Wheeling and dealing

Note: a sidebar article, "A muckraker throws a well-aimed wrench," accompanies this feature story.

WESTON HILLS, Wyo. - Larry Gerard's blue work shirt whips in the wind as we stand among ponderosa pines on this ridge. To the west, the Bighorn Mountains glitter with spring snow. Just below, rancher Joe Collins is planting wheat.

The 1,100 acres of rugged land around us, home to mule deer, grouse and wild turkeys, are about to leave Collins' ownership and become public property managed by the Bureau of Land Management. In return, Collins will get 10 isolated parcels of BLM grazing land that had been locked inside the boundaries of his Flying U Ranch.

Gerard, a soft-spoken BLM wildlife biologist, is happy about the trade. The Weston Hills, he says, is one of only a few public areas near the coal-and-oil town of Gillette, 25 miles to the south, and the land trade will make the area more accessible. It's already a popular destination for hikers, hunters and off-road-vehicle enthusiasts, and the exchange will create a 10,000-acre block of public land that can be more easily managed by the agency.

Collins, whose family has lived on this ground since 1896, says that the patches of government land sprinkled around the Flying U were always a source of problems to him. Since he leased them for grazing, he had to tell BLM officials when he would be turning his cows onto and off the parcels each year. Collins says it's hard to make those decisions a year ahead of time. He, too, is happy about the exchange.

"It solves a lot of problems for them and for us," he says.

Land trades like this once went on quietly all the time in the West - negotiated in private and announced in the small type of legal sections of local newspapers. They made hardly a ripple in the surface of public awareness.

The Collins transaction could be considered land exchange at its best, with the federal government in charge, cleaning up two messes at once.

Each year, on the average, almost 500 square miles of the West change hands through the trading programs of the Forest Service and the BLM. Not all, it turns out, have been as desirable as the Collins trade.

In the past few years, the federal land exchange program has been rocked by scandals, prompting investigations and calls for reform. As the West's population swells and the competition for what is left of its open spaces sharpens, the public is becoming increasingly skeptical of these transactions. As former BLM Director Pat Shea put it last spring, land exchanges are "the most frightening part of my job."

Ripping off chucks of "The Great Barbecue"

The parcels of BLM land in the middle of the Collins ranch are crumbs that fell from the enormous table of the American West during what historian Vernon Parrington called "The Great Barbecue."

For much of the 19th century, and even a good part of the 20th, the young United States busily disposed of the huge territory it had gained through a series of cessions and purchases from other world powers - ignoring the rights of the native cultures already in residence.

Hoping to pay off its debts from the Revolutionary War and the War of 1812, the federal government began auctioning off large tracts of land. But by 1830, squatters had begun to balk at having to bid on lands they already occupied. A series of pre-emption and homestead acts kept the settlers more or less happy, as did special offers that rewarded war veterans. Meanwhile, the government was also granting large acreages to the states for education and other improvements. Railroads got a chuck of the barbecue from generous land grants - as a group, they ended up with nearly a tenth of the public domain.

Speculators, of course, were everywhere, making off with the profits at government auctions, perverting the homestead laws for their own benefit and amassing millions of acres for lucrative resale.

Historian Parrington commented, "More food, to be sure, was spoiled than was eaten, and the revelry was a bit unseemly; but it was a fine spree in the name of the people ..." Most government agencies of the time were dominated by lumber, stock-raising, and railroad interests. Western politicians, under the guise of protecting "the poor settlers," took up the causes of mining companies and loggers, and Congress as a whole seemed never the wiser.

"When the bill was sent in to the American people," Parrington concluded, "the farmers discovered that they had been put off with the giblets while the capitalists were consuming the turkey."

It was not until the last quarter of the 19th century that Americans began to have second thoughts about virtually giving away the continent. The creation of Yellowstone National Park in 1872 marked the first admission that some places might be better off remaining in public ownership. It was not until 1891, however, that Congress passed a law halting most public offerings of land and authorizing the president to create forest reserves. Even so, a minor amount of homesteading and land sales went on well into the 20th century.

On a map, the end result of the Great Barbecue is a messy spread indeed. States like Wyoming are littered with railroad holdings, state-land sections and leftovers that were either never homesteaded or reverted to federal ownership when their owners were starved out in the 1930s. The railroad lands, granted in alternate square-mile sections known as checkerboards, extend as much as 40 miles on either side of the tracks. It is hardly surprising that people have been trading these remains back and forth ever since.

But like the land giveaways, some of the early land exchanges were nothing more than bare-faced grabs for public resources. In 1899, when Mount Rainier National Park was established, the Northern Pacific Railroad held commercially worthless grant lands inside its boundaries. The railroad was allowed to swap them for hundreds of thousands of acres of prime timberlands elsewhere in the Northwest. Some observers of the time suspected the park was created for that very purpose.

An 1897 forest-management act also allowed landowners inside the boundaries of the new forest reserves (later the national forests) to trade their holdings for equal acreages outside. Intended to prevent settlers from becoming stranded without roads or services, this provision was seized upon by speculators and railroads, who traded their holdings (often after stripping them of trees) for better lands elsewhere. It was repealed in 1905.

The Forest Service continued to acquire land through exchanges under several early 20th century laws, and the 1934 Taylor Grazing Act later allowed ranchers to consolidate their holdings with the BLM through trades. Once again, speculators got into the act, making windfall profits by acquiring public lands at less than market value.

It was not until 1976 that the federal government made a definitive statement, in the Federal Land Policy and Management Act (FLPMA), that it was no longer in the business of dishing out the public domain. The act also declared land exchanges to be the preferred method for blocking federal lands into manageable units.

Congress had also set up a fund in 1965, so that federal agencies saddled with troublesome inholdings in national parks, forests, and other areas, could buy them outright. This Land and Water Conservation Fund, deriving most of its income from offshore drilling royalties, generated millions of dollars each year (HCN, 8/4/97). Finally, it seemed the mess left by the Great Barbecue was going to be cleaned up.

Reagan calls a halt

It didn't happen.

Western hostility to the federal government - the so-called Sagebrush Rebellion - combined with Ronald Reagan's arrival in the White House, put the kibosh on ambitious land purchases. Instead, Congress diverted the Fund's hundreds of millions to help balance the budget, while Forest Service and BLM funds for land purchases were slashed in half. In effect, this hog-tied the agencies: They were increasingly forced to use land exchanges to acquire sensitive properties. Between 1982 and 1985, for example, the number of BLM swaps doubled.

In fact, exchanges became so popular that in 1988 their proponents pushed through a bill to streamline the process. They complained that land exchanges took too long, that the Forest Service and BLM had vastly different processes for dealing with such transactions and that there was no way to settle differences over appraisal values.

The Federal Land Exchange Facilitation Act (FLEFA) was supposed to solve many of those problems, providing uniform rules for swaps, setting up arbitration to deal with appraisal disputes, and making it possible to delete or add acreages to reimburse exchange parties for their costs.

The regulations that implemented FLEFA mandated that both sides of an exchange had to be equal in market value, and also serve "the public interest." A description of that term, however, was a laundry list that included everything from protection of fish and wildlife habitat to the "fulfillment of public needs."

The regulations also allowed either party to an exchange to pay expenses or conduct studies that would normally be assumed by the other. In a case like the Collins exchange in Wyoming, this provision helped the trade by allowing BLM to take on most of the costs.

But where large corporations were involved, it created a loophole big enough to throw a conference table through. Not surprisingly, Kennecott Corp., the American Mining Congress, Barrick Goldstrike Mines, Weyerhaeuser, and Meridian Oil were all interested enough in swap regulations to submit comments on them.

In theory, FLEFA was supposed to provide more money for the agencies to process trades. The failure of Congress to fulfill this pledge put pressure on BLM and Forest Service staffers to let developers, miners and lumber companies take over appraisals, environmental studies and other expenses of conducting land swaps.

The result of understaffed federal land management agencies and little money to buy critical private lands was all too predictable.

In Las Vegas, a skewed process emerges in the desert

Here on the southern edge of the Las Vegas Valley, the desert is succumbing to a tide of pastel stucco. New subdivision signs are everywhere. Beeping earthmovers belch black fumes as nameless streets seem to appear overnight.

Hot, dry Nevada was never a popular selection on the Great Barbecue's menu; when the party was over, only 13 percent of this state had passed into private hands.

No one much cared about the shortage of private land until 1931, when casino gambling and big entertainment started a boom that continues to this day. By 1955, Las Vegas was the fastest growing city in the country. Yet this city of 1 million is hemmed in by federal conservation areas and military reservations. There was one key tract to the south that seemed ripe for the building, but it was in the hands of the BLM. It was time to negotiate a land swap.

The exchange that started the bulldozers rolling here was set in motion by Del Webb Corp., a developer famous for its Sun Cities, those master-planned retirement communities found across the American sunbelt. A transaction more unlike the Collins trade in Wyoming is difficult to imagine.

There, Joe Collins and Larry Gerard had known each other for years and worked out their swap one-on-one. Records of their trade fit into a single file. The Del Webb exchange, which involved 5,000 acres of BLM land, was engineered by a company whose income last year equaled BLM's entire national budget.

Del Webb could hire consultants that included a future secretary of the Interior. To get the land it needed to swap, the company went on a shopping spree across Nevada. It bought up a private parcel here and a ranch there in order to assemble enough property to trade for the plum it really wanted near Las Vegas. The records of these trades created a file four feet thick.

Del Webb had built one Las Vegas Sun City on land it bought from the Howard Hughes Corp. But when a deal for a second parcel fell through, it turned to the BLM, which manages a large tract to the south of Las Vegas.

One of the company's first representatives in its dealings with the BLM was Bruce Babbitt. After Babbitt became secretary of Interior in 1993, Del Webb hired Babbitt's friend and business associate, Donald Moon, a burly, affable public-land lawyer, as its trader.

In his dealings with BLM, Moon found an agency that was still reeling from the occasional violence of Nevada's early "Wise Use" movement, when federal officials were so hated that they needed bodyguards on their field trips. And although Moon insists, "Never once did I ever bring Babbitt into it," everyone at the BLM probably knew of their boss's former relationship with Del Webb.

Moon's most dogged opponent, however, came from the ranks of the BLM. Charles Hancock had been BLM's chief appraiser for Nevada for 16 years. He'd retired from that post in 1989, saying he was horrified by what was happening to land exchanges. During the 1990s, he became a watchdog of the agency, devoting himself to reforming the way the BLM traded land.

Hancock believes that the BLM's Las Vegas lands had become so valuable that they'd turned into a slush fund that encouraged all kinds of abuses.

He saw exchange proponents making windfall profits by playing "high ball, low ball' - undervaluing the Las Vegas tracts they wanted while overvaluing the private land they traded for them. He found that the environmental justification for the federal acquisitions was often shaky, and that federal agencies sometimes accepted properties that added nothing to the public estate.

In the next eight years, Hancock protested almost a dozen Nevada exchanges, made his case on a Tom Brokaw TV news program, and also described his concerns to the Department of Interior's inspector general.

Meanwhile, Del Webb was maneuvering for BLM land in Las Vegas. The only problem: The company owned nothing of value to trade.

Gary Ryan, who was in charge of the Las Vegas district BLM office at the time, says Del Webb's lack of anything to offer stood the exchange on its head.

"The offered land should drive the process," he says. "What are the American people getting out of this? That should be the focus."

The company ended up scouring Nevada, coming up with some warm springs that were home to the Moapa dace, an endangered fish, some desert wetlands in the Stillwater National Wildlife Refuge that were a crucial link for migrating waterfowl, and several parcels in the Lake Tahoe area. (These properties did not go to the BLM, but to the U.S. Fish and Wildlife Service and the U.S. Forest Service.)

In the end, the Del Webb trade involved so many properties coming in at different times that it had to be divided into multiple phases, each published separately in the local papers. It was hard for outsiders to tell what was going on.

The Del Webb appraisals were also a problem. In the old days, Hancock says, "I had a whole appraisal staff. We did our own appraisals." All that changed when the agency was downsized during the Reagan-Watt era in the 1980s. It was then, he says, that "everything started going downhill."

By the time Del Webb came along, Nevada's BLM was relying on a list of approved outside appraisers to evaluate land trades. Del Webb's Moon protested that these appraisers were not used to working with urban properties, and after he complained to the BLM's Washington, D.C., office, Del Webb was allowed to hire its own appraiser, a man Moon says was far better qualified.

Hancock says letting proponents like Del Webb hire appraisers is like putting a fox in charge of the chicken coop.

"The loyalty of any appraiser is to the person who is paying him," he says.

Gerald Stoebig, who by then held Hancock's position as the Bureau's chief appraiser in Nevada, still expected to review the company's figures. But at a meeting early in 1996, he was dismayed to learn that Del Webb's appraiser was evaluating the parcel the corporation wanted, using what is known as the development approach.

This method estimates a developer's sales proceeds minus his costs to reach a value for the land. According to the Department of Interior's Inspector General, it essentially "reflects the highest price a proponent of a land exchange could afford to pay for the lands and still earn its desired profit."

Federal land exchange regulations do not forbid such a method outright, but it is allowed only if there is no reliable market data from other sales.

Del Webb's appraiser argued that the development approach was necessary because Hughes Corp. held a virtual monopoly on land, creating unnaturally high real estate prices.

Stoebig did not agree. He reminded the Del Webb people that federal guidelines say a market approach should be used; they, in turn, told him he was wrong.

"Quite frankly," he says, "I got the impression they had already done the appraisal." The meeting ended in a stalemate.

Stoebig adds, "I at no time said that the (land) values had been underestimated. That would have been unethical."

Moon maintains that Stoebig "sat in that room and basically offered his view of what the property was worth," and once again he complained to the Bureau's Washington, D.C., office. A few weeks later, Stoebig was taken off the case. He later quit the BLM, he says, in disgust.

In the end, Del Webb was allowed to have its appraisal reviewed by a firm it had suggested. This is permissible under federal guidelines - in transactions where time is of the essence. In this case it was hard to see where the urgency was; the company still had not come up with nearly enough property to offer the government in return for the Las Vegas tract it wanted.

Just the beginning of scandal

No one outside the meeting rooms where the Del Webb trade was being hammered out knew what was going on in there. But by the summer of 1996, anyone who read the Las Vegas papers knew Nevada land exchanges were troubled. The Department of Interior inspector general's office, alerted by Hancock and some news reports, had audited the program, and its report contained some embarrassing disclosures.

Inspector general auditors estimated that the government had lost $12 million in four Nevada trades they examined. The Nevada state BLM office had, they said, acquired $2.7 million worth of land that "had no discernible mission-related purpose' - as well as a defunct bowling alley.

They found that land-exchange proponents were speculating - making large profits by breaking up parcels they had gotten from the government and selling them in smaller chunks. One proponent who got 70 acres at an exchange value of $763,000 from BLM sold the tract the same day for $4.6 million.

In fact, the inspector general substantiated just about every allegation Hancock had made.

Still, the Del Webb exchange rolled on. In November 1996, the first phase of the transaction was approved by BLM. The value of the whole Las Vegas parcel had now been set at $43 million. At this point in the federal exchange process, the public is notified of the decision and given 45 days to appeal it.

Since protests require information, the BLM generally lets the public see environmental and other studies that are not confidential at this point. In this case, the appraisal was still in bureaucratic limbo. Even though it had been reviewed, someone in the Bureau had to approve it. But the unorthodox way it had been handled made it a hot potato and no one wanted responsibility.

Then a bombshell hit. Just before the public comment period ended, the BLM learned that the inspector general was going to audit the Del Webb exchange.

In the scramble that followed, the Bureau decided to commission a new appraisal and give the public a second chance to comment - this time with some figures in front of them. The second appraiser vindicated Stoebig by using the method he had argued for the year before and came up with a higher value of $52 million.

Whether taxpayers were entitled to even more than that is still a matter of dispute. Independent appraisals have put the value of the Las Vegas property Del Webb wants at $71 million or more.

The BLM decided the first half of the trade would have so few effects on the environment that an environmental impact statement was not necessary. But local environmental groups disagree; they are concerned about the development's contribution to Las Vegas' urban sprawl and already dirty air.

"In Las Vegas we have development run amok," says Charles Watson of the Nevada Outdoor Recreation Association.

Watson also worries about the effects of development on the threatened desert tortoises that live on BLM land and on a nearby wilderness study area that contains rare plants and unique petroglyphs.

"Del Webb says they'll fence it off," he says. "Give me a break."

The Nevada Environmental Coalition and the Nevada Outdoor Recreation Association have both filed lawsuits against the exchange.

In January 1998, a Wall Street Journal article painted a highly unflattering picture of the Del Webb trade. Two months later, the Inspector General's report on the deal was released, revealing in detail the back-room machinations it had interrupted. Then another scandal, this one involving Nevada deals between the Forest Service and the American Land Conservancy, a California-based nonprofit, was charged by the Department of Agriculture (HCN, 12/21/98).

By October 1998, Nevadans had had enough. That month the state's delegation got Congress to pass a law bypassing the exchange process by allowing the BLM to sell its lands in the Las Vegas Valley and keep most of the money for conservation purposes. Although some exchanges already in the works - Del Webb's second phase among them - will be allowed to proceed, the game of trading for Las Vegas real estate is mostly over.

Some people say that Nevada is an unusual case and that land exchanges here aren't typical. But as the Del Webb swap shows, when a proponent with money and political clout comes along, federal officials are ill-equipped to defend the public's interests.

A one-woman truth squad

A few years ago, Janine Blaeloch fell in love with a mountain.

Blaeloch, a slender, intense Seattle resident, was once an environmental consultant who wrote environmental impact statements for the Forest Service. She became acquainted with Huckleberry Mountain, which lies between the city of Tacoma and the Cascades, when some friends asked for her help in appealing a land exchange that would give a large chunk of this ridge to Weyerhaeuser Corp.

What she learned changed her life, sending her into a world of quiet, often enormous land deals whose records were buried in agency files all over the country.

Weyerhaeuser wanted 4,400 acres on Huckleberry Mountain; in return, it was offering the public some 30,000 acres, most of them near the Interstate 90 corridor.

This looked like a wonderful deal - but 90 percent of the company's holdings had either been clear-cut or were too high and rocky to grow trees. Not only that: Some of the land the public was getting had been traded away to the company in the 1980s. Now, after shaving off the trees, Weyerhaeuser was offering it back.

Blaeloch was so incensed by the Huckleberry Mountain trade that she went on to found the nonprofit Western Land Exchange Project, the only environmental organization that does nothing but track federal land swaps. She soon made enough disturbing discoveries to start calling the program "the second great Land Grab."

Blaeloch found that, much like the Nevada experience with Del Webb, most land trades are proposed by the private sector, and proponents often pressure federal agencies to hurry the environmental studies that justify them. Meanwhile, the documents that are the crux of the deals - the appraisals - are kept from the public until it is too late to change anything.

"We never have enough of the picture to truly determine whether a land exchange is meeting the public interest until after the fact," she says. "They've been able to do these things behind the scenes for a very long time."

Blaeloch found horror stories all over the country. In Arizona, a mining company was paying part of the salaries of the BLM employees that were processing its trade. In Idaho, a prominent businessman had proposed an exchange with the Boise National Forest that would give him 10 acres for every one he contributed. In central Oregon, a timber company was about to make a net gain of around 6 million board-feet of public timber by trading away land it had clear-cut. This last strategy, often involving huge parcels of land, had recently become common in the Northwest.

"We're subsidizing corporations by giving them timber," she says. Blaeloch found that the agency staffers who processed trades were seldom trained to deal forcefully with high-powered corporate lawyers. She also became convinced that some environmentalists were being adroitly manipulated by exchange proponents.

The Huckleberry Mountain trade, for instance, was at first opposed by Washington's environmental community as a "trees for stumps' deal. But after Weyerhaeuser promised to donate an additional 2,000 acres to the Alpine Lakes Wilderness, a popular recreation area, opposition just about evaporated.

Although a lawsuit against the trade was filed by two environmental groups and the Muckleshoot Indian tribe, which was losing religious sites on the mountain, the timber company finally prevailed in 1997.

Shortly after that, Plum Creek Timber Company used a similar strategy in the so-called Interstate 90 exchange. The company wanted to divest itself of its highly visible - and controversial - holdings in the high Cascades, around half of them already clear-cut, in return for lower-elevation tracts that grow trees faster

Plum Creek wanted the deal done by the end of 1998. After a year of public meetings, however, company officials realized that a lawsuit like the one over Huckleberry Mountain was probably inevitable. The Western Land Exchange Project and a number of other groups were opposed to any trade that gave native forest to a timber company.

Blaeloch felt the Forest Service was rushing through its wildlife surveys to accommodate Plum Creek's deadline.

In April 1998, company officials announced that they were abandoning the administrative route to their exchange, and would instead try to get Congress to authorize it. Since legislated exchanges are usually immune to citizen protests and lawsuits, the environmental community here was outraged.

Still, after a summer of changes to the trade that reduced the acreage Plum Creek was getting, protected a large block of forest in the Green River, and set up a wilderness study area near the Alpine Lakes, six key organizations gave the bill their seal of approval. In October 1998, Congress passed it.

Steve Whitney, Northwest director of the Wilderness Society, which did not endorse the bill, says that the swap was helpful in consolidating some areas of public land. But he doesn't think anyone had enough biological data to say whether the losses of public land were worth it.

"The reality is that we have cut too much. We have cut ourselves into a corner, and a rational person would stop right now," he says. "That's the gut-wrenching thing about exchanges."

The trade offs can be harsh

The Huckleberry exchange follows a pattern seen in other trades around the West: Proponents hoping for a green seal of approval are often quite willing to sit down with environmental organizations. But citizen groups that take this route have to make hard choices.

The Greater Yellowstone Coalition, for instance, recently helped broker a legislated swap between Gallatin National Forest and Big Sky Lumber. The trade consolidated a large area of former railroad lands north of Yellowstone National Park, and will benefit grizzlies, moose and elk. On the other hand, 40 percent of the 100,000 acres the public got in the exchange had been logged - including nearly 2,000 acres the company got in an early phase of the transaction, cut, and then traded back. Local critics also say Big Sky Lumber got a sweet deal on some prime tracts near a ski area.

Sam Francis, who represents a group that wanted the Forest Service to drive a harder bargain here, says corporations have learned how to sway organizations like the Greater Yellowstone Coalition: "They dangle something out that an environmental group really wants."

Big Sky Lumber kept the negotiations lively by threatening to subdivide its holdings. GYC program director Michael Scott says that the Yellowstone region is being developed so rapidly that it was crucial to complete the trade.

"These guys aren't dumb," he says of corporate proponents in general. "They're cherry-picking high-value public lands all over the West and using them to get what they want."

The federal law governing land exchanges is clear. It says that all trades must not only be in the public interest, but must also provide equal market values.

The two concepts are supposed to work as a fail-safe system, not to be played off against one another. But the secrecy that protects appraisals from public view makes abuses almost inevitable. It was only last fall - months after the Huckleberry Mountain exchange had been final - that independent timber appraisers discovered that the public had lost over $15 million on that transaction.

"Mining companies and corporations aren't in this for the public interest," Blaeloch says. "They're in it for the money."

The recent spate of land exchange scandals has spurred some administrative reforms. Both the Forest Service and BLM have set up national teams to find ways to improve land swaps. But critics say what's most important is public oversight. They want earlier and better public notice of exchanges. They want more outside oversight of trades and a lifting of the secrecy that protects appraisals from public view.

The federal land exchange program has some merit. It is politically palatable, fairly low in cost and recognizes that some lands are more valuable as wildlife habitat, watershed protection or recreation, while others can better be used for development. But this very process of chopping the West's landscapes into pieces with different uses and values practically invites corporations to trade them back and forth, until all the money has been squeezed out of them.

The terms of the debate seem never as simple as exchange apologists would have us believe. How can we choose between old-growth forests and alpine scenery? Or between desert tortoises and ducks? Why should we have to?

Charles Watson, a longtime defender of the West's BLM lands and co-author of the 1975 book, The Lands No One Knows, has seen first-hand the impact of such choices on his home state of Nevada.

"I think these land exchanges have gotten out of control," he says. "Unappropriated government land must be the frontline of environmental defense."

The Great Barbecue ended a century ago, but there is still enough meat left on the West's bones to tempt corporate appetites. But these final remnants of a once-pristine landscape have now become infinitely more precious to us all. As Will Rogers once observed, nobody is making any more land.

Lynne Bama lives in Wapiti, Wyoming. Her writing has appeared in Sierra, Orion, and several anthologies. She has been following the federal land exchange program for the past year.

This story was funded by grants from the Wyss Foundation, the Ruth Mott Fund and the Kendall Foundation.

You can learn more ...

* The Department of the Interior inspector general audit reports on Nevada land exchanges are: REPORT NO. 96-I-1025, "Nevada Land Exchange Activities, Bureau of Land Management" (July 1996); REPORT NO. 98-I-363, "The Del Webb Land Exchange in Nevada, Bureau of Land Management" (March 1998) REPORT NO. 98-I-689, "Followup of Nevada Land Exchange Activities, Bureau of Land Management" (September 1998). All are available online at: www.oig.doi.gov or can be ordered from: Office of Inspector General, U.S. Department of the Interior, 1849 C St. NW/mailstop 5341, Washington, D.C. 20240
* Western Land Exchange Project, P.O. Box 95545, Seattle, WA 98145-2545 (206/325-3515). They also have a Web site: www.westlx.org.

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