada: Total; 
Status: 3 completed; 
Number of nonfederal acres: 36,797.97; 
Total value of nonfederal interests acquired: $3,607,920; 
Equalization payment by nonfederal party: $417,222; 
Number of federal acres: 22,880.42; 
Total value of federal interests conveyed: $4,025,142; 
Equalization payment by U.S.: $0. 

State, field office, and other offices: Oregon/Washington: Burns 
District; 
Exchange name: Rock Creek Ranch (Gary Miller); 
Status: Pending; 
Number of nonfederal acres: 233.25; 
Total value of nonfederal interests acquired: $98,000; 
Equalization payment by nonfederal party: $
Number of federal acres: 1,124.09; 
Total value of federal interests conveyed: $115,500; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 12/14/2007; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

State, field office, and other offices: Oregon/Washington: Coos Bay 
District; 
Exchange name: Coos Bay (North Spit); 
Status: Terminated; 
Number of nonfederal acres: 101.00; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 80.00; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 8/28/2002; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

State, field office, and other offices: Oregon/Washington: Medford 
District; 
Exchange name: Berry Rock (Boehm); 
Status: Pending; 
Number of nonfederal acres: 160.00; 
Total value of nonfederal interests acquired: $215,000; 
Equalization payment by nonfederal party: $
Number of federal acres: 90.00; 
Total value of federal interests conveyed: $277,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 7/29/2002; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

State, field office, and other offices: Oregon/Washington: Prineville 
District; 
Exchange name: Little Deschutes River (Youngs); 
Status: Completed; 
Number of nonfederal acres: 173.00; 
Total value of nonfederal interests acquired: $326,474; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 173.66; 
Total value of federal interests conveyed: $275,000; 
Equalization payment by U.S.: $51,474; 
Date ATI signed[A]: 10/9/2003; 
Date exchange completed, if applicable: 1/9/2006; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 2.25. 

State, field office, and other offices: Oregon/Washington: Spokane 
District; 
Exchange name: Columbia Basin Shrub Steppe (CBSS) Assembled Land 
Exchange; 
Status: Pending; 
Number of nonfederal acres: 45,053.23; 
Total value of nonfederal interests acquired: $5,732,150; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 4,805.39; 
Total value of federal interests conveyed: $6,030,940; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 6/13/2002; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: Clearwater Land Exchange; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

State, field office, and other offices: Oregon/Washington: Spokane 
District; 
Exchange name: CWALE (Central Washington Assembled Land Exchange II); 
Status: Pending; 
Number of nonfederal acres: 11,433.25; 
Total value of nonfederal interests acquired: $1,958,200; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 4,598.53; 
Total value of federal interests conveyed: $2,582,400; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 7/29/1999; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: Clearwater Land Exchange
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

State, field office, and other offices: Oregon/Washington: Spokane 
District; 
Exchange name: Hallauer; 
Status: Pending; 
Number of nonfederal acres: 472.00; 
Total value of nonfederal interests acquired: $472,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 368.00; 
Total value of federal interests conveyed: $495,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 7/11/2002; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

State, field office, and other offices: Oregon/Washington: Total; 
Status: 1 completed, 5 pending, 1 terminated; 
Number of nonfederal acres: 57,625.73; 
Total value of nonfederal interests acquired: $8,801,824; 
Equalization payment by nonfederal party: $0; 
Number of federal acres: 11,239.67; 
Total value of federal interests conveyed: $9,775,840
Equalization payment by U.S.: $51,474. 

State, field office, and other offices: Utah: Cedar City; 
Exchange name: Nichols; 
Status: Pending; 
Number of nonfederal acres: 1,667.22; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 1,458.55; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 3/30/2006; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

State, field office, and other offices: Utah: Cedar City; 
Exchange name: SITLA/Three Peaks; 
Status: Completed; 
Number of nonfederal acres: 950.69; 
Total value of nonfederal interests acquired: $881,000; 
Equalization payment by nonfederal party: $20,000; 
Number of federal acres: 330.20; 
Total value of federal interests conveyed: $901,000
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 2/6/2006; 
Date exchange completed, if applicable: 5/29/2008; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 2.31. 

State, field office, and other offices: Utah: Moab; 
Exchange name: Professor Valley Ranch; 
Status: Pending; 
Number of nonfederal acres: 32.10; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 17.86; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 4/4/2008; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

State, field office, and other offices: Utah: Salt Lake; 
Exchange name: Dees; 
Status: Completed; 
Number of nonfederal acres: 5,672.97; 
Total value of nonfederal interests acquired: $510,000; 
Equalization payment by nonfederal party: $6,750; 
Number of federal acres: 5,485.38; 
Total value of federal interests conveyed: $550,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 10/10/2000; 
Date exchange completed, if applicable: 2/7/2005; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 4.33. 

State, field office, and other offices: Utah: Salt Lake; 
Exchange name: Hogup; 
Status: Completed; 
Number of nonfederal acres: 6,360.84; 
Total value of nonfederal interests acquired: $381,841; 
Equalization payment by nonfederal party: $409; 
Number of federal acres: 5,204.31; 
Total value of federal interests conveyed: $382,250; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 11/15/2001; 
Date exchange completed, if applicable: 12/22/2004; 
Third-party facilitator name, if any: Western Resource Management; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 3.10. 

State, field office, and other offices: Utah: St. George; 
Exchange name: Milkvetch/Desert Tortoise; 
Status: Pending; 
Number of nonfederal acres: 389.98; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 398.88; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 9/24/2007; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

State, field office, and other offices: Utah: Total; 
Status: 3 completed, 3 pending; 
Number of nonfederal acres: 15,073.80; 
Total value of nonfederal interests acquired: $1,772,841; 
Equalization payment by nonfederal party: $27,159; 
Number of federal acres: 12,895.18; 
Total value of federal interests conveyed: $1,833,250
Equalization payment by U.S.: $0. 

State, field office, and other offices: Wyoming: Buffalo; 
Exchange name: Groeschel/Cow Creek; 
Status: Pending; 
Number of nonfederal acres: 683.70; 
Total value of nonfederal interests acquired: $855,000; 
Equalization payment by nonfederal party: $
Number of federal acres: 893.82; 
Total value of federal interests conveyed: $$927,610; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 6/24/2002; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

State, field office, and other offices: Wyoming: Rawlins; 
Exchange name: Talbott
Status: Completed
Number of nonfederal acres: 160.00
Total value of nonfederal interests acquired: $26,000
Equalization payment by nonfederal party: $
Number of federal acres: 160.00; 
Total value of federal interests conveyed: $23,000; 
Equalization payment by U.S.: $3,000; 
Date ATI signed[A]: 5/29/2002; 
Date exchange completed, if applicable: 9/30/2005; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 3.34. 

State, field office, and other offices: Wyoming: Worland; 
Exchange name: Great Western; 
Status: Completed; 
Number of nonfederal acres: 440.00; 
Total value of nonfederal interests acquired: $270,000; 
Equalization payment by nonfederal party: $10,000; 
Number of federal acres: 520.00; 
Total value of federal interests conveyed: $280,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 8/8/2003; 
Date exchange completed, if applicable: 9/21/2005; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 2.12. 

State, field office, and other offices: Wyoming: Wyoming State Office; 
Exchange name: P&M Coal[B]; 
Status: Completed; 
Number of nonfederal acres: 3,618.22; 
Total value of nonfederal interests acquired: $4,835,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 2,045.53; 
Total value of federal interests conveyed: $5,400,000
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 12/18/2000; 
Date exchange completed, if applicable: 2/3/2005; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 4.13. 

State, field office, and other offices: Wyoming: Total; 
Status: 3 completed,1 pending; 
Number of nonfederal acres: 4,901.92
Total value of nonfederal interests acquired: $5,986,000
Equalization payment by nonfederal party: $10,000
Number of federal acres: 3,619.35; 
Total value of federal interests conveyed: $6,630,610; 
Equalization payment by U.S.: $3,000. 

State, field office, and other offices: BLM total; 
Number of nonfederal acres: 432,210; 
Total value of nonfederal interests acquired: $89,391,982; 
Equalization payment by nonfederal party: $1,547,746; 
Number of federal acres: 224,926; 
Total value of federal interests conveyed: $85,276,856; 
Equalization payment by U.S.: $98,474. 

Source: GAO analysis of BLM data. 

[A] In some cases, amendments to ATI's are signed if, for example, 
there is a change in parcels. This column only shows the original date. 

[B] The P&M Coal exchange is a joint exchange with BLM and the Forest 
Service. Since BLM is the lead agency, this exchange is listed here. 
However, the acres and values benefiting the Forest Service are listed 
in appendix IV. 

[End of table] 

Appendix IV: Forest Service Completed, Pending, or Terminated Land 
Exchanges, October 1, 2004, through June 30, 2008: 

Region, state, and national forest: Region 1; Idaho; Idaho Panhandle; 
Exchange name: Grandmother
Status: Pending
Number of nonfederal acres: 2,394.38
Total value of nonfederal interests acquired: $5,800,000
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 1,325.38; 
Total value of federal interests conveyed: $5,800,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 5/25/2005; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 1; Idaho; Idaho Panhandle 
and Clearwater; 
Exchange name: Boise Foothills; 
Status: Pending; 
Number of nonfederal acres: 4,154.05; 
Total value of nonfederal interests acquired: $16,765,000; 
Equalization payment by nonfederal party: $315,000; 
Number of federal acres: 7,219.62; 
Total value of federal interests conveyed: $37,172,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 4/26/2005; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 1; Idaho; Nez Perce; 
Exchange name: Seminole Ranch; 
Status: Completed; 
Number of nonfederal acres: 41.92; 
Total value of nonfederal interests acquired: $1,100,000; 
Equalization payment by nonfederal party: $200,000; 
Number of federal acres: 180.99; 
Total value of federal interests conveyed: $1,300,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 4/25/2003; 
Date exchange completed, if applicable: 4/6/2005; 
Third-party facilitator name, if any: TCF; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 1.95. 

Region, state, and national forest: Region 1; Montana; Beaverhead-Deer-
lodge; 
Exchange name: Boatman; 
Status: Completed; 
Number of nonfederal acres: 111.76; 
Total value of nonfederal interests acquired: $134,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 113.63; 
Total value of federal interests conveyed: $112,000; 
Equalization payment by U.S.: $22,000; 
Date ATI signed[A]: 2/25/2003; 
Date exchange completed, if applicable: 11/24/2004; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 1.75. 

Region, state, and national forest: Region 1; Montana; Beaverhead-Deer-
lodge; 
Exchange name: Braxton; 
Status: Pending; 
Number of nonfederal acres: 89.92; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 320.00; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 5/22/2008; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 1; Montana; Beaverhead-Deer-
lodge; 
Exchange name: Lost Creek; 
Status: Completed; 
Number of nonfederal acres: 1,798.83; 
Total value of nonfederal interests acquired: $2,014,345; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 241.05; 
Total value of federal interests conveyed: $2,014,345; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: No ATI signed[B]; 
Date exchange completed, if applicable: 02/2/2007; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): No ATI signed[B]. 

Region, state, and national forest: Region 1; Montana; Beaverhead-Deer-
lodge; 
Exchange name: North Butte; 
Status: Pending; 
Number of nonfederal acres: 100.31; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 669.93; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 6/17/2004; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 1; Montana; Beaverhead-Deer-
lodge; 
Exchange name: Ward; 
Status: Completed; 
Number of nonfederal acres: 20.66; 
Total value of nonfederal interests acquired: $16,000; 
Equalization payment by nonfederal party: $600; 
Number of federal acres: 21.46; 
Total value of federal interests conveyed: $16,600; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 3/16/2006; 
Date exchange completed, if applicable: 4/11/2007; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 1.07. 

Region, state, and national forest: Region 1; Montana; Beaverhead-Deer-
lodge; 
Exchange name: Warms Springs; 
Status: Completed; 
Number of nonfederal acres: 282.37; 
Total value of nonfederal interests acquired: $847,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 251.96; 
Total value of federal interests conveyed: $831,000; 
Equalization payment by U.S.: $16,000; 
Date ATI signed[A]: 9/25/2001; 
Date exchange completed, if applicable: 6/30/2005; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 3.76. 

Region, state, and national forest: Region 1; Montana; Gallatin; 
Exchange name: Brackett Creek; 
Status: Completed; 
Number of nonfederal acres: 602.92; 
Total value of nonfederal interests acquired: $1,510,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 602.92; 
Total value of federal interests conveyed: $1,510,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 6/15/2000; 
Date exchange completed, if applicable: 12/20/2006; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 6.51; 

Region, state, and national forest: Region 1; Montana; Gallatin; 
Exchange name: Bennett Creek; 
Status: Completed; 
Number of nonfederal acres: 160.00; 
Total value of nonfederal interests acquired: $640,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 160.00; 
Total value of federal interests conveyed: $640,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 6/15/2000; 
Date exchange completed, if applicable: 2/26/2007; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 6.70. 

Region, state, and national forest: Region 1; Montana; Helena; 
Exchange name: Dry Range; 
Status: Completed; 
Number of nonfederal acres: 1,280.00; 
Total value of nonfederal interests acquired: $1,856,000; 
Equalization payment by nonfederal party: $76,000; 
Number of federal acres: 1,931.65; 
Total value of federal interests conveyed: $1,932,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 3/15/2005; 
Date exchange completed, if applicable: 5/18/2006; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 1.17. 

Region, state, and national forest: Region 1; Montana; Helena; 
Exchange name: Springhill; 
Status: Pending; 
Number of nonfederal acres: 116.84; 
Total value of nonfederal interests acquired: $158,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 1.44; 
Total value of federal interests conveyed: $157,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 9/12/2005; [Empty]; 
Date exchange completed, if applicable: 
Third-party facilitator name, if any: Prickly Pear Land Trust
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 1; Montana; Helena, 
Gallatin, Lolo, Kootenai; 
Exchange name: Alberton Gorge; 
Status: Completed; 
Number of nonfederal acres: 288.09; 
Total value of nonfederal interests acquired: $1,112,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 566.60; 
Total value of federal interests conveyed: $1,097,000; 
Equalization payment by U.S.: $15,000; 
Date ATI signed[A]: 1/24/2001; 
Date exchange completed, if applicable: 11/30/2004; 
Third-party facilitator name, if any: Five Valleys Land Trust
Average time to complete exchange from date ATI signed to date 
completed (in years): 3.85. 

Region, state, and national forest: Region 1; Montana; Helena, Lolo; 
Exchange name: Alberton Gorge; 
Status: Completed; 
Number of nonfederal acres: 95.88; 
Total value of nonfederal interests acquired: $165,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 15.40; 
Total value of federal interests conveyed: $165,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 1/24/2001; 
Date exchange completed, if applicable: 3/2/2007; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 6.10. 

Region, state, and national forest: Region 1; Montana; Kootenai; 
Exchange name: Rock Hill; 
Status: Completed; 
Number of nonfederal acres: 60.80; 
Total value of nonfederal interests acquired: $145,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 40.00; 
Total value of federal interests conveyed: $145,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 4/23/2004; 
Date exchange completed, if applicable: 6/14/2005; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 1.14. 

Region, state, and national forest: Region 1; Montana; Lewis & Clark; 
Exchange name: Taylor Hills; 
Status: Pending; 
Number of nonfederal acres: 151.52; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 158.53; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 3/21/2007; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 1; Montana; Lolo; 
Exchange name: DNRC/Lolo; 
Status: Pending; 
Number of nonfederal acres: 12,123.68; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 11,331.27; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 2/2/2005; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 1; Montana; Lolo; 
Exchange name: Greenough II; 
Status: Completed; 
Number of nonfederal acres: 10.00; 
Total value of nonfederal interests acquired: $26,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 20.00; 
Total value of federal interests conveyed: $26,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 7/13/2001; 
Date exchange completed, if applicable: 4/10/2006; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 4.74. 

Region, state, and national forest: Region 1 total; 
Status: 12 completed, 7 pending
Number of nonfederal acres: 23,883.93
Total value of nonfederal interests acquired: $32,288,345
Equalization payment by nonfederal party: $591,600
Number of federal acres: 25,171.83; 
Total value of federal interests conveyed: $52,917,945; 
Equalization payment by U.S.: $53,000. 

Region, state, and national forest: Region 2; Colorado; ARRO; 
Exchange name: NCWCD (Windy Gap); 
Status: Pending; 
Number of nonfederal acres: 14.30; 
Total value of nonfederal interests acquired: $93,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 12.44; 
Total value of federal interests conveyed: $93,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 2/9/1998; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 2; Colorado; GMUG
Exchange name: Cockrell, et al. (Taylor River); 
Status: Pending; 
Number of nonfederal acres: 6.68; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 6.68; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 3/4/2008; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: Western Land Group, Inc.
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 2; Colorado; GMUG; 
Exchange name: Faraway Ranch; 
Status: Completed; 
Number of nonfederal acres: 159.81; 
Total value of nonfederal interests acquired: $1,079,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 79.99; 
Total value of federal interests conveyed: $1,000,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 8/26/2003; 
Date exchange completed, if applicable: 3/4/2005; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 1.52. 

Region, state, and national forest: Region 2; Colorado; GMUG; 
Exchange name: Kempfe/Stump (Adventure Experiences); 
Status: Pending; 
Number of nonfederal acres: 160.00; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 377.24; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 10/23/2007; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: Western Land Group, Inc.
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 2; Colorado; GMUG; 
Exchange name: Kent/Lindsay; 
Status: Completed; 
Number of nonfederal acres: 59.58; 
Total value of nonfederal interests acquired: $34,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 1.06; 
Total value of federal interests conveyed: $34,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 11/5/2004; 
Date exchange completed, if applicable: 9/29/2006; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 1.90. 

Region, state, and national forest: Region 2; Colorado; GMUG; 
Exchange name: Telluride Airport; 
Status: Completed; 
Number of nonfederal acres: 64.59; 
Total value of nonfederal interests acquired: $1,199,500; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 37.61; 
Total value of federal interests conveyed: $1,000,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 7/6/2005; 
Date exchange completed, if applicable: 7/13/2007; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 2.02. 

Region, state, and national forest: Region 2; Colorado; Pawnee 
(Arapaho/Roosevelt); 
Exchange name: Diehl; 
Status: Completed; 
Number of nonfederal acres: 320.00; 
Total value of nonfederal interests acquired: $169,600; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 320.00; 
Total value of federal interests conveyed: $169,600; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 8/18/2005; 
Date exchange completed, if applicable: 6/28/2006; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 0.86. 

Region, state, and national forest: Region 2; Colorado; Pawnee 
(Arapaho/Roosevelt); 
Exchange name: Hahn; 
Status: Pending; 
Number of nonfederal acres: 320.00; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 320.00; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 11/20/2007; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 2; Colorado; PKSN
Exchange name: Denver Water Board (Round Hill); 
Status: Completed; 
Number of nonfederal acres: 684.35; 
Total value of nonfederal interests acquired: $903,600; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 478.32; 
Total value of federal interests conveyed: $957,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 12/12/2002; 
Date exchange completed, if applicable: 8/29/2007; 
Third-party facilitator name, if any: Shepard & Associates, Inc.
Average time to complete exchange from date ATI signed to date 
completed (in years): 4.71. 

Region, state, and national forest: Region 2; Colorado; Rio Grande; 
Exchange name: ATAH I/Catspaw/Navajo Headwaters (Banded Peak); 
Status: Pending; 
Number of nonfederal acres: 19,725.42; 
Total value of nonfederal interests acquired: $296,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 16,176.24; 
Total value of federal interests conveyed: $226,500; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 12/21/2005; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: Western Land Group, Inc. 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 2; Colorado; Rio Grande; 
Exchange name: Lisenby & Nearburg (Rio Oxbow); 
Status: Pending; 
Number of nonfederal acres: 814.91; 
Total value of nonfederal interests acquired: $1,598,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 469.79; 
Total value of federal interests conveyed: $1,493,500; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 2/2/2001; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: Western Land Group, Inc.
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 2; Colorado; Routt; 
Exchange name: Campbell (Miles); 
Status: Completed; 
Number of nonfederal acres: 83.44; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 90.14; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: ATI not signed[B]; 
Date exchange completed, if applicable: 10/20/2005; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): ATI not signed[B]. 

Region, state, and national forest: Region 2; Colorado; Routt; 
Exchange name: Needmore Ranch II, Ltd (Big Creek); 
Status: Completed; 
Number of nonfederal acres: 507.44; 
Total value of nonfederal interests acquired: $1,619,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 760.00; 
Total value of federal interests conveyed: $1,900,000
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 4/27/2004; 
Date exchange completed, if applicable: 12/30/2005; 
Third-party facilitator name, if any: Western Land Group, Inc.
Average time to complete exchange from date ATI signed to date 
completed (in years): 1.68. 

Region, state, and national forest: Region 2; Colorado; San Juan; 
Exchange name: Jung; 
Status: Completed; 
Number of nonfederal acres: 38.05; 
Total value of nonfederal interests acquired: $685,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 0.45; 
Total value of federal interests conveyed: $699,000
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 3/1/2004; 
Date exchange completed, if applicable: 1/30/2006; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 1.92. 

Region, state, and national forest: Region 2; Colorado; San Juan; 
Exchange name: Morgan (Fish Creek II); 
Status: Completed; 
Number of nonfederal acres: 169.02; 
Total value of nonfederal interests acquired: $161,600; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 10.84; 
Total value of federal interests conveyed: $132,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 1/11/2005; 
Date exchange completed, if applicable: 12/21/2006; 
Third-party facilitator name, if any: Western Land Group, Inc.
Average time to complete exchange from date ATI signed to date 
completed (in years): 1.94. 

Region, state, and national forest: Region 2; Colorado; San Juan; 
Exchange name: Tamarron Properties (Hermosa Park); 
Status: Pending; 
Number of nonfederal acres: 320.00; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 275.20; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 6/7/2007; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: Western Land Group, Inc.
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 2; Colorado; White River; 
Exchange name: Chihuahua, LLC & Town of Breckenridge (Snake River); 
Status: Pending; 
Number of nonfederal acres: 42.78; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 73.83; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 12/21/2007; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: Western Land Group, Inc.
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 2; Colorado; White River; 
Exchange name: Pitkin County; 
Status: Pending; 
Number of nonfederal acres: 216.48; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 54.68; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: No ATI signed[B]; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 2; Colorado; White River; 
Exchange name: Vail Associates (South Game Creek); 
Status: Completed; 
Number of nonfederal acres: 493.01; 
Total value of nonfederal interests acquired: $5,571,250; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 5.13; 
Total value of federal interests conveyed: $5,600,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 11/2/2004; 
Date exchange completed, if applicable: 4/26/2006; 
Third-party facilitator name, if any: Western Land Group, Inc.
Average time to complete exchange from date ATI signed to date 
completed (in years): 1.48. 

Region, state, and national forest: Region 2; Nebraska; Nebraska; 
Exchange name: State of Nebraska (Middle Loup); 
Status: Pending; 
Number of nonfederal acres: 295.73; 
Total value of nonfederal interests acquired: $$145,575; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 175.37; 
Total value of federal interests conveyed: $192,900; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 7/5/2006; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 2; South Dakota; Black 
Hills; 
Exchange name: Harlow/Hartog/Finley (Greyhound); 
Status: Pending; 
Number of nonfederal acres: 120.00; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 96.88; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 4/19/2006; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 2; South Dakota; Black 
Hills; 
Exchange name: The Nature Conservancy/Wood (Cattail); 
Status: Pending; 
Number of nonfederal acres: 557.60; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 784.44; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 2/2/2005; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 2; South Dakota; Black 
Hills; 
Exchange name: Home-stake, et al. (Grizzly); 
Status: Pending; 
Number of nonfederal acres: 227.13; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 478.86; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 11/29/2006; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: Western Land Group, Inc.
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 2; South Dakota; Buffalo Gap 
and Nebraska; 
Exchange name: Dakota Partnership (Indian Creek); 
Status: Pending; 
Number of nonfederal acres: 2,956.40; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 3,801.38; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 10/18/2004; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 2; South Dakota; Buffalo Gap 
and Nebraska; 
Exchange name: Edoff; 
Status: Completed; 
Number of nonfederal acres: 720.00; 
Total value of nonfederal interests acquired: $230,400; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 834.32; 
Total value of federal interests conveyed: $233,600; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 10/15/2002; 
Date exchange completed, if applicable: 6/13/2006; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 3.66. 

Region, state, and national forest: Region 2; South Dakota; Buffalo Gap 
and Nebraska; 
Exchange name: Sides Ranch (Cortney Creek); 
Status: Completed; 
Number of nonfederal acres: 640.00; 
Total value of nonfederal interests acquired: $192,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 658.79; 
Total value of federal interests conveyed: $214,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 7/1/2004; 
Date exchange completed, if applicable: 2/19/2008; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 3.64. 

Region, state, and national forest: Region 2; South Dakota; Buffalo Gap 
and Nebraska; 
Exchange name: Stroup (Missouri Breaks); 
Status: Completed; 
Number of nonfederal acres: 240.00; 
Total value of nonfederal interests acquired: $120,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 272.59; 
Total value of federal interests conveyed: $143,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 12/15/2003; 
Date exchange completed, if applicable: 1/14/2006; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 2.08. 

Region, state, and national forest: Region 2; Wyoming; Bighorn; 
Exchange name: City of Buffalo; 
Status: Completed; 
Number of nonfederal acres: 320.39; 
Total value of nonfederal interests acquired: $480,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 98.24; 
Total value of federal interests conveyed: $490,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 9/30/2003; 
Date exchange completed, if applicable: 8/16/2005; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 1.88. 

Region, state, and national forest: Region 2; Wyoming; Medicine Bow; 
Exchange name: Bragg; 
Status: Completed; 
Number of nonfederal acres: 39.93; 
Total value of nonfederal interests acquired: $52,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 20.00; 
Total value of federal interests conveyed: $46,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 6/26/1998; 
Date exchange completed, if applicable: 4/19/2005; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 6.81. 

Region, state, and national forest: Region 2; Wyoming; Medicine Bow; 
Exchange name: Dull Center (Dilts); 
Status: Completed; 
Number of nonfederal acres: 4,318.03; 
Total value of nonfederal interests acquired: $768,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 4,478.41; 
Total value of federal interests conveyed: $746,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 7/30/2001; 
Date exchange completed, if applicable: 5/10/2005; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 3.78. 

Region, state, and national forest: Region 2; Wyoming; Thunder Basin; 
Exchange name: Thomson (Cow Creek); 
Status: Pending; 
Number of nonfederal acres: 600.00; 
Total value of nonfederal interests acquired: $180,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 720.52; 
Total value of federal interests conveyed: $176,500; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 6/6/2002; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 2 total; 
Status: 17 completed, 15 pending; 
Number of nonfederal acres: 35,382.57; 
Total value of nonfederal interests acquired: $15,888,225; 
Equalization payment by nonfederal party: $0; 
Number of federal acres: 32,054.32; 
Total value of federal interests conveyed: $15,801,600; 
Equalization payment by U.S.: $0. 

Region, state, and national forest: Region 3; Arizona; Coconino; 
Exchange name: Bellemont; 
Status: Terminated; 
Number of nonfederal acres: 1,160.00; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 754.00; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 7/6/2001; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 3; Arizona; Coconino; 
Exchange name: Clear Creek; 
Status: Pending; 
Number of nonfederal acres: 820.72; 
Total value of nonfederal interests acquired: $6,465,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 503.35; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 6,465,000; 
Date exchange completed, if applicable: 11/18/2005; 
Third-party facilitator name, if any: Summit Resource, LLC; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 3; Arizona; Coconino; 
Exchange name: Mule Park; 
Status: Completed; 
Number of nonfederal acres: 270.87; 
Total value of nonfederal interests acquired: $1,888,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 197.21; 
Total value of federal interests conveyed: $1,888,000
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 1/3/2000; 
Date exchange completed, if applicable: 11/4/2004; 
Third-party facilitator name, if any: FLEX of Arizona; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 4.84. 

Region, state, and national forest: Region 3; Arizona; Prescott; 
Exchange name: Gray Wolf; 
Status: Completed; 
Number of nonfederal acres: 645.78; 
Total value of nonfederal interests acquired: $2,872,500; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 265.00; 
Total value of federal interests conveyed: $2,875,500; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 9/24/2001; 
Date exchange completed, if applicable: 6/19/2007; 
Third-party facilitator name, if any: FLEX of Arizona
Average time to complete exchange from date ATI signed to date 
completed (in years): 5.73. 

Region, state, and national forest: Region 3; Arizona; Prescott; 
Exchange name: Northern Arizona; 
Status: Pending; 
Number of nonfederal acres: 35,559.00; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 15,417.00; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 1/30/2007; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 3; Arizona; Sitgreaves; 
Exchange name: Black River; 
Status: Pending; 
Number of nonfederal acres: 400.00; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 337.00; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 10/15/2001; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: Summit Resources, LLC; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 3; Arizona; Sitgreaves; 
Exchange name: Camp Tatiyee; 
Status: Pending; 
Number of nonfederal acres: 1,719.45; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 344.06; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 10/1/2007; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: Page Land and Cattle; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 3; Arizona; Sitgreaves; 
Exchange name: Dry Lakes; 
Status: Completed; 
Number of nonfederal acres: 586.43; 
Total value of nonfederal interests acquired: $3,890,000; 
Equalization payment by nonfederal party: [Empty];
Number of federal acres: 176.90; 
Total value of federal interests conveyed: $3,890,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 4/26/2002; 
Date exchange completed, if applicable: 7/24/2006; 
Third-party facilitator name, if any: Genesis Real Estate and 
Development, Inc.
Average time to complete exchange from date ATI signed to date 
completed (in years): 4.24. 

Region, state, and national forest: Region 3; Arizona; Sitgreaves; 
Exchange name: Showlow Airport; 
Status: Completed; 
Number of nonfederal acres: 439.69; 
Total value of nonfederal interests acquired: $2,100,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 748.97; 
Total value of federal interests conveyed: $2,100,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 3/29/2002; 
Date exchange completed, if applicable: 11/3/2004; 
Third-party facilitator name, if any: FLEX of Arizona; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 2.6. 

Region, state, and national forest: Region 3; Arizona; Tonto; 
Exchange name: Ellison Creek; 
Status: Completed; 
Number of nonfederal acres: 520.97; 
Total value of nonfederal interests acquired: $2,872,972; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 142.34; 
Total value of federal interests conveyed: $2,872,972; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 2/9/1998; 
Date exchange completed, if applicable: 10/4/2005; 
Third-party facilitator name, if any: FLEX of Arizona; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 7.65. 

Region, state, and national forest: Region 3; Arizona; Tonto; 
Exchange name: Montezuma Castle; 
Status: Completed; 
Number of nonfederal acres: 364.88; 
Total value of nonfederal interests acquired: $3,857,500; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 222.33; 
Total value of federal interests conveyed: $3,857,500; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 5/23/2006; 
Date exchange completed, if applicable: 12/10/2007; 
Third-party facilitator name, if any: Western Land Group; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 1.55. 

Region, state, and national forest: Region 3; Arizona; Tonto; 
Exchange name: Tonto Apache; 
Status: Completed; 
Number of nonfederal acres: 422.74; 
Total value of nonfederal interests acquired: $5,425,000; 
Equalization payment by nonfederal party: [Empty];
Number of federal acres: 272.77; 
Total value of federal interests conveyed: $5,425,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 1/14/2000; 
Date exchange completed, if applicable: 3/10/2008; 
Third-party facilitator name, if any: The Sparks Law Firm; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 8.15. 

Region, state, and national forest: Region 3; New Mexico; Lincoln; 
Exchange name: Pine Springs; 
Status: Pending; 
Number of nonfederal acres: 80.00; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 80.00; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 1/14/2008; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 3; total; 
Status: 7 completed, 5 pending, 1 terminated; 
Number of nonfederal acres: 42,990.53; 
Total value of nonfederal interests acquired: $29,370,972; 
Equalization payment by nonfederal party: $0; 
Number of federal acres: 19,460.93; 
Total value of federal interests conveyed: $29,373,972; 
Equalization payment by U.S.: $0. 

Region, state, and national forest: Region 4; Idaho; Boise; 
Exchange name: Danskin; 
Status: Pending; 
Number of nonfederal acres: 1,057.64; 
Total value of nonfederal interests acquired: $550,000; 
Equalization payment by nonfederal party: $6,000; 
Number of federal acres: 1,281.84; 
Total value of federal interests conveyed: $$556,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 6/23/2006; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 4; Idaho; Challis; 
Exchange name: Sulphur Creek; 
Status: Completed; 
Number of nonfederal acres: 5.04; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 4.95; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 9/30/2004; 
Date exchange completed, if applicable: 1/26/2005; 
Third-party facilitator name, if any: 
Average time to complete exchange from date ATI signed to date 
completed (in years): 0.32. 

Region, state, and national forest: Region 4; Idaho; Payette; 
Exchange name: Brundage Ski Area; 
Status: Completed; 
Number of nonfederal acres: 349.49; 
Total value of nonfederal interests acquired: $3,080,000; 
Equalization payment by nonfederal party: $25,000; 
Number of federal acres: 388.35; 
Total value of federal interests conveyed: $3,105,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 1/19/2005; 
Date exchange completed, if applicable: 8/10/2006; 
Third-party facilitator name, if any: Brundage Mountain; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 1.56. 

Region, state, and national forest: Region 4; Idaho; Targhee; 
Exchange name: Yale Creek; 
Status: Terminated; 
Number of nonfederal acres: 21.00; 
Total value of nonfederal interests acquired: $220,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 22.80; 
Total value of federal interests conveyed: $228,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 7/25/2001; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 4; Utah; Uinta; 
Exchange name: OSPG (Timpanagos); 
Status: Completed; 
Number of nonfederal acres: 37.05; 
Total value of nonfederal interests acquired: $1,505,000; 
Equalization payment by nonfederal party: $70,000; 
Number of federal acres: 237.24; 
Total value of federal interests conveyed: $1,575,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 10/28/2004; 
Date exchange completed, if applicable: 4/21/2005; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 0.48. 

Region, state, and national forest: Region 4; Utah; Wasatch-Cache; 
Exchange name: 6200 South (FSFREA Authority); 
Status: Pending; 
Number of nonfederal acres: 3.20; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 4.26; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 5/13/2008; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 4; total; 
Status: 3 completed, 2 pending, 1 terminated; 
Number of nonfederal acres: 1,473.43; 
Total value of nonfederal interests acquired: $5,355,000; 
Equalization payment by nonfederal party: $101,000; 
Number of federal acres: 1,939.44; 
Total value of federal interests conveyed: $5,464,000; 
Equalization payment by U.S.: $0. 

Region, state, and national forest: Region 5; California; Cleveland; 
Exchange name: Lost Valley; 
Status: Completed; 
Number of nonfederal acres: 94.00; 
Total value of nonfederal interests acquired: $160,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 52.50; 
Total value of federal interests conveyed: $160,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 5/25/2004; 
Date exchange completed, if applicable: 8/29/2005; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 1.26. 

Region, state, and national forest: Region 5; California; Eldorado; 
Exchange name: [Empty]; 
Status: [Empty]; 
Number of nonfederal acres: [Empty]; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: [Empty]; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: [Empty]; 
Date exchange completed, if applicable: 8/2/2007
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 7.33. 

Region, state, and national forest: Region 5; California; Eldorado; 
Exchange name: Eldorado Irrigation District
Status: Pending; 
Number of nonfederal acres: 603.51; 
Total value of nonfederal interests acquired: [Empty];
Equalization payment by nonfederal party: [Empty];
Number of federal acres: 697.04; 
Total value of federal interests conveyed: [Empty];
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 11/18/2004; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 5; California; Eldorado; 
Exchange name: Hoover; 
Status: Completed; 
Number of nonfederal acres: 40.00; 
Total value of nonfederal interests acquired: $150,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 40.00; 
Total value of federal interests conveyed: $150,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 4/21/2005; 
Date exchange completed, if applicable: 11/3/2006; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 1.54. 

Region, state, and national forest: Region 5; California; Eldorado; 
Exchange name: Rubicon-Siller Tripartite; 
Status: Completed; 
Number of nonfederal acres: 146.40; 
Total value of nonfederal interests acquired: $300,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: [Empty]; 
Total value of federal interests conveyed: $300,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 4/6/2006; 
Date exchange completed, if applicable: 3/10/2008; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 1.93. 

Region, state, and national forest: Region 5; California; Inyo; 
Exchange name: Mammoth Community Facilities; 
Status: Completed; 
Number of nonfederal acres: 3,080.00; 
Total value of nonfederal interests acquired: $5,712,500; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 12.52; 
Total value of federal interests conveyed: $5,712,500; 
Equalization payment by U.S.: $12,500; 
Date ATI signed[A]: 1/11/2005; 
Date exchange completed, if applicable: 11/9/2007; 
Third-party facilitator name, if any: Western Land Group, Inc. 
Average time to complete exchange from date ATI signed to date 
completed (in years): 2.83. 

Region, state, and national forest: Region 5; California; Inyo, Tahoe, 
and Eldorado; 
Exchange name: Snow-creek; 
Status: Completed; 
Number of nonfederal acres: 1,950.85; 
Total value of nonfederal interests acquired: $1,569,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 94.00; 
Total value of federal interests conveyed: $1,400,000; 
Equalization payment by U.S.: $169,000; 
Date ATI signed[A]: 4/22/2002; 
Date exchange completed, if applicable: 2/9/2005; 
Third-party facilitator name, if any: Western Land Group, Inc.
Average time to complete exchange from date ATI signed to date 
completed (in years): 2.80. 

Region, state, and national forest: Region 5; California; Klamath; 
Exchange name: Bogus/Thompson Creek (Tripartite); 
Status: Completed; 
Number of nonfederal acres: 80.00; 
Total value of nonfederal interests acquired: $47,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: [Empty]; 
Total value of federal interests conveyed: $47,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 3/18/2005; 
Date exchange completed, if applicable: 9/12/2006; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 1.49. 

Region, state, and national forest: Region 5; California; Klamath; 
Exchange name: Moody (Tripartite); 
Status: Completed; 
Number of nonfederal acres: 80.00; 
Total value of nonfederal interests acquired: $165,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: [Empty]; 
Total value of federal interests conveyed: $165,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 8/19/2004; 
Date exchange completed, if applicable: 3/7/2005; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 0.55. 

Region, state, and national forest: Region 5; California; Klamath; 
Exchange name: Trans Wood (Tripartite); 
Status: Completed; 
Number of nonfederal acres: 40.00; 
Total value of nonfederal interests acquired: $155,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: [Empty]; 
Total value of federal interests conveyed: $155,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 8/19/2004; 
Date exchange completed, if applicable: 12/15/2004; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 0.32. 

Region, state, and national forest: Region 5; California; Klamath; 
Exchange name: WLT-Middle Boulder (Tripartite); 
Status: Completed; 
Number of nonfederal acres: 1,289.46; 
Total value of nonfederal interests acquired: $1,459,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: [Empty]; 
Total value of federal interests conveyed: $1,459,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 10/31/2003; 
Date exchange completed, if applicable: 11/23/2004; 
Third-party facilitator name, if any: The Wilderness Land Trust; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 1.07. 

Region, state, and national forest: Region 5; California; Lassen; 
Exchange name: Mill Creek LLC; 
Status: Completed; 
Number of nonfederal acres: 2,844.82; 
Total value of nonfederal interests acquired: $663,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 87.74; 
Total value of federal interests conveyed: $663,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 7/22/1997; 
Date exchange completed, if applicable: 11/18/2004; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 7.33. 

Region, state, and national forest: Region 5; California; Lassen; 
Exchange name: Spalding; 
Status: Completed; 
Number of nonfederal acres: 40.41; 
Total value of nonfederal interests acquired: $55,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 57.21; 
Total value of federal interests conveyed: $70,000; 
Equalization payment by U.S.: $15,000; 
Date ATI signed[A]: 2/11/2004; 
Date exchange completed, if applicable: 8/30/2005; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 1.55. 

Region, state, and national forest: Region 5; California; Los Padres
Exchange name: Serge; 
Status: Completed; 
Number of nonfederal acres: 1.25; 
Total value of nonfederal interests acquired: $410,000; 
Equalization payment by nonfederal party: $40,000; 
Number of federal acres: 0.80; 
Total value of federal interests conveyed: $450,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 4/9/2003; 
Date exchange completed, if applicable: 6/3/2006; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 3.15. 

Region, state, and national forest: Region 5; California; Mendocino; 
Exchange name: Greg D. Biagi (Faraway Ranch legislated conveyance); 
Status: Completed; 
Number of nonfederal acres: [Empty]; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 120.90; 
Total value of federal interests conveyed: $154,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: No ATI signed[B]; 
Date exchange completed, if applicable: 3/17/2005; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): No ATI signed[B]. 

Region, state, and national forest: Region 5; California; San 
Bernadino; 
Exchange name: Mill Creek; 
Status: Completed; 
Number of nonfederal acres: 101.00; 
Total value of nonfederal interests acquired: $304,000
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 24.86; 
Total value of federal interests conveyed: $502,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: No ATI signed[B]; 
Date exchange completed, if applicable: 12/8/2006; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): No ATI signed[B]. 

Region, state, and national forest: Region 5; California; San 
Bernadino; 
Exchange name: Upper Ranch; 
Status: Completed; 
Number of nonfederal acres: 320.00; 
Total value of nonfederal interests acquired: $364,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 58.94; 
Total value of federal interests conveyed: $364,000; 
Equalization payment by U.S.: $16,500; 
Date ATI signed[A]: 4/15/2005; 
Date exchange completed, if applicable: 7/29/2005; 
Third-party facilitator name, if any: American Land Conservancy; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 0.29. 

Region, state, and national forest: Region 5; California; San 
Bernadino; 
Exchange name: Wildwood; 
Status: Pending; 
Number of nonfederal acres: 2,250.00; 
Total value of nonfederal interests acquired: $1,584,600; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 783.28; 
Total value of federal interests conveyed: $1,584,600; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 9/24/2004; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: The Wildlands Conservancy; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 5; California; Sequoia; 
Exchange name: Coy Flats Recreation Residences Tract; 
Status: Pending; 
Number of nonfederal acres: 99.00; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 65.60; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 10/20/2007; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 5; California; Sequoia; 
Exchange name: Grouse Lake Phase V Tripartite; 
Status: Pending; 
Number of nonfederal acres: 40.99; 
Total value of nonfederal interests acquired: $625,700; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: [Empty]; 
Total value of federal interests conveyed: $625,700; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 8/23/2005; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 5; California; Shasta 
Trinity; 
Exchange name: Siddeley Bischoff Tripartite; 
Status: Completed; 
Number of nonfederal acres: 2.50; 
Total value of nonfederal interests acquired: $7,500; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: [Empty]; 
Total value of federal interests conveyed: $7,500; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 2/24/2005; 
Date exchange completed, if applicable: 6/26/2006; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 1.33. 

Region, state, and national forest: Region 5; California; Shasta 
Trinity; 
Exchange name: Siddeley Bischoff #2 Tripartite; 
Status: Completed; 
Number of nonfederal acres: 2.50; 
Total value of nonfederal interests acquired: $8,250; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: [Empty]; 
Total value of federal interests conveyed: $8,250; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 2/24/2005; 
Date exchange completed, if applicable: 7/19/2007; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 2.40. 

Region, state, and national forest: Region 5; California; Sierra; 
Exchange name: Sierra National Forest Land Exchange; 
Status: Pending; 
Number of nonfederal acres: 80.00; 
Total value of nonfederal interests acquired: $200,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 160.00; 
Total value of federal interests conveyed: $250,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: No ATI signed[B]; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 5; California; Tahoe; 
Exchange name: Barker Pass III; 
Status: Completed; 
Number of nonfederal acres: 318.22; 
Total value of nonfederal interests acquired: $750,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: [Empty]; 
Total value of federal interests conveyed: $750,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 7/28/2006; 
Date exchange completed, if applicable: 5/25/2007; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 0.82. 

Region, state, and national forest: Region 5; California; Tahoe; 
Exchange name: Milk Lake Tripartite; 
Status: Completed; 
Number of nonfederal acres: 318.42; 
Total value of nonfederal interests acquired: $950,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: [Empty]; 
Total value of federal interests conveyed: $950,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 3/27/2007; 
Date exchange completed, if applicable: 1/18/2008; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 0.81. 

Region, state, and national forest: Region 5; total; 
Status: 19 completed, 5 pending; 
Number of nonfederal acres: 13,823.33; 
Total value of nonfederal interests acquired: $15,639,550; 
Equalization payment by nonfederal party: $40,000; 
Number of federal acres: 2,255.39; 
Total value of federal interests conveyed: $15,927,550; 
Equalization payment by U.S.: $213,000. 

Region, state, and national forest: Region 6; Oregon; Deschutes; 
Exchange name: Hardie; 
Status: Pending; 
Number of nonfederal acres: 0.30; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 0.30; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 6/19/2008; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 6; Oregon; Malheur, 
Umatilla, Wallowa-Whitman; 
Exchange name: Blue Mountain (Clearwater Land Exchange-Oregon); 
Status: Terminated; 
Number of nonfederal acres: 32,000.00; 
Total value of nonfederal interests acquired: $15,717,500; 
Equalization payment by nonfederal party: $270,000; 
Number of federal acres: 18,000.00; 
Total value of federal interests conveyed: $15,987,500; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 10/14/1998; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: Clear-water Land Exchange-Oregon; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 6; Oregon; Wallowa-Whitman
Exchange name: Gabriel (Pallette Ranch); 
Status: Pending; 
Number of nonfederal acres: 9.11; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 6.03; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 12/20/2007; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 6; Washington; Colville; 
Exchange name: Blake Tripartite; 
Status: Completed; 
Number of nonfederal acres: 10.00; 
Total value of nonfederal interests acquired: $41,300; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: [Empty]; 
Total value of federal interests conveyed: $41,300; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 10/31/2005; 
Date exchange completed, if applicable: 9/26/2006; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 0.90. 

Region, state, and national forest: Region 6; Washington; Colville; 
Exchange name: Chad M. Thompson DDS Profit Sharing, Plan and Trust 
(Yellow House); 
Status: Completed; 
Number of nonfederal acres: 80.00; 
Total value of nonfederal interests acquired: $68,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 0.14; 
Total value of federal interests conveyed: $68,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 6/28/2004; 
Date exchange completed, if applicable: 1/6/2005; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 0.53. 

Region, state, and national forest: Region 6; Washington; Okanogan and 
Wenatchee; 
Exchange name: City of Cle Elum; 
Status: Completed; 
Number of nonfederal acres: 0.25; 
Total value of nonfederal interests acquired: $10,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 0.25; 
Total value of federal interests conveyed: $10,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 4/29/2005; 
Date exchange completed, if applicable: 11/23/2005; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 0.57. 

Region, state, and national forest: Region 6; Washington; Wenatchee; 
Exchange name: McMahon (Nahahum Canyon); 
Status: Pending; 
Number of nonfederal acres: 160.00; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 160.00; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 5/31/2007; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 6; total; 
Status: 3 completed, 3 pending, 1 terminated; 
Number of nonfederal acres: 32,259.66; 
Total value of nonfederal interests acquired: $15,836,800; 
Equalization payment by nonfederal party: $270,000; 
Number of federal acres: 18,166.72; 
Total value of federal interests conveyed: $16,106,800; 
Equalization payment by U.S.: $0. 

Region, state, and national forest: Region 8; Alabama; Bank-head; 
Exchange name: Kathryn H. and Jasper N. Bailey; 
Status: Completed; 
Number of nonfederal acres: 80.45; 
Total value of nonfederal interests acquired: $140,788.00; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 2.28; 
Total value of federal interests conveyed: $128,000.00; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 11/26/2002; 
Date exchange completed, if applicable: 1/27/2006; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 3.17. 

Region, state, and national forest: Region 8; Arkansas; Ouachita; 
Exchange name: Trust for Public Land; 
Status: Completed; 
Number of nonfederal acres: 2,137.43; 
Total value of nonfederal interests acquired: $1,282,458; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: [Empty]; 
Total value of federal interests conveyed: $1,282,458; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 7/22/2005; 
Date exchange completed, if applicable: 3/30/2006; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 0.69. 

Region, state, and national forest: Region 8; Arkansas; Ozark; 
Exchange name: I.W. Owen; 
Status: Completed; 
Number of nonfederal acres: 456.70; 
Total value of nonfederal interests acquired: $443,000; 
Equalization payment by nonfederal party: [Empty];
Number of federal acres: 171.08; 
Total value of federal interests conveyed: $432,140; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 3/19/2004; 
Date exchange completed, if applicable: 6/16/2005; 
Third-party facilitator name, if any: [Empty];
Average time to complete exchange from date ATI signed to date 
completed (in years): 1.24. 

Region, state, and national forest: Region 8; Arkansas; Ozark; 
Exchange name: Stephen & Van Hkill; 
Status: Completed; 
Number of nonfederal acres: 77.45; 
Total value of nonfederal interests acquired: $76,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: [Empty]; 
Total value of federal interests conveyed: $76,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 5/2/2005; 
Date exchange completed, if applicable: 4/17/2006; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 0.96. 

Region, state, and national forest: Region 8; Arkansas; Ozark; 
Exchange name: Rick & Paula Walker; 
Status: Completed; 
Number of nonfederal acres: 40.00; 
Total value of nonfederal interests acquired: $33,440; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 39.77; 
Total value of federal interests conveyed: $33,440; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 10/20/2005; 
Date exchange completed, if applicable: 3/30/2006; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 0.44. 

Region, state, and national forest: Region 8; Arkansas; Ozark; 
Exchange name: Lunie and David Smith; 
Status: Pending; 
Number of nonfederal acres: 636.00; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 795.00; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 4/30/2007; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 8; Arkansas; Ozark; 
Exchange name: G. Gerard and M. Huckabey; 
Status: Pending; 
Number of nonfederal acres: 400.00; 
Total value of nonfederal interests acquired: $48,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: [Empty]; 
Total value of federal interests conveyed: $48,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 8/24/2007; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 8; Arkansas; Ozark; 
Exchange name: City of Forth Smith; 
Status: Completed; 
Number of nonfederal acres: 572.00; 
Total value of nonfederal interests acquired: $882,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 556.27; 
Total value of federal interests conveyed: $721,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 4/15/2003; 
Date exchange completed, if applicable: 10/11/2008; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 3.49. 

Region, state, and national forest: Region 8; Arkansas; Ozark; 
Exchange name: Elliot Family Trust; 
Status: Pending; 
Number of nonfederal acres: 80.00; 
Total value of nonfederal interests acquired: $102,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 100.00; 
Total value of federal interests conveyed: $95,500; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 12/1/2006; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Ozark; 
Exchange name: Kenneth Kelly, Et Ux; 
Status: Pending; 
Number of nonfederal acres: 255.00; 
Total value of nonfederal interests acquired: $510,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: [Empty]; 
Total value of federal interests conveyed: $510,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 5/22/2007; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 8; Arkansas; 
Arkansas/Oklahoma Ozark, Ouachita; 
Exchange name: Ronnie and Judy Campbell; 
Status: Pending; 
Number of nonfederal acres: 263.43; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 210.25; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 3/23/2007; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 8; Florida; 
Exchange name: John H. Mcelveen; 
Status: Completed; 
Number of nonfederal acres: 10.39; 
Total value of nonfederal interests acquired: $$30,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: [Empty]; 
Total value of federal interests conveyed: $30,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 7/7/2004; 
Date exchange completed, if applicable: 3/23/2005; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 0.71. 

Region, state, and national forest: Region 8; Florida; 
Exchange name: State of Florida; 
Status: Completed; 
Number of nonfederal acres: 18,617.55; 
Total value of nonfederal interests acquired: $22,519,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 297,415.60; 
Total value of federal interests conveyed: $22,420,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 5/4/2001; 
Date exchange completed, if applicable: 4/5/2005; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 3.92. 

Region, state, and national forest: Region 8; Georgia; Chattahoochee-
Oconee; 
Exchange name: American Natural Res; 
Status: Completed; 
Number of nonfederal acres: 208.84; 
Total value of nonfederal interests acquired: $605,700; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 95.55; 
Total value of federal interests conveyed: $602,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 3/25/2005; 
Date exchange completed, if applicable: 8/4/2006; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 1.36. 

Region, state, and national forest: Region 8; Georgia; Chattahoochee-
Oconee; 
Exchange name: Silvertip Land; 
Status: Completed; 
Number of nonfederal acres: 130.00; 
Total value of nonfederal interests acquired: $430,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 116.10; 
Total value of federal interests conveyed: $420,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 12/20/2005; 
Date exchange completed, if applicable: 8/18/2006; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 0.66. 

Region, state, and national forest: Region 8; Georgia; Chattahoochee-
Oconee; 
Exchange name: Tom Phillips; 
Status: Pending; 
Number of nonfederal acres: 42.31; 
Total value of nonfederal interests acquired: $973,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 72.31; 
Total value of federal interests conveyed: $970,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 5/25/2007; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 8; Georgia; Chattahoochee-
Oconee; 
Exchange name: Georgia Fall Line Prop; 
Status: Terminated; 
Number of nonfederal acres: 77.00; 
Total value of nonfederal interests acquired: $331,000; 
Equalization payment by nonfederal party: [Empty]; [Empty]; 
Number of federal acres: [Empty]; 
Total value of federal interests conveyed: $331,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 1/5/2006; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 8; Georgia; Chattahoochee-
Oconee; 
Exchange name: The Conservation Fund; 
Status: Terminated; 
Number of nonfederal acres: 51.09; 
Total value of nonfederal interests acquired: $237,571; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: [Empty]; 
Total value of federal interests conveyed: $237,571; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 4/25/2007; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 8; Mississippi; Desoto; 
Exchange name: Tommy D. Rives; 
Status: Completed; 
Number of nonfederal acres: 313.18; 
Total value of nonfederal interests acquired: $379,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 95.55; 
Total value of federal interests conveyed: $602,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 3/25/2005; 
Date exchange completed, if applicable: 8/4/2006; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 1.36. 

Region, state, and national forest: Region 8; Mississippi; Desoto; 
Exchange name: DeSota Land & Timber (Double A Firewood, Inc); 
Status: Completed; 
Number of nonfederal acres: 1,795.00; 
Total value of nonfederal interests acquired: $3,050,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: [Empty]; 
Total value of federal interests conveyed: $3,050,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 1/27/2005; 
Date exchange completed, if applicable: 4/19/2006; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 1.22. 

Region, state, and national forest: Region 8; Mississippi; Desoto; 
Exchange name: Myers, Danny Roy & Marvin; 
Status: Completed; 
Number of nonfederal acres: 346.73; 
Total value of nonfederal interests acquired: $541,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 107.29; 
Total value of federal interests conveyed: $472,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 6/2/2005; 
Date exchange completed, if applicable: 4/25/2006; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 0.90. 

Region, state, and national forest: Region 8; North Carolina; North 
Carolina; 
Exchange name: Grace Tabernacle Baptist Church; 
Status: Pending; 
Number of nonfederal acres: 9.24; 
Total value of nonfederal interests acquired: $79,100; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 4.98; 
Total value of federal interests conveyed: $74,400; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 8/18/2006; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 8; North Carolina; 
Nantahala; 
Exchange name: The Trust for Public Land; 
Status: Completed; 
Number of nonfederal acres: 11.96; 
Total value of nonfederal interests acquired: $10,764; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 8.20; 
Total value of federal interests conveyed: $8,610.00; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 12/15/1992; 
Date exchange completed, if applicable: 8/22/2005; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 12.68. 

Region, state, and national forest: Region 8; Oklahoma; Ouachita; 
Exchange name: Charles, Reed and Dennis Jordan; 
Status: Completed; 
Number of nonfederal acres: 402.96; 
Total value of nonfederal interests acquired: $569,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 155.12; 
Total value of federal interests conveyed: $540,070; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 5/17/2004; 
Date exchange completed, if applicable: 8/15/2005; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 1.25. 

Region, state, and national forest: Region 8; Oklahoma; Ouachita; 
Exchange name: Forest Ridge Prop; 
Status: Completed; 
Number of nonfederal acres: 3,061.43; 
Total value of nonfederal interests acquired: $1,200,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 356.00; 
Total value of federal interests conveyed: $1,200,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 6/8/2006; 
Date exchange completed, if applicable: 2/20/2007; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 0.70. 

Region, state, and national forest: Region 8; Oklahoma; Ouachita; 
Exchange name: Doyel O’Neal; 
Status: Completed; 
Number of nonfederal acres: 41.00; 
Total value of nonfederal interests acquired: $37,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 32.00; 
Total value of federal interests conveyed: $35,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 3/28/2005; 
Date exchange completed, if applicable: 3/23/2006; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 0.99. 

Region, state, and national forest: Region 8; Oklahoma; Ouachita; 
Exchange name: Sain Boise Minerals; 
Status: Completed; 
Number of nonfederal acres: 40.00; 
Total value of nonfederal interests acquired: $36,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: [Empty]; 
Total value of federal interests conveyed: $36,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 8/23/2005; 
Date exchange completed, if applicable: 12/4/2006; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 1.28. 

Region, state, and national forest: Region 8; Oklahoma; Ouachita; 
Exchange name: Sain Properties LLC; 
Status: Completed; 
Number of nonfederal acres: 320.00; 
Total value of nonfederal interests acquired: $320,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 200.00; 
Total value of federal interests conveyed: $360,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 9/18/2006; 
Date exchange completed, if applicable: 8/28/2007; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 0.94. 

Region, state, and national forest: Region 8; South Carolina; Francis 
Marion; 
Exchange name: MS Recreational Properties; 
Status: Completed; 
Number of nonfederal acres: 432.29; 
Total value of nonfederal interests acquired: $648,435; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: [Empty]; 
Total value of federal interests conveyed: $648,435
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 11/21/2005; 
Date exchange completed, if applicable: 2/8/2007; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 1.22. 

Region, state, and national forest: Region 8; Tennessee; Cherokee; 
Exchange name: Citico Missionary Baptist Church; 
Status: Pending; 
Number of nonfederal acres: 1.60; 
Total value of nonfederal interests acquired: $17,600; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 8.42; 
Total value of federal interests conveyed: $20,600; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 9/26/2006; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 8; Tennessee; Cherokee; 
Exchange name: John & Geraldine Wynn; 
Status: Completed; 
Number of nonfederal acres: 13.18; 
Total value of nonfederal interests acquired: $21,094; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 4.21; 
Total value of federal interests conveyed: $21,095; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 2/11/2004; 
Date exchange completed, if applicable: 5/16/2005; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 1.26. 

Region, state, and national forest: Region 8; Virginia; George 
Washington/Jefferson; 
Exchange name: David and Betty Kiser; 
Status: Completed; 
Number of nonfederal acres: 13.05; 
Total value of nonfederal interests acquired: $$28,710; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 25.00; 
Total value of federal interests conveyed: $37,500; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 8/3/2006; 
Date exchange completed, if applicable: 3/24/2008; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 1.64. 

Region, state, and national forest: Region 8 total; 
Status: 22 completed, 8 pending, 2 terminated; 
Number of nonfederal acres: 30,937.26; 
Total value of nonfederal interests acquired: $35,581,660; 
Equalization payment by nonfederal party: $0; 
Number of federal acres: 300,676.08; 
Total value of federal interests conveyed: $35,273,819; 
Equalization payment by U.S.: $0. 

Region, state, and national forest: Region 9; Illinois; Shawnee; 
Exchange name: American Land Holdings of IL, LLC; 
Status: Pending; 
Number of nonfederal acres: 480.85; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 389.44; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 8/24/2007; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 9; Indiana; Hoosier; 
Exchange name: Braun, Michael K.
Status: Completed; 
Number of nonfederal acres: 431.84; 
Total value of nonfederal interests acquired: $$714,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 422.19; 
Total value of federal interests conveyed: $$742,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 4/20/2005; 
Date exchange completed, if applicable: 8/16/2006; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 1.32. 

Region, state, and national forest: Region 9; Indiana; Hoosier; 
Exchange name: Wright, Ronald E.
Status: Pending; 
Number of nonfederal acres: 180.00; 
Total value of nonfederal interests acquired: $396,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 130.32; 
Total value of federal interests conveyed: $326,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 1/4/2007; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 9; Michigan; Huron; 
Exchange name: Diocese of Gaylord; 
Status: Completed; 
Number of nonfederal acres: 280.00; 
Total value of nonfederal interests acquired: $203,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 422.19; 
Total value of federal interests conveyed: $742,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 4/20/2005; 
Date exchange completed, if applicable: 8/16/2006; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 1.32. 

Region, state, and national forest: Region 9; Michigan; Huron; 
Exchange name: Rose Trust; 
Status: Completed; 
Number of nonfederal acres: 37.00; 
Total value of nonfederal interests acquired: $60,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 21.92; 
Total value of federal interests conveyed: $48,000; 
Equalization payment by U.S.: $12,000; 
Date ATI signed[A]: 5/10/2004
Date exchange completed, if applicable: 11/1/2006; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 2.48. 

Region, state, and national forest: Region 9; Michigan; Manistee; 
Exchange name: Groves; 
Status: Pending; 
Number of nonfederal acres: 10.09; 
Total value of nonfederal interests acquired: $34,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: [Empty]; 
Total value of federal interests conveyed: $34,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 8/4/2006; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 9; Michigan; Manistee; 
Exchange name: Hastings; 
Status: Completed; 
Number of nonfederal acres: 40.00; 
Total value of nonfederal interests acquired: $92,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: [Empty]; 
Total value of federal interests conveyed: $92,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 5/20/2004; 
Date exchange completed, if applicable: 11/13/2004; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 0.48. 

Region, state, and national forest: Region 9; Michigan; Manistee; 
Exchange name: Hultman; 
Status: Terminated; 
Number of nonfederal acres: 75.10; 
Total value of nonfederal interests acquired: $210,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: [Empty]; 
Total value of federal interests conveyed: $210,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 9/28/2005; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 9; Michigan; Manistee; 
Exchange name: Nucci; 
Status: Pending; 
Number of nonfederal acres: 39.50; 
Total value of nonfederal interests acquired: $80,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: [Empty]; 
Total value of federal interests conveyed: $80,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 3/4/2008; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 9; Michigan; Manistee; 
Exchange name: Williams; 
Status: Pending; 
Number of nonfederal acres: 40.08; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: [Empty]; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 3/14/2008; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 9; Michigan; Manistee; 
Exchange name: Wrung; 
Status: Pending; 
Number of nonfederal acres: 19.73; 
Total value of nonfederal interests acquired: $53,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: [Empty]; 
Total value of federal interests conveyed: $53,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 1/11/2006; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 9; Michigan; Ottawa; 
Exchange name: Allen, Everett et. al.
Status: Completed; 
Number of nonfederal acres: 40.00; 
Total value of nonfederal interests acquired: $48,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 40.00; 
Total value of federal interests conveyed: $48,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 3/24/1998; 
Date exchange completed, if applicable: 2/25/2006; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 7.93. 

Region, state, and national forest: Region 9; Michigan; Ottawa; 
Exchange name: Carter, Scott; 
Status: Completed; 
Number of nonfederal acres: 160.00; 
Total value of nonfederal interests acquired: $160,000; 
Equalization payment by nonfederal party: $7,000; 
Number of federal acres: 119.23; 
Total value of federal interests conveyed: $167,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: [Empty]; 
Date exchange completed, if applicable: 3/23/2005; 
Third-party facilitator name, if any: 8/29/2005; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 0.44. 

Region, state, and national forest: Region 9; Michigan; Ottawa; 
Exchange name: McCosker, Carole; 
Status: Completed; 
Number of nonfederal acres: 37.40; 
Total value of nonfederal interests acquired: $69,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 40.00; 
Total value of federal interests conveyed: $68,000; 
Equalization payment by U.S.: $1,000; 
Date ATI signed[A]: 7/19/2006; 
Date exchange completed, if applicable: 8/9/2007; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 1.06. 

Region, state, and national forest: Region 9; Michigan; Hiawatha; 
Exchange name: Sturgis; 
Status: Completed; 
Number of nonfederal acres: 40.00; 
Total value of nonfederal interests acquired: $72,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 50.12; 
Total value of federal interests conveyed: $60,000; 
Equalization payment by U.S.: $12,000; 
Date ATI signed[A]: [Empty]; 
Date exchange completed, if applicable: 4/18/2006; 
Third-party facilitator name, if any: 6/4/2008; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 2.13. 

Region, state, and national forest: Region 9; Minnesotal Chippewa; 
Exchange name: Steward; 
Status: Pending; 
Number of nonfederal acres: 40.00; 
Total value of nonfederal interests acquired: $38,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 39.00; 
Total value of federal interests conveyed: $46,900; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 11/21/2005; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 9; Minnesota; Chippewa; 
Exchange name: Cass County; 
Status: Pending; 
Number of nonfederal acres: 160.00; 
Total value of nonfederal interests acquired: $200,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 160.00; 
Total value of federal interests conveyed: $224,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 2/7/2006; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 9; Minnesota; Superior; 
Exchange name: Correll, Randy; 
Status: Completed; 
Number of nonfederal acres: 760.00; 
Total value of nonfederal interests acquired: $360,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 720.00; 
Total value of federal interests conveyed: $360,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 6/25/2004; 
Date exchange completed, if applicable: 11/1/2006; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 2.35. 

Region, state, and national forest: Region 9; Minnesota; Superior; 
Exchange name: South Kawishiwi; 
Status: Pending; 
Number of nonfederal acres: 1,254.02; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 424.6; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 6/18/2008; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 9; Minnesota; Superior; 
Exchange name: Wright, Greg; 
Status: Completed; 
Number of nonfederal acres: 160.00; 
Total value of nonfederal interests acquired: $140,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 60.00; 
Total value of federal interests conveyed: $140,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 5/25/2004; 
Date exchange completed, if applicable: 6/20/2005; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 1.07. 

Region, state, and national forest: Region 9; Missouri; Mark Twain; 
Exchange name: Barton, Ray W. (Trust); 
Status: Completed; 
Number of nonfederal acres: 160.00; 
Total value of nonfederal interests acquired: $$118,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 160.00; 
Total value of federal interests conveyed: $132,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 3/21/2007; 
Date exchange completed, if applicable: 9/6/2007; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 0.46. 

Region, state, and national forest: Region 9; Missouri; Mark Twain; 
Exchange name: Buckeye Int’l; 
Status: Completed; 
Number of nonfederal acres: 160.00; 
Total value of nonfederal interests acquired: $125,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 160.00; 
Total value of federal interests conveyed: 132,000; 
Equalization payment by U.S.: 132,000; 
Date ATI signed[A]: 3/21/2007; 
Date exchange completed, if applicable: 9/6/2007; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 0.46. 

Region, state, and national forest: Region 9; Missouri; Mark Twain; 
Exchange name: Campbell, Kenneth (Trust)
Status: Completed
Number of nonfederal acres: 27.76
Total value of nonfederal interests acquired: $36,000
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 36,000; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 9/24/2007; 
Date exchange completed, if applicable: 3/18/2008; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 0.48. 

Region, state, and national forest: Region 9; Missouri; Mark Twain; 
Exchange name: Cook, Ron & Judy; 
Status: Completed; 
Number of nonfederal acres: 39.75; 
Total value of nonfederal interests acquired: $36,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 41.04; 
Total value of federal interests conveyed: $37,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 5/4/2006; 
Date exchange completed, if applicable: 9/8/2006; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 0.35. 

Region, state, and national forest: Region 9; Missouri; Mark Twain; 
Exchange name: Doe Run; 
Status: Completed; 
Number of nonfederal acres: 441.50; 
Total value of nonfederal interests acquired: $492,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 438.50; 
Total value of federal interests conveyed: $609,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 10/6/2004; 
Date exchange completed, if applicable: 2/8/2008; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 3.34. 

Region, state, and national forest: Region 9; Missouri; Mark Twain; 
Exchange name: Hudson; 
Status: Completed; 
Number of nonfederal acres: 80.00; 
Total value of nonfederal interests acquired: $76,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: [Empty]; 
Total value of federal interests conveyed: $76,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 6/27/2007; 
Date exchange completed, if applicable: 4/2/2008; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 0.77. 

Region, state, and national forest: Region 9; Missouri; Mark Twain; 
Exchange name: Evans; 
Status: Completed; 
Number of nonfederal acres: 40.00; 
Total value of nonfederal interests acquired: $64,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: [Empty]; 
Total value of federal interests conveyed: $64,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 9/24/2007; 
Date exchange completed, if applicable: 1/30/2008; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 0.35. 

Region, state, and national forest: Region 9; Missouri; Mark Twain; 
Exchange name: Keith; 
Status: Pending; 
Number of nonfederal acres: 40.00; 
Total value of nonfederal interests acquired: $44,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 33.01; 
Total value of federal interests conveyed: $46,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 4/11/2008; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 9; Missouri; Mark Twain; 
Exchange name: Kissee, Derene; 
Status: Completed; 
Number of nonfederal acres: 120.00; 
Total value of nonfederal interests acquired: $170,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: [Empty]; 
Total value of federal interests conveyed: $170,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 3/29/2007; 
Date exchange completed, if applicable: 9/25/2007; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 0.49. 

Region, state, and national forest: Region 9; Missouri; Mark Twain; 
Exchange name: Laves; 
Status: Pending; 
Number of nonfederal acres: 34.00; 
Total value of nonfederal interests acquired: $68,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: [Empty]; 
Total value of federal interests conveyed: $68,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 9/25/2007; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 9; Missouri; Mark Twain; 
Exchange name: Pattee; 
Status: Pending; 
Number of nonfederal acres: 80.00; 
Total value of nonfederal interests acquired: $84,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: [Empty]; 
Total value of federal interests conveyed: $84,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 9/4/2007; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 9; Missouri; Mark Twain; 
Exchange name: Peschel, Delton; 
Status: Completed; 
Number of nonfederal acres: 77.59; 
Total value of nonfederal interests acquired: $62,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: [Empty]; 
Total value of federal interests conveyed: $62,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 10/4/2005; 
Date exchange completed, if applicable: 4/23/2007; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 1.55. 

Region, state, and national forest: Region 9; Missouri; Mark Twain; 
Exchange name: Poe, Robert (Estate of); 
Status: Completed; 
Number of nonfederal acres: 40.00; 
Total value of nonfederal interests acquired: $30,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: [Empty]; 
Total value of federal interests conveyed: $30,000
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 2/14/2006; 
Date exchange completed, if applicable: 4/20/2006; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 0.18. 

Region, state, and national forest: Region 9; Missouri; Mark Twain; 
Exchange name: Reeves, David; 
Status: Completed; 
Number of nonfederal acres: 20.00; 
Total value of nonfederal interests acquired: $20,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: [Empty]; 
Total value of federal interests conveyed: $20,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 6/15/2006; 
Date exchange completed, if applicable: 10/10/2006; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 0.32. 

Region, state, and national forest: Region 9; Missouri; Mark Twain; 
Exchange name: Turnbough, Minnie (Trust); 
Status: Completed; 
Number of nonfederal acres: 160.00; 
Total value of nonfederal interests acquired: $122,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 160.00; 
Total value of federal interests conveyed: $128,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 7/7/2005; 
Date exchange completed, if applicable: 3/2/2007; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 1.65. 

Region, state, and national forest: Region 9; Missouri; Mark Twain; 
Exchange name: Watkins/Weill Estate; 
Status: Completed; 
Number of nonfederal acres: 20.00; 
Total value of nonfederal interests acquired: $18,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: [Empty]; 
Total value of federal interests conveyed: $18,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 4/20/2006; 
Date exchange completed, if applicable: 7/18/2007; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 1.24. 

Region, state, and national forest: Region 9; Ohio; Wayne; 
Exchange name: Jackson Twp. Trustees; 
Status: Completed; 
Number of nonfederal acres: 3.56; 
Total value of nonfederal interests acquired: $1,250; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 2.58; 
Total value of federal interests conveyed: $$1,250; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 7/3/2006; 
Date exchange completed, if applicable: 9/22/2006; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 0.22. 

Region, state, and national forest: Region 9; Ohio; Wayne; 
Exchange name: Washington County Commissioners; 
Status: Pending; 
Number of nonfederal acres: [Empty]; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 2.19; 
Total value of federal interests conveyed: $25,000; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 12/7/2007; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 9; New Hampshire; White 
Mountain National Forest; 
Exchange name: Mittersill-Sentinel Mtn.
Status: Pending; 
Number of nonfederal acres: 244.00; 
Total value of nonfederal interests acquired: [Empty]; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 100.00; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 1/2/2008; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty]. 

Region, state, and national forest: Region 9; Vermont; Green Mountain; 
Exchange name: Wickes, Ira & Ester; 
Status: Completed; 
Number of nonfederal acres: 5.70; 
Total value of nonfederal interests acquired: $7,400; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 2.21; 
Total value of federal interests conveyed: $7,400; 
Equalization payment by U.S.: [Empty]; 
Date ATI signed[A]: 12/1/2003; 
Date exchange completed, if applicable: 11/30/2005; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 2.00. 

Region, state, and national forest: Region 9 total; 
Status: 25 completed, 14 pending, 1 terminated; 
Number of nonfederal acres: 6,079.47; 
Total value of nonfederal interests acquired: $4,502,650; 
Equalization payment by nonfederal party: $7,000; 
Number of federal acres: 3,558.77; 
Total value of federal interests conveyed: $4,532,550; 
Equalization payment by U.S.: $70,000. 

Region, state, and national forest: Region 10; Alaska; Tongass; 
Exchange name: Heirs of Jimmie A. George, Sr.
Status: Completed; 
Number of nonfederal acres: 99.96; 
Total value of nonfederal interests acquired: $580,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 220.00; 
Total value of federal interests conveyed: $507,000; 
Equalization payment by U.S.: $73,000; 
Date ATI signed[A]: 11/20/2002; 
Date exchange completed, if applicable: 6/16/2005; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): 2.57. 

Region, state, and national forest: Region 10 total; 
Status: 1 completed
Number of nonfederal acres: 99.96
Total value of nonfederal interests acquired: $580,000
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: 220.00; 
Total value of federal interests conveyed: $507,000; 
Equalization payment by U.S.: $73,000. 

Region, state, and national forest: [Empty]; 
Exchange name: P&M Coal[C]; 
Status: [Empty]; 
Number of nonfederal acres: 2,447.88; 
Total value of nonfederal interests acquired: $609,000; 
Equalization payment by nonfederal party: [Empty]; 
Number of federal acres: [Empty]; 
Total value of federal interests conveyed: [Empty]; 
Equalization payment by U.S.: $44,000; 
Date ATI signed[A]: [Empty]; 
Date exchange completed, if applicable: [Empty]; 
Third-party facilitator name, if any: [Empty]; 
Average time to complete exchange from date ATI signed to date 
completed (in years): [Empty];. 

Region, state, and national forest: Forest Service total; 
Number of nonfederal acres: 189,378; 
Total value of nonfederal interests acquired: $155,652,202; 
Equalization payment by nonfederal party: $1,009,600; 
Number of federal acres: 403,503; 
Total value of federal interests conveyed: $175,905,236; 
Equalization payment by U.S.: $453,000. 

Source: GAO analysis of Forest Service data. 

[A] In some cases, amendments to ATI's are signed if, for example, 
there is a change in parcels. This column only shows the original date. 

[B] This exchange was legislated, and agency officials told us an ATI 
was not needed. 

[C] The P&M Coal exchange is a joint exchange with BLM and the Forest 
Service. Since BLM is the lead agency, this exchange is listed on the 
BLM exchange appendix (app. III). However, the acres and values 
benefiting the Forest Service are listed here. 

[End of table] 

[End of section] 

Appendix V: Comments from the Department of Agriculture: 

Note: GAO comments supplementing those in the report text appear at the 
end of this appendix. 

USDA United States Department of Agriculture: 
Forest Service: 
Washington Office: 
1400 Independence Avenue, SW: 
Washington, DC 20250: 

File Code: 5430: 

Date: May 22, 2009: 

Ms. Robin M. Nazzaro, Director: 
Natural Resources and Environment: 
U.S. Government Accountability Office: 
441 G. Street, N.W. 
Washington, DC 20548: 

Dear Ms. Nazzaro: 

We appreciate the opportunity to review and comment on the draft 
Government Accountability Office (GAO) report, GAO-09-611, "BLM and the 
Forest Service Have Improved Oversight of the Land Exchange Process, 
but Additional Actions Are Needed." The Agency generally agrees with 
the report and recommendations. Overall, the report accurately reflects 
the Improved Oversight of the Land Exchange Program. However, the 
Forest Service offers several substantive comments. 

Page 9, Line 16: GAO states, "In addition, in January 2009, a Region 4 
official told us that for all exchanges in that region, the reviewers 
were both preparing and reviewing the same exchanges." 

Region 4 comments that the region is organized in such a way so that 
there is an intentional separation between those individuals that 
prepare the documents to process an exchange and those individuals who 
have review and oversight responsibilities. While the Region does not 
know the context of the cited comment, it does not describe standard 
operating procedures. [See comment 1] 

Page 72, Recommendation 1, Action Item 2: GAO recommends that the 
Secretaries clarify the retention policy for key exchange documents and 
ensure that staff follows this policy. 

As noted in the report, the agency has already acknowledged this need, 
and the Forest Service is currently working to develop and implement 
revised policy. 

Page 73, Recommendation 4, Action Item 12: GAO recommends that the 
Secretaries "develop and issue national land tenure strategies for each 
agency and encourage the BLM state and Forest Service regional offices 
to develop their own plans to help guide land exchange decisions." 

The Forest Service agrees, in part, with this action item. As directed 
by Congress in the FY 2004 Appropriations Act, the U.S. Department of 
the Interior and U.S. Department of Agriculture published a National 
Land Acquisition Plan in February 2005. [See comment 2] This plan, as 
well as the Agency's Strategic Plan, provides sufficient overarching 
guidance to the Regions in the development of Regional and Forest 
plans. Current policy requires Regions and Forests to develop planning 
documents sufficient to guide land adjustment activities in the 
respective units. The Agency acknowledges that some of these plans are 
out of date or inadequate, and agrees with GAO that units must better 
document land adjustment planning. 

Page 73, Recommendation 4, Action Item 13: GAO recommends "track the 
agencies cost of processing individual land exchanges." 

The Forest Service agrees in part with this Action item. The Forest 
Service recognizes that tracking costs for individual exchanges may 
provide some benefit. However, the cost of developing and implementing 
an elaborate tracking system is considered to exceed the expected 
benefit. The Forest Service has rough costs for each individual land 
exchange, but the Agency is developing a beta-test for a database to 
centralize these rough costs. Placing these costs in a searchable 
format will help the Agency make decisions, track trends, and report 
out to stakeholders and Congress. [See comment 3] 

Page 73, Recommendation 4, Action Item 15: GAO recommends "ensure that 
staff have completed this training before working on land exchanges." 

The Forest Service agrees in part with the recommended action item. 
However, the Agency also recognizes that while senior staff may not 
have had the specific formal training which may become mandatory, they 
will likely be tasked to develop and/or instruct the training. In 
addition, the action item, as written, is too restrictive. The Agency 
needs the flexibility to allow inexperienced employees to work on 
exchanges, under the supervision of appropriately trained and 
experienced staff. The Agency agrees with the intent of the 
recommendations to clearly describe and implement necessary training 
and supervisory requirements. [See comment 4] 

The agency appreciates the professional quality work and 
recommendations of the GAO and is eager to continue to improve its 
oversight of the exchange process. If you have any additional questions 
or concerns please contact Sandy T. Coleman, Forest Service Assistant 
Director for GAO/OIG Audit Liaison Staff, at 703-605-4699. 

Sincerely, 

Signed by: 

Abigail R. Kimbell: 
Chief: 

The following are GAO's comments on the Department of Agriculture's 
Forest Service letter, dated May 22, 2009. 

GAO Comments: 

1. We revised the report to reflect the fact that regional staff, not 
necessarily reviewers, both process and review all exchanges in the 
region. We also added a sentence to acknowledge that there is an 
intentional separation between regional staff who process exchanges and 
those who review them. (Now on p. 35.) 

2. We continue to believe that the Forest Service needs a more detailed 
national plan to guide its land exchange activities. The 2005 National 
Land Acquisition Plan does not, in our opinion, offer a specific 
strategy on making exchange and other land transaction decisions on a 
national basis. We believe a specific strategy could help clarify 
organizational priorities and unify staff in the pursuit of shared 
goals. (Now on p. 66.) 

3. Although the Forest Service agrees in part with our recommendation 
on tracking costs and recognizes that tracking costs for individual 
exchanges may provide some benefit, it does not provide any support for 
its position that the effort to track the costs would exceed the 
expected benefit, such as a cost-benefit analysis. Furthermore, Forest 
Service officials had told us during our review that they would need 
only to establish a specific project code in their accounting system to 
track such costs, and therefore the Forest Service would not need to 
develop and implement a new system to track exchange costs. We commend 
the Forest Service's effort to develop a centralized database to 
collect the rough costs of exchanges it does collect, but we believe 
that better data on the cost of land exchanges will help the agencies 
decide whether a proposed land exchange is affordable and worthwhile. 
(Now on p. 66.) 

4. We slightly modified our recommendation by replacing "this" with 
"mandatory" to more closely align this recommendation with the prior 
one calling for the Forest Service to identify and make certain 
training mandatory. We believe, however, that by ensuring that realty 
staff working on exchanges have taken the proper training, the agency 
can help these staff develop and maintain the skills necessary to 
process exchanges. Moreover, our recommendation for the agencies to 
determine which elements of the current training courses to make 
mandatory and how often they should be taken provides the agencies with 
necessary flexibility. (Now on p. 66.) 

[End of section] 

Appendix VI: Comments from the Department of the Interior: 

Note: GAO comments supplementing those in the report text appear at the 
end of this appendix. 

United States Department of the Interior
Office Of The Secretary: 
Washington, DC 20240: 

May 28, 2009: 

Ms. Robin M. Nazzaro: 
Director, Natural Resources and Environment: 
Government Accountability Office: 
441 G Street, N.W. 
Washington, D.C. 20548-0001: 

Dear Ms. Nazzaro: 

Thank you for the opportunity to review and comment on the Government 
Accountability Office's draft report entitled "Federal Land Management: 
BLM and the Forest Service Have Improved Oversight of the Land Exchange 
Process, but Additional Actions Are Needed," (GAO-09-61 1). 

The Department of the Interior appreciates the diligent work of the 
team that prepared the draft report. We appreciate GAO's recognition 
that the Bureau of Land Management has taken actions to improve the 
land exchange program. However we do not concur with some aspects of 
the report and findings as explained below in the enclosure. 

We disagree with the characterization that BLM Manual 1220, Records and 
Information Management, does not clearly state the retention policy for 
land exchange documents. This characterization may be based on 
discussions with BLM personnel who are not records managers. The GAO 
was provided a copy of the Manual, which contains records retention 
information, and it was recommended they discuss the guidance with a 
BLM Records Manager. The draft report indicates the GAO contacted the 
Forest Service's National Records Manager, although there is not a 
similar reference for the BLM. [See comment 1] 

Furthermore, the draft report states that "the agency is not adhering 
to its own guidance for maintaining land exchange ledgers to track 
value imbalances in multiphase exchanges so that it can know how much 
is owed." The BLM believes that the case files, in whole, including the 
ledgers, decisions, appraisals, and other supporting information, 
document the values of lands conveyed and any resulting value 
imbalances. The BLM was not able to verify the $2.6 million figure 
stated for the cumulative value imbalance. However, the BLM will direct 
the State Offices to review all case files in which value imbalances 
exist to verify the accuracy of the records. [See comment 2] 

The enclosure provides some technical and specific comments on the 
draft report. We hope these comments will assist you in preparing the 
final report. If you have any questions, please contact Jeff Holdren, 
Acting Chief, Division of Lands, Realty and Cadastral Survey at (202) 
452-7779 or LaVanna Stevenson-Harris, BLM Audit Liaison Officer, at 
(202) 785-6580. 

Sincerely, 

Signed by: 

Ned Farquhar: 
Acting Assistant Secretary: 
Land and Minerals Management: 

Enclosure: 

[End of letter] 

Draft Government Accountability Office Report: "Federal Land 
Management: BLM and the Forest Service Have Improved Oversight of the 
Land Exchange Process, but Additional Actions Are Needed" (GAO-09-611): 

Technical Comments: 

Page 7, last paragraph, second sentence: "At BLM, a multiphase land 
exchange is the consolidation of multiple parcels of federal and/or 
nonfederal land for purposes of conducting one or more exchange 
transactions over a period of time." 

The definition of "multiphase land exchange" is really the definition 
of an "assembled land exchange" for the BLM (see 43 Code of Federal 
Regulations (CFR) 2200.0-5(f)). It is also believed the definition in 
the fifth sentence for Forest Service's exchanges also applies to an 
assembled exchange rather than a multiphase exchange. Neither agency's 
definition of an "assembled land exchange" is dependent on the number 
of transactions (phases). An assembled exchange under either agency's 
definition might be closed in a single transaction and may not be a 
multiphase land exchange. In addition, the Forest Service could process 
a multiphase land exchange with a single landowner, which would not be 
an assembled exchange under the Forest Service's definition. The simple 
definition of a multiphase exchange is one that involves more than one 
closing transaction. [See comment 3] 

Page 8, last paragraph, fourth sentence: "However, if the agencies 
determine that an exchange falls within a category of activities the 
agency has already determined has no significant environmental impact - 
called a categorical exclusion - then the agency generally need not 
prepare an environmental assessment or an environmental impact 
statement." 

This statement indicating that both agencies can utilize a categorical 
exclusion (CX) for land exchange is not correct. The BLM cannot utilize 
a CX for a land exchange, and this statement only applies to the Forest 
Service. [See comment 4] 

Page 16, second paragraph: In addition to the reasons cited in the 
draft report as reasons for delays in completion of land exchanges, the 
BLM also believes protests, appeals, and litigation should be 
identified. [See comment 5] 

Page 22, last paragraph, third sentence: "The ninth multiphase exchange 
in Idaho - Birch Creek - did not have a ledger". This statement is 
incorrect. 

The Birch Creek land exchange was completed in five phases and the 
ledger documents the transactions and value imbalances for the first 
four transactions. Upon completion of the fifth and final transaction, 
the case file documents that the values in Birch Creek land exchange 
were equalized and the ledger was closed. Although no specific piece of 
paper identified as a "ledger" was prepared for this fifth and final 
transaction of the Birch Creek exchange, the case file clearly 
documents that the values of the Federal and non-Federal lands that 
were exchanged were equalized in the final transaction for this 
multiphase exchange. Copies of the ledger for the first four 
transactions were previously provided to the GAO. In addition, the 
first four transactions of the Birch Creek land exchange were audited 
by Deloitte & Touche LLP in fiscal years 2001 and 2002 at the request 
of the BLM in response to a previous GAO audit. [See comment 6] 

Page 23, Table 4: In the column titled "Ledger Status," for the Birch 
Creek land exchange, "None" should be changed to "Closed" and footnote 
b should also be deleted. [See comment 7] 

Page 23, Table 4: Information on the multiphase exchanges requires the 
following corrections: 

The information for the Columbia Basin Shrub Steppe and Central 
Washington Assembled Land Exchange II includes all lands that may have 
been considered in these exchanges. Because both exchanges have been 
completed, the BLM believes the information should reflect the lands 
and values of the lands actually conveyed. The data for the Columbia 
Basin Shrub-Steppe Assembled Land Exchange should be corrected as 
follows: column one should be 17,701, column two should be $7,787,150, 
column three should be 4,529, and column four should be $7,794,740. The 
data for the Central Washington Assembled Land Exchange should be 
corrected as follows: column one should be 11,304, column two should be 
$2,372,200, column three should be 3,241, and column four should be 
$2,662,200. [See comment 8] 

Page 25, Table 5: For the State of California exchange, the column 
"Specifies lands to be exchanged" should be checked. Sec. 707 (a) of 
Public Law 103-433 specifies the lands to be exchanged, i.e., "Federal 
lands or interests therein on the list referred to in subsection (b)(2) 
for California State School lands or interests therein which are 
located within the boundaries of one or more of the wilderness areas or 
park system units designated by this Act." [See comment 9] 

Page 40, first paragraph, Page 45, and Page 46: The BLM disagrees with 
the characterization that the statutory authority for certain 
multiphase exchanges, including the Central Washington Assembled Land 
Exchange (C WALE) cited in the draft report, remains questionable. 
These land exchanges were processed under the land exchange authority 
of Section 206 of the Federal Land Policy and Management Act (FLPMA) 
and the accompanying land exchange regulations (43 CFR Part 2200). The 
regulations at 43 CFR 2201.1-1 clearly provide for multiphase 
exchanges, including the use of ledgers. [See comment 20] 

The draft report has not presented sufficient evidence to support the 
conclusion reached in issuing the findings and recommendations. The BLM 
believes the administrative records related to the exchanges clearly 
indicate that the BLM intended to conduct, and did conduct, land 
exchanges. Those administrative records show the BLM (1) entered into 
agreements to initiate a land exchange with a non-Federal party, (2) 
notified the public that the BLM was considering land exchange 
proposals, (3) identified the proposed action in the environmental 
analyses as proposed land exchanges, (4) identified in the applicable 
decision documents that the action was the exchange of lands that would 
serve the public interest, and (5) identified in conveyance documents 
that the conveyance of Federal and non-Federal lands was for and in 
consideration of other lands conveyed in the exchange pursuant to 
Section 206 of the FLPMA. 

Page 44, first bullet, eighth sentence: "According to California BLM 
State Office officials, the exchange has been on hold since 2003, when 
BLM headquarters review team and Interior's Office of the Solicitor 
raised concerns about the memorandum of agreement." 

In regard to the multiphase land exchange with the California State 
Lands Commission, the statement that the exchange "has been on hold" is 
misleading. Work on this exchange, independent of the Federal lands 
administered by the General Services Administration described in the 
draft report, has occurred. It would be more accurate to state that an 
exchange transaction to balance the ledger account has been delayed 
because the United States and the State have been unable to reach an 
agreement on the values of the State lands being proposed for exchange, 
and that efforts to reach an agreement on value are ongoing. The United 
States and the State have been working to resolve the appraisal issue, 
and to date, three appraisals have been completed: the first prior to 
2003, the second in 2006, and the third in 2008. None of the appraisals 
have been acceptable to both the United States and the State. Since 
January 2009, the United States and the State have been discussing 
potential ways to resolve this appraisal issue so that the transfer of 
the State lands to the United States and closure of the ledger may 
occur. [See comment 11] 

Page 45, second paragraph and Page 46, second paragraph: The BLM 
disagrees with the characterization that the CWALE is an unauthorized 
exchange as discussed in the 2000 GAO report and the statement that 
payment from a non-Federal party that equals the Federal land's value 
appears more likely to be a purchase price. This land exchange did not 
involve the sale or purchase of land and was processed under the land 
exchange authority of Section 206 of the Federal Land Policy and 
Management Act (FLPMA) and the accompanying land exchange regulations 
(43 CFR Part 2200). [See comment 12] 

The case file, including the ledger, for the CWALE exchange documents 
the value of lands conveyed in each transaction and the cumulative 
value imbalance as of the completion of each transaction. The CWALE did 
include transactions in which only non-Federal lands were conveyed or 
in which only Federal lands were conveyed. Use of such an arrangement 
is within the authority of Section 206 of the FLPMA, the accompanying 
regulations at 43 CFR Part 2200 and the BLM's policies and should not 
be construed as a sale or purchase of the subject lands. As identified 
in Chapter 11.G of the BLM's H-2200-1 Land Exchange Handbook, the first 
transaction in a multiphase exchange must include the conveyance of 
both Federal and nonFederal lands. In any subsequent transaction, it is 
permissible to convey only Federal or nonFederal lands. In such 
instances, as in this case, the change in the value imbalance 
identified on the ledger would necessarily reflect the full value of 
the land conveyed in the transaction. 

The deposits into a suspense account with the BLM's Spokane District 
upon completion of each transaction: (1) were directly related, and 
equivalent, to the value imbalance as of that transaction, and (2) were 
security and a financial assurance that the exchange would continue or 
that funds would be available for the equalization payment, if future 
transactions did not occur; the exchange would then be terminated. Upon 
completion of the final transaction in this exchange, there was a value 
imbalance of $290,200 in favor of the United States and the 
equalization amount equivalent to this imbalance was deposited into the 
Federal Land Disposal Account. 

Although the facts do not support the draft report's conclusion that 
the BLM was conducting land sales and purchases, rather than components 
of assembled land exchanges, the BLM recognizes the concerns raised by 
the draft report about processes and controls over multiphase land 
exchanges and ledger management. Commitments have been made to amend 
the guidance relating to ledger management and to elevate the level of 
oversight for all multiphase exchanges in which ledgers are proposed. 

Page 54, first paragraph: "According to BLM's 2003 workgroup review, 
BLM lacks a national, comprehensive policy or a statement of management 
direction that addresses land transactions, including land exchanges." 

While it is true that the BLM has not finalized the national land 
tenure strategy recommended by the 2003 BLM workgroup, other documents 
provide national management policy and direction. As an example, 
Chapter 1.G of the Land Exchange Handbook contains policy guidance (1) 
concerning the use and evaluation of a variety of land disposal and 
acquisition methods and (2) ensuring that land exchange proposals meet 
needs identified in, and are consistent with, land use plans. [See 
comment 13] 

Page 55, first bullet, second sentence "haphazard" should be changed to 
"decentralized and inconsistent". [See comment 14] 

Page 55, last paragraph: "According to BLM survey respondents in the 
remaining six states, two-states -Idaho and Oregon - had not started a 
strategy;..." 

The statement that the BLM Idaho has not started a statewide strategy 
is not completely correct. The BLM Idaho State Office does have a land 
exchange strategy with the State of Idaho concerning BLM/State land 
exchanges that was developed as a Memorandum of Understanding and was 
completed in April 1998. Prior to that date, the BLM Idaho had a 1976 
Working Agreement between the BLM and the State and an Idaho State/BLM 
Exchange Strategy which was developed in 1984 and updated in 1986 and 
1987. For land exchanges that do not involve the State, it is more 
accurate to say that Idaho also relies on land use plans to make 
decisions on land tenure actions in accordance with those plans and to 
support the multiple-use mission as outlined in those plans. [See 
comment 15] 

Page 66, last paragraph, third sentence: "in a new office" should be 
changed to "in a new agency." [See comment 16] 

Page 67, first paragraph: "realty specialists" should be changed to 
"managers." [See comment 17] 

The following are GAO's comments on the Department of the Interior's 
letter, dated May 28, 2009. 

GAO Comments: 

1. We continue to believe that the BLM policy for records retention is 
not clear for land exchange records. The four subsections on land 
exchanges do not always provide clear time frames for how long 
documents are to be retained. In response to Interior's comment, we 
revised the report to state that two senior lands and realty managers 
provided different interpretations of the policy. One stated that, in 
practice, completed exchange case files are retained for 3 years and 
then sent to a Federal Records Center. The second official stated that 
retention varies depending on the final disposition of a proposal, and 
he was unclear on certain aspects of the policy. While we did not 
contact a BLM records management official, we believe that our 
assessment of the policy, together with the differing interpretations 
of program officials, support our conclusion that the retention policy 
is unclear. (Now on p. 33.) 

2. BLM believes that the land exchange case files as a whole document 
the values of lands conveyed and any resulting imbalances. While this 
may be the case, BLM's land exchange handbook states, and we concur, 
that ledgers should completely and accurately reflect the balances due 
in order that values owed are easily identified. In its comment, BLM 
states that it is not currently able to verify the cumulative 
imbalance. We continue to believe that better management and oversight 
of BLM ledgers would help ensure that ledgers comply with regulations 
and policy and that imbalances reported are accurate. (Now on p. 38.) 

3. We revised the report text and accompanying footnote to clarify how 
the two agencies conduct multiphase exchanges and how these relate to 
the agencies' separate definitions of assembled land exchanges. (Now on 
p. 6.) 

4. We revised the report to clarify that categorical exclusions apply 
only to Forest Service. (Now on p. 7.) 

5. The statement in this paragraph is based on the frequency of 
responses to our survey, and the additional reason the comments cited 
was not among the most frequent. However, two respondents did cite 
protests, appeals, and litigation as reasons for delays in completion 
of land exchanges. We revised the text to reflect Interior's comment. 
(Now on p. 15.) 

6. As the Interior letter states, a ledger was not prepared for the 
fifth and final phase of the exchange and therefore could not be 
provided to us for review. Although Interior states that the case file 
clearly documents that the values of the federal and nonfederal lands 
exchanged were equalized in the final phase of this exchange, as stated 
earlier, this information should be maintained in the ledger. We 
revised the text to clarify that we are referring to the final phase of 
the Birch Creek exchange. (Now on p. 20.) 

7. As stated above, a ledger was not prepared for the final phase of 
the Birch Creek exchange. We retain the ledger status as "none" and 
clarified the footnote. (Now on p. 21.) 

8. We appreciate the updated figures for acreage and value in these two 
exchanges. However, the numbers we list are based on BLM data provided 
as of June 30, 2008. Since we do not have updated acreage and value 
data for the other 248 BLM and Forest Service land exchanges, we will 
not incorporate these updated numbers for only two exchanges in our 
report. (Now on p. 21.) 

9. The law addressing the State of California exchange calls for the 
exchange of certain state school lands for certain public lands under 
Interior's jurisdiction and any federal land which is or becomes 
surplus to the needs of the federal government, but does not identify 
specific parcels of land. All of the other legislated exchanges with 
this column checked had specific parcels identified for exchange. We 
revised the report to clarify this distinction. (Now on p. 23.) 

10. We reported that BLM officials believe that the Central Washington 
Assembled Land Exchange II (CWALE) multiphase exchange was conducted 
pursuant to the applicable statutory and regulatory requirements. As we 
stated in the report, we are pursuing the issue of whether certain 
multiphase exchanges, including CWALE, are authorized with Interior's 
Office of the Solicitor. (Now on p. 36 and 40-41.) 

11. We added this explanation to the report regarding the reasons the 
exchange has been pending since 2003. (Now on p. 39.) 

12. We reported that BLM officials believe that the CWALE multiphase 
exchange was conducted pursuant to the applicable statutory and 
regulatory requirements. As we stated in the report, we are pursuing 
the issue of whether certain multiphase exchanges, including CWALE, are 
authorized with Interior's Office of the Solicitor. Interior's comments 
state that funds BLM received during the CWALE multiphase exchange and 
placed into a deposit fund account (which the comments erroneously call 
a suspense account) were for financial assurance purposes. However, BLM 
was unable to produce any documentation that the monies BLM received 
were financial assurances when we requested such documentation. Most 
notably, BLM was unable to provide us with the completed form that the 
agency's handbook says should accompany financial assurances of cash or 
personal bonds. (Now on p. 40-41.) 

13. While the handbook provides guidance and land use plans provide 
management direction for a specific resource area, neither offers a 
national strategy on making exchange and other land transaction 
decisions. We continue to believe that developing a national land 
tenure strategy at BLM could help clarify organizational priorities and 
unify agency staff in the pursuit of shared goals for land exchanges. 
(Now on p. 48.) 

14. There is no change required because this is a direct quotation. 
(Now on p. 49.) 

15. We revised the text to reflect this comment. We continue to believe 
that developing a national land tenure strategy at BLM could help 
clarify organizational priorities and unify agency staff in the pursuit 
of shared goals for land exchanges. (Now on p. 49.) 

16. There is no change required. (Now on p. 60.) 

17. We revised the text as suggested. (Now on p. 60.) 

[End of section] 

Appendix VII: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Robin N. Nazzaro, (202) 512-3841 or nazzaror@gao.gov: 

Staff Acknowledgments: 

In addition to the contact named above, Andrea Wamstad Brown (Assistant 
Director), Eric Charles, Rich Johnson, Mark Keenan, Emily Larson, 
Sheila Rajabiun, John Scott, Rebecca Shea, Carol Herrnstadt Shulman, 
Jeanette Soares, John Warner, and Michelle Woods made key contributions 
to this report. 

[End of section] 

Footnotes: 

[1] Ledgers are records that track the value conveyed by each party in 
an exchange and the balance due to the federal government or the 
nonfederal party after each phase. 

[2] See appendix II for a list of GAO and other reports and audits on 
the BLM and Forest Service land exchange programs. 

[3] For the purposes of this report, "processed" land exchanges include 
those that were pending, completed, or terminated from October 1, 2004, 
through June 30, 2008. 

[4] Several of these state offices are responsible for managing lands 
in other states without a BLM state office. For example, the Oregon 
State Office is also responsible for BLM lands in the state of 
Washington, and the Eastern States Office is responsible for the BLM 
lands in the 31 states east of or bordering the Mississippi River. 

[5] Cadastral survey is the means by which private and public land is 
defined, divided, traced, and recorded. The term derives from the 
French cadastre, a register of the survey of lands, and is, in effect, 
the public record of the extent, value, and ownership of land for 
purposes of taxation. 

[6] Pub. L. No. 94-579 (1976) (codified as amended at 43 U.S.C. §§ 1701-
1782). 

[7] Examples of these authorities include the Weeks Act of 1911, ch. 
186, § 7, 36 Stat. 962 (1911) (codified as amended at 16 U.S.C. § 516), 
and the General Exchange Act of 1922, ch. 105, § 1, 42 Stat. 465 (1922) 
(codified as amended at 16 U.S.C. § 485), each of which authorize the 
Forest Service to exchange land for land or timber. 

[8] BLM regulations define "assembled land exchange" to mean the 
consolidation of multiple parcels of federal and/or nonfederal land for 
purposes of one or more exchange transactions over a period of time. 43 
C.F.R. § 2200.0-5(f). In this report, we refer to assembled exchanges 
that involve more than one closing transaction as "multiphase 
exchanges." Forest Service regulations define an assembled exchange as 
an exchange of federal land for a package of multiple ownership parcels 
of nonfederal land consolidated for purposes of one land exchange 
transaction. 36 C.F.R. § 254.2 

[9] The authority is provided by the Weeks Act of 1911, ch. 186, § 7, 
36 Stat. 962 (1911) (codified as amended at 16 U.S.C. § 516), and the 
General Exchange Act of 1922, ch. 105, § 1, 42 Stat. 465 (1922) 
(codified as amended at 16 U.S.C. § 485). 

[10] A nonbinding ATI is signed after the agency agrees with a 
nonfederal party to proceed with an exchange proposal. 

[11] Pub. L. No. 91-190 (1970), (codified as amended at 42 U.S.C. §§ 
4321-4370f). 

[12] Categorical exclusions for BLM land exchanges are not available 
because neither Department of the Interior regulations nor BLM guidance 
has listed land exchanges as activities eligible for a categorical 
exclusion. 

[13] Pub. L. No. 90-171 (1967), (codified as amended at 16.U.S.C. § 
484a). Under the Sisk Act, a state, county, municipal government, or 
public school authority with insufficient land to exchange can acquire 
not more than 80 acres of certain land administered by the Forest 
Service by paying the Forest Service an amount equal to a portion of or 
all of the federal land's value. These payments are deposited in a 
special fund, which, when appropriated, are available for the Forest 
Service to use to acquire certain lands in the same state. 

[14] These states are Arizona, California, Colorado, Idaho, Montana, 
New Mexico, Nevada, Oregon, Utah, Washington, and Wyoming. 

[15] Subsurface acres, also referred to as mineral acres, represent the 
resources located below the land surface, such as oil and gas deposits. 

[16] Although some exchanges were reported as being completed in about 
2 months, it is likely that they actually took longer. For example, 
according to a Forest Service official in Region 8, one exchange 
reported as being completed in about 2 months actually took about 2 
years. The official explained that this was because the regional office 
was working under a draft ATI with the nonfederal parties, and the ATI 
was not signed until the necessary surveys and analyses were completed-
-2 months before the date the title was transferred. 

[17] GAO, BLM and the Forest Service: Land Exchanges Need to Reflect 
Appropriate Value and Serve the Public Interest, [hyperlink, 
http://www.gao.gov/products/GAO/RCED-00-73] (Washington, D.C.: June 22, 
2000). 

[18] BLM considers each land exchange to have least two transactions 
per exchange--for example, the acquisition of land and the conveyance 
of land. An exchange can have more transactions if the exchange 
involves more than two parties or more than two parcels of land. 

[19] Of the remaining five survey respondents, one said that the number 
of exchanges processed since 2000 had greatly increased, two said that 
the number had somewhat increased, and two said that the number had 
stayed the same. 

[20] Pub. L. No. 106-248, tit. II (2000), codified at 43 U.S.C. §§ 2301-
2306. 

[21] GAO, Federal Land Management: Federal Land Transaction 
Facilitation Act Restrictions and Management Weaknesses Limit Future 
Sales and Acquisitions, [hyperlink, 
http://www.gao.gov/products/GAO-08-196] (Washington, D.C.: February 5, 
2008). 

[22] Pub. L. No. 109-54, tit. III (2005), codified at 16 U.S.C. § 580d 
Note. The act authorized the Secretary of Agriculture to convey certain 
administrative sites by sale, lease, exchange, a combination of sale 
and exchange, or other means the Secretary considered appropriate. 

[23] Inholdings are nonfederal lands within the boundaries of national 
parks, forests, wildlife refuges, and other designated areas. 

[24] [hyperlink, http://www.gao.gov/products/GAO/RCED-00-73]. 

[25] Muckleshoot Indian Tribe v. U.S. Forest Serv., 177 F.3d 800 (9th 
Cir. 1999). Specifically, the court found that the Forest Service did 
not consider the cumulative impacts of the exchange, in conjunction 
with past or reasonably likely future land transactions, and did not 
consider an adequate range of alternatives to the exchange, such as 
buying the nonfederal land. 

[26] The BLM headquarters review team is the National Land Exchange 
Team, and the Forest Service equivalent is the National Landownership 
Adjustment Team. In addition to its land exchange oversight 
responsibilities, the National Landownership Adjustment Team provides 
oversight for other land transactions, such as administrative site 
sales. For the purposes of this report, we will refer to both as the 
headquarters review teams. 

[27] The Solicitor reviews are in addition to the title reviews the 
Solicitor regularly provides for each exchange. 

[28] BLM's guidance states that the current review practice will 
continue until the Director authorizes individual state directors to 
resume selective responsibility for land exchange management oversight 
and quality control. 

[29] Forest Service policy memorandum to Regional Foresters, "National 
Landownership Adjustment Oversight," dated March 17, 2006 (file code 
5430/5570). 

[30] These reviews are referred to as reviews of regional landownership 
adjustment programs and, in addition to exchanges, include activities 
such as administrative site sales. 

[31] Of the 31 exchanges in our sample, we selected 27 because they 
represented 85 percent of the acres that the agencies have or plan to 
acquire and the remaining 4 because they were available for review 
during our site visits. 

[32] See BLM's Manual 1220 - Records And Information Management, GRS/ 
BLM Combined Records Schedules, Schedule 4 - Property Use and Disposal 
Records, app. 2, p. 4-1. 

[33] [hyperlink, http://www.gao.gov/products/GAO/RCED-00-73]. 

[34] If required, a financial assurance may be provided by the 
nonfederal party by posting a performance bond secured by cash or 
personal bond, negotiable U.S. Treasury bonds, notes or bills, or a 
bond of corporate surety. Ledger documentation must include a statement 
indicating if the imbalance is secured. 

[35] The Department of the Treasury has established budget clearing 
suspense accounts to temporarily hold unidentifiable collections that 
belong to agencies until they are classified to the proper receipt or 
expenditure account. Sound financial management practices entail 
entities having appropriate controls over the suspense accounts 
including maintaining adequate detailed records of the transactions in 
the account, promptly investigating the transactions, and promptly 
transferring them to the proper accounts. 

[36] Pub. L. No. 103-433 (1994). 

[37] The Financial Management Service of the Department of the Treasury 
establishes deposit fund accounts to record monies that do not belong 
to the federal government but are held by the federal government for 
various authorized purposes. See 1 TFM 2-1535. 

[38] Not all of BLM's multiphase exchanges involve such cash transfers. 
For example, in the Acoma exchange, BLM conveys federal land to and 
acquires nonfederal land from New Mexico without receiving or paying 
cash equal to the land's fair market value. Instead, BLM tracks the 
fair market value of land conveyed and acquired; any imbalance will be 
addressed with a cash equalization payment at the conclusion of the 
exchange. 

[39] Pub. L. No. 106-248, tit. II (2000), codified at 43 U.S.C. §§ 2301-
2306. 

[40] The number of acres included in this exchange varied over time. 
For example, the original 1998 ATI for the Blue Mountain exchange 
involved 19,000 federal and 29,000 nonfederal acres. The acreage 
numbers provided here are those reported by regional officials in 
response to our data call. 

[41] The disclosure guidelines became effective for BLM and the Forest 
Service in December 2005 and December 2006, respectively. We included 
only those facilitated exchanges with a signed ATI on or after the 
effective date of the agencies' disclosure guidelines. 

[42] GAO, Agencies' Strategic Plans Under GPRA: Key Questions to 
Facilitate Congressional Review, GAO/GGD-10.1.16 (Washington, D.C.: May 
1997). 

[43] The recommendation specifically called for BLM to establish 
national land tenure adjustment program management policies, goals, and 
objectives. BLM refers to this as a national land tenure strategy. 

[44] BLM's Executive Leadership Team consists of the BLM Director, 
deputy directors, assistant directors, center directors, and state 
directors. 

[45] This plan is referred to as the BLM Arizona Land Tenure Strategy. 

[46] This plan is referred to as the State Director Guidance and Policy 
for Land Exchange Processing Within the Montana/Dakotas. 

[47] This plan is referred to as the Land Tenure Management Strategy 
and Implementation Plan. 

[48] While the Idaho State Office reported it had not developed a 
statewide strategy document, in commenting on this report Interior 
stated that the office has a specific exchange strategy with the State 
of Idaho that is outlined in a 1998 memorandum of understanding. 

[49] H. Rep. No. 108-195, at 10 (2003). 

[50] Department of the Interior and Department of Agriculture, National 
Land Acquisition Plan (Washington, D.C., February 2005). 

[51] Each national forest is required to have a Land and Resource 
Management Plan, commonly referred to as forest plans. These plans 
provide broad guidance for forest activities, but generally do not 
provide detail on activities such as land exchanges. Landownership 
adjustment strategy plans supplement the forest plans by providing more 
detailed information on making land adjustment decisions, including 
land exchanges. 

[52] GAO, Federal Land Acquisition: Land Exchange Process Working, But 
Can Be Improved, [hyperlink, http://www.gao.gov/products/GAO/RCED-87-9] 
(Washington, D.C.: Feb. 5, 1987). 

[53] Interior provided formal comments on behalf of BLM. 

[54] SSFAS No. 4's five standards require government agencies to (1) 
accumulate and report the costs of activities on a regular basis for 
management information purposes; (2) establish responsibility segments, 
and measure and report the costs of each segment's outputs and 
calculate the unit cost of each output; (3) determine and report the 
full costs of government goods and services, including direct and 
indirect costs; (4) recognize the costs of goods and services provided 
by other federal entities; and (5) use and consistently follow costing 
methodologies or cost-finding techniques most appropriate to the 
segment's operating environment to accumulate and assign costs to 
outputs. 

[55] GAO, Managerial Cost Accounting Practices: Department of 
Agriculture and the Department of Housing and Urban Development, 
[hyperlink, http://www.gao.gov/products/GAO-06-1002R] (Washington, 
D.C.: Sept. 21, 2006); and Managerial Cost Accounting Practices at the 
Department of the Interior, [hyperlink, 
http://www.gao.gov/products/GAO-07-298R] (Washington, D.C.: May 24, 
2007). 

[56] BLM uses program element designations "FO" for acquisition and 
"FM" for disposal expenses. 

[57] SSFAS does not cover the costs paid by the nonfederal partners. 

[58] ATIs were not provided for 2 of the 31 exchanges in our sample. 

[59] As of March 2009, the Lands and Realty Academy has been replaced 
by the Beginning Lands and Realty course, according to BLM officials. 

[60] GAO, Human Capital: A Guide for Assessing Strategic Training and 
Development Efforts, [hyperlink, 
http://www.gao.gov/products/GAO-04-546G] (Washington, D.C.: March 
2004). 

[61] The academy is being replaced by a new course, Beginning Lands and 
Realty, to be conducted in one 9.5-week session, according to BLM 
officials. In addition, a number of topics from the previous Lands and 
Realty Academy, including land exchanges, will be moved to a new 
course, Intermediate Land Tenure, a 4-week course that will first be 
offered in fiscal year 2010. 

[62] This system is called DOI Learn and contains data on employee 
attendance back to 2000. 

[63] Department of the Interior, Office of Inspector General, Report of 
Investigation: San Rafael Land Exchange, Case Number OI-NM-02-0073-I 
(July 11, 2003). 

[64] The U.S. Office of Special Counsel is an independent federal 
investigative and prosecutorial agency whose primary mission is to 
safeguard the merit system by protecting federal employees and 
applicants from prohibited personnel practices, especially reprisal for 
whistle-blowing. 

[65] The Appraisal Foundation, Evaluation of the Appraisal Organization 
of the Department of Interior Bureau of Land Management (Washington, 
D.C., Oct. 9, 2002). 

[66] Interior’s other land management agencies are the Bureau of 
Reclamation, the Fish and Wildlife Service, and the National Park 
Service. 

[67] GAO, Interior’s Land Appraisal Services: Actions Needed to Improve 
Compliance with Appraisal Standards, Increase Efficiency, and Broaden 
Oversight, [hyperlink, http://www.gao.gov/products/GAO-06-1050] 
(Washington, D.C.: Sept. 28, 2006). 

[68] The Appraisal Foundation, Evaluation of the Appraisal Organization 
of the USDA Forest Service (Mar. 28, 2000). 

[69] The Forest Service does not have a Region 7. 

[70] In some cases, agency officials reported multiple dates for the 
ATI to account for the original and any amendments. To calculate time 
frames, we used the date of the original ATI. 

[71] GAO, Interior's Land Appraisal Services: Actions Needed to Improve 
Compliance with Appraisal Standards, Increase Efficiency, and Broaden 
Oversight, [hyperlink, http://www.gao.gov/products/GAO-06-1050] 
(Washington, D.C.: Sept. 28, 2006). 

[72] Because the agencies begin their efforts to comply with the 
National Environmental Policy Act only after the feasibility stage, it 
is only applicable to the decision reviews. 

[End of section] 

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