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. . : REPORTBY THE //42&s Comptroller General ; i OF THE UNITEDSTATES ; How To Speed Development Of Geothermal Energy On Federal Lands Eight years after enactment of the Geothermal Steam Act, there is no commercial produe ti on of geothermal energy under a Federal lease. Leasing delays are one of several important reasons for this slow pace. Since Federal lands are critical to the development of geothermal energy, GAO is making several recommendations, including changes in the act. Even without these changes, there are administrative improvements the Departments of the Interior and Agriculture can make. This report was requested by the Chairman, Senate Committee on Energy and Natural Resources. EMDgO-13 OCTOBER 26, 1979 COMPTROLLER GENERAL WASHINGTON, OF THE D.C. UNITED STATES 20548 B-1782115 The Honorable Henry M. Jackson Chairman, Committee on Energy and Natural Resources The Honorable Mark 0, Hatfield Ranking Minority Member The Honorable Frank Church The Honorable Wendell H. Ford The Honorable James A. McClure United States Senate c In an April 2, 1979, letter, you expressed concern about the pace of geothermal development in the United States and requested that we investigate the Federal geoIn response to the request, thermal lea&[email protected] we looked specifically at. --the amount of geothermal lands owned and leased by the Federal Government, and activities on these lands: --reasons for the relatively slow development of and whether there is any geothermal energy, evidence to suggest that the pace of development is being deliberately slowed: --whether the Geothermal Steam Act of 1970 contains any provisions which are major impediments to geothermal development, particularly the acreage limitation of 20,480 acres per State, and whether diligence provisions assure development; --geothermal development on Federal lands in California and whether or not the application of a phased environment.al assessment would be advantageous; an2 --whether or not a major industry could be established on private and State-owned lands if the Federal Government were not. to encourage development on Federal lands. Detailed included information in appendix on these I of this and other letter. issues is , I ,.; Ii i- B-178205 the Geothermal Steam Act was In summary, although is no commerenacted over 8 years ago in 1970, there still Reasons cial geothermal production from a Federal lease. offered for the slow pace of development are many and but certainly delays in Federal leasing have been varied, And, since Federal lands are critian important factor. cal to the future of geothermal development, we believe indicated below and beginning on page 20 certain actions-But to place these in of appendix I --need to be taken. it is important to recognize that proper perspective, Federal leasing delays are not the only or even necessarily the primary reasons for the slow pace of geothermal developAs we stated in recent testimony before Senate and ment. L/ the main reasons probably have more House Subcommittees, to do with ecomomic and technological considerations. As now being considered includes various you know, legislation financial incentives and other initiatives addressing this part of the problem. Since 1974, after a slow start, a substantial amount of Federal land has been offered and leased for geothermal About 815,000 acres, or 37 percent of federally development. owned "known geothermal resource area" (KGRA) lands, have been so offered and, of this, over 444,000 acres- were under lease as of June 1979. Another 2.25 million acres of other potentially valuable geothermal resource lands have also 1.67 million of which were still under lease been leased, as of June 1979. Most of the land leased has been under the jurisdiction of the Bureau of Land Management. The Forest Service, which also manages a significant portion of Federal lands with high geothermal development potential, has made considerably less progress in leasing its lands, particularly in California. While considerable interest has been shown by industry in leasing such lands on Energy Resources and Materials Produc-l/Subcommittee tion, Senate Committee on Energy and Natural Resources, and Subcommittee on Mines and Mining, House Committee on Interior and Interior Affairs, July 20, 1979, and Sept. 6, 1979, respectively. 2 B-178205 no lease sales have yet been held and no in California, Unless geothermal leasing is leases have been issued. given higher priority within the Forest Service, we believe it could be a matter of concern for future geothermal development. We found no indication that the pace of geothermal As of June 30, development was being deliberately slowed. lease applica1979, however, close to 2,000 noncompetitive about half involving Forest tions were awaiting action, Service lands. We also noted that over l/2 million acres of land on which leases have been relinquished or terminated are not being made available for re-leasing in a We believe the Bureau of Land Management timely manner. needs to determine the extent of any interest in such lands and make them available for re-Leasing. In addition, certain provisions of the Geothermal Steam Act of 1970-- particularly the acreage limitation and the present method of designating KGRAs--may act as impediments to future development. Thus , as we have stated in recent testimony, we favor certain changes that are beiny considered in current legislation. Finally, to help expedite geothermal development-particularly since the vast number of leases will never ---we believe that in certain be commercially exploitable instances the Government ought to give developers the option of accepting leases based on separate (phased) environmental assessments for exploration and development. Legislation may be needed to clarify this issue. PENDING LEGISLATION Several bills introduced by Senator Church, Senator Representatives Udall and Santini, and RepresenMcClure, tative Symms (S. 1388, S. 1330, H.R. 5187, and H.R. 4471, respectively), relating to Federal geothermal leasing activities, appear to be patterned after recommendations included in a recent report by the Interagency Geothermal Streamlining Task Force. Our review disclosed many of the sane problems and generalI,,/ led to the same kinds of recommendations. in our most recent Thus, as indicated testimony before the Eiouse Intc:rior's Subcommittee on Mines and Mining (see app. TV), we qenerally support the Task Force recommendations as we1.L IS leqgislation currently being consitjered. Whether or not legislation is adopted, however, the Secretaries of Aqriculture, Energy, and the B-178205 Interior should implement those changes that they can make the Interagency Geothermal In addition, administratively. Coordinating Council should monitor the actions taken on these recommendations by the respective Departments and include in its 1980 annual report a summary of the specific steps taken. AGENCY COMMENTS We submitted a draft of our analysis to the Departments of Agriculture (Forest Service) and the Interior for their review and oral comment. Neither Department expressed major Forest Service disagreements or raised other problems. officials acknowledged the problem of excessive delays in p,rocessing lease applications and presented us with a memoForesters randum (see app. V) being sent to all Regional which, the Service hopes, will speed up processing. Interior officials provided further views on the re-leasing of lands with relinquished or terminated leases and the application of a phased environmental review process. These comments, along with our evaluation of them, appear in more detail on page 21 of appendix I. This report is also being sent to the Honorable Henry M. Senate Committee on Energy and Natural Jackson, Chairman, and Senators Hatfield, Church, and McClure who along Resources, with you formally requested this information. We are sending copies of this report to the Secretaries of Agriculture, the Interior, and Energy: appropriate House and Senate energy committees; and the Director, Office of Management and Budget. Copies will also be made available to other interested parties who request them. of 4 the United States Contents -Page APPENDIX I II III IV v LEASING AND DEVELOPMENT OF FEDERAL GEOTHERMAL RESOURCES Federal leasing program estabSteam lished by Geothermal Act of 1970 Interagency Geothermal Streamlining Task Force Geothermal leasing program activities Reasons cited for the relatively slow pace of geothermal energy development Some provisions of the Geothermal Act of 1970 seen as impediments Slow geothermal development in California-would phased environmental assessment help? Geothermal development without Federal Government involvement not advisable Conclusions and recommendations Agency comments and our evaluation 1 8 11 17 19 19 21 LETTER OF REQUEST FROM UNITED STATES SENATE, COMMITTEE ON ENERGY AND NATURAL RESOURCES 23 INTERAGENCY STREAMLINING TASK FORCE RECOMMENDATIONS 26 STATEMENT OF DOUGLAS L. MCCULLOUGH, U.S. GENERAL ACCOUNTING OFFICE, BEFORE THE SUBCOMMITTEE ON MINES AND MINING, HOUSE COMMITTEE ON INTERIOR AND INSULAR AFFAIRS, ON SEPT. 6, 1979 28 MEMORANDUMFROM U.S. DEPARTMENT OF AGRICULTURE, FOREST SERVICE TO REGIONAL FORESTERS, ON OCTOBER 11, 1979 42 ABBREVIATIONS BLM Bureau C.F.R. Code of IGCC Interagency KGRA Known Geothermal KGS Known Geologic USGS U.S. of Land Management Federal Regulations Geothermal Geological Coordinating Resource Structure Survey Area Council APPENDIX I APPENDIX I -,LEASING AND DEVELOPMENT OF FEDERAL GEOTHERMALRESOURCES FEDERAL LEASING PROGRAMESTABLISHED BY GEOTHERMAL STEAM ACT OF 1970 The Geothermal Steam Act of 1970 (30 U.S.C. 1001 et the Secretary of seq.) effective December 24, 1970, authorizes the Interior to lease Federal lands for geothermal resources Interior, through exploration, development, and production. its BUreaU of Land Management (BLM) and and U.S. Geological Survey (USGS), conducts the Federal leasing program. BLM is responsible for selecting lands for lease and holding lease sales. USGS classifies the lands according to its appraisal of their geothermal value before lease issuance, Lands which may and supervises development of the lands. be leased under the act include --open public, certain withdrawn, and acquired lands administered by the Secretary of the Interior, --National istered Forests and other lands adminthe Forest Service, and by --lands which have passed from Federal ownership, subject to a reservation to the United States of mineral resources. Lands such as national recreation areas, National Park Service lands, fish hatcheries, wildlife refuges and ranges, and other similarly protected areas are exempt from leasing under the act, as are Indian lands. Leases on Indian lands may be obtained, however, under the separate leasing authority of the Bureau of Indian Affairs. The amount of land which lnay be held under geothermal leases by any person, association, or corporation in any one State is limited to 20,480 acres. The Secretary may, in 1985, 15 years after passage of the Geothermal Steam Act, increase the lnaximum allowable holding in any one State to 51,200 acres. APPENDIX I APPENUIX I Applicable Federal regulations Regulations Group 3200 of title 43, Code of Federal establishes the leasing procedures for competitive (C.F.K.), lands available for leasing, and noncompetitive leases, qualifications of lessees, leasing terms, surface management rentals and royalties, and rules for explorarequirements, Part 270, title 30, tion operations on unleased lands. establishes the jurisdiction and function of the geothermal engineering requirements for operators designed supervisor, to promote safety and to minimize waste and environmental damage, pollution control measures, methodology for computing royalties, reports to be filed by the lessees, and Part 271, title 30, establishes enforcement procedures. the general procedures to be followed and the requirements to be met by lessees who enter into a cooperative or unit plan for collectively developing a geothermal field. Section 3200.0-5 of 43 C.F.R. defines known geothermal resource areas (KGRAs) as areas "in which the geology, nearby discoveries, competitive interests, or other indicia" indicate that the geothermal resource prospects are good enough to warrant expenditures of money for their extraction. "Competitive interestll occurs when the lands covered by two or more noncompetitive lease applications filed in the same filing period overlap by 50 percent or more. Such land is automatically classified as a KGRA subject to competitive leasing. The KGRA concept is similar to the known geologic structure (KGS) approach in oil and gas leasing, except that designation of a field as a KGS requires a producing well. The environmental impact review procedures used by the agencies involved (formalized by two memoranda of understanding) call for an environmental review at each step in the geothermal development process on Federal lands, i.e., before a competitive lease sale is held, before noncompetitive leases are issued, and before each postlease plan of operation 1s approved. The regulations to implement the program went into in January 1974, and tiie first leases were issued in 'i'ne first commercial production of geothermal energy from Federal lands is scheduled to begin in the Imperial Valley In Zaiifornla in the nciar future. effect 1974. APPENDIX I APPENDIX I INTERAGENCY GEOTHERMAL STREAMLINING TASK FORCE in his April 1977 energy message, The President, directed the Departments of the Interior and Agriculture to streamline their procedures for leasing and environmental "to remove unnecessary barriers to development of reviews In response to this direction, an geothermal resources." Interagency Geothermal Streamlining Task Force was formed under the already established Interagency Geothermal The IGCC (formally the GeoCoordinating Council (IGCC). thermal Energy Coordination and Management Project) was created by the Geothermal Energy Research, Development, and Demonstration Act of 1974 (30 U.S.C. 1101 et seq.) to coordinate geothermal activities scattered among various Federal agencies. the Streamlining Task Force has Since its inception, conducted an in-depth study of Federal leasing and permit procedures and has held a series of public meetings to Several special studies solicit suggestions and comments. on development of geothermal resources on Federal lands were also accomplished under contract in support of the Task Force's work. The Task Force report to the IGCC included 19 specific legislative, regulatory, and administrative recommendations expected to improve Federal geothermal (See app. III.) leasing procedures. Sixteen of the 19 recommendations were approved by the IGCC in January 1979, while the remaining 3 were remanded for further study. GEOTHERMALLEASING PROGRAMACTIVITIES USGS has identified 3.4 million acres as KGKAs and another 106 million as potentially valuable geothermal acreUSGS records show that 64 percent, or about 2.2 milliorl age. acres of KGRAs, are on federally owned lands, as shown on the following page. APPENDIX I APPENDIX I Geothermal Federal Acreage Potentially valuable geothermal acreage (note a) KGRA Non-Federal 11,913,ooo 88,160 Alaska Arizona 2,960,OOO 3,700 California 897,698 Colorado 12,453 8,372 3,322,OOO 131,224 46,794 18,093,OOO Montana 40,318 18,337 3,910,000 Nevada 414,728 220,734 14,074,000 New Mexico 191,822 136,030 8,071,OOO Oregon 249,552 182,384 15,187,OOO Utah 97,716 31,342 Washington 28,978 6,635 Idaho South 15'990,000 573,939 5,855,ooo 6,063,OOO Dakota 435,000 Wyoming Total Percent 906,000 2,156,349 1,224,567 64 -a/Based on USGS estimates private acreage. 106,779,OOO 36 and includes Federal, State, and Of the federally owned KGRA lands, 37 percent, or 815,000 acres, has been offered for lease. Of those lands offered for lease, 54 percent, or 444,000 acres, is under lease as of June 1979. Regarding other potentially valuable geothermal lands, about 2-l/4 million acres have been leased. As of June 1, 1979, about 1.67 million of these acres remain under lease, as follows: 4 APPENDIX I APPENDIX I Current Leases Issued Noncompetitive Active 1,320 Competitive 296 1,616 Total Competitive Ended 988 332 265 31 1,253 363 -. Total acres acreage L,672,562.61 leased Portion National Forest in 90,017.75 444,416.20 43,524.62 2)116,978.81 1 133,542.37 leases During the past 5-l/2 years (1974 through May 19791, there have been a total of 59 competitive public lease sales held in nine States. These sales have resulted in over $73.6 million in total bonus bids and about $36 million in total winning bonus bids. Acreage in five western States--California, Idaho, Nevada, Arizona, and Oregon--accounted for most of the sales (72 percent), most of the money (83 percent), and most of the competitive acreage (63 percent) leased between 1974 and 1978. The Geysers KGRA (California) alone has accounted for over $24 million in total accepted bonus bids, or more than 68 percent of all bonus bids accepted since the first Federal geothermal lease sale in 1974. Noncompetitive leases The leasing program began with a surge of 2,000 noncompetitive lease applications in January 1974. The number of applications filed in later years has been less, and has been more evenly spaced. The Streamlining Task Force used data as of June 1978 to evaluate BLM's performance in handling the lease applications. Their results show that since 1974 the average number of months from application to lease issuance has been reduced from 23 to 8 for those applications that resulted in leases. Since only 2 percent of all Forest Service applications have resulted in leases, the Task Force concluded that there is insufficient data by which to measure any appreciable changes in its performance. lease As of June 30, 1979, there were 1,956 applications awaiting acticjn for the noncompetitive following reasons: APPENDIX I APPENDIX I --Awaiting KGRA report --Pre-lease plan from USGS (34). of development (1). --Pending preparation of Environmental ment Report (BLM only) (597). --Awaiting Forest --Lease Assess- comment of other agencies (1093 from Service and 15 from other agencies). forwarded --Processing for signature (adjudication) (30). (186). Processing time still~-__. a to leasmajor deterrent ~.-__ of Forest System lands - -_____ While evaluating the President's National Energy Plan, we reported in ;ruly 1977 that the time taken to process leases by the Departments of the Interior and Agriculture seemed to be one of the major deterrents to geothermal l/ We found in this review that the energy development. leasing of Federal lands under the jurisdiction of AgriUnless geothermal culture's Forest Service has not improved. leasing is given higher priority within the Forest Service, we believe it cculd be a matter of concern for future development. Based upon USGS designations, the Forest Service estimates that about 900,000 acres of National Forest System lands are within KGRAs. In addition, the geothermal industry has submitted many applications involving several hundred thousand acres outside of KGRAs. As of June 1, 1979, about 43,500 acres of Forest System lands have been leased competitively and about 90,000 acres of other potentially valuable geothermal lands are under lease. According to BLM records, 989 noncompetitive lease applications are currently pending for Forest System lands. The Chief development of is "generally ment program. of the Forest Service recently testified that geothermal resources on National Forest lands compatible" with the Service's overall manageHowever, Forest Syst.em lands in California -l/'"An Evaluation July 25, 1977. of the Mational Energy 6 Plan," EMD-77-48, APPENDIX I APPENDIX I have generated considerable interest (233 noncompetitive lease applications are pending), but no lease sales have or noncompetitive--have been held and no leases-- competitive We noted that the Forest Service been issued in California. Regional Office in California has not been provided the resources to deal with geothermal leasing activity in recent years. Relinquished or terminated leases not being made available for noncompetitive leasing We found that lands on which leases have been relinquished or terminated are not being made available for noncompetitive leasing. USGS records as of June 1, 1979, show the following: Number Noncumpetitive or terminated leases Competitive leases or terminated Acres relinquished 332 528,158 relinquished Total -- 31 363 66,037 594,195 The re-leasing of noncompetitively leased lands is covered in 43 C.F.K. 3211, but BLM officials have instructed their State offices not to make these lands available for re-leasing. Apparently, BLM headquarters officials believe that making these lands available would lead to the formation of overlapping or competitive-interest KGKAs (i.e., lands covered by two or more noncompetitive lease applications filed in the same filing period which overlap by 50 percent), requiring leasing competitively through a lease sale (a dilemma further discussed beginning on p. 13). We believe that Interior should, at a minimum, determine the extent of any interest in these lands and make them available for re-leasing. Interior withdrawn plans to lease lands There have been some disagreements rity of the Department of the Interior Steam Act of 1970 to issue leases for regarding the authounder the Geothermal certain withdrawn and APPENDIX I APPENDIX I acquired lands, particularly lands withdrawn for the BLM initiated an environmental Department of Defense. assessment of 72,460 acres in and around the Coso KGRA in Some 41,560 acres of the Coso Study Area are August 1978. located within the boundaries of the China Lake Naval Weapons California, and 2,920 acres are Navy-acquired lands. Center, The assessment is scheduled to be completed next year and Until recently, BLM officials will cost over $700,000. believed that the Geothermal Steam Act of 1970 did not authorize the leasing of geothermal resources in lands withdrawn for or acquired by the Department of Defense, and they instructed the California BLM office to reject promptly any The application for development of resources on such lands. Solicitor in the Department of the Interior has been looking into this problem, and we understand that BLM now plans to lease these lands on a priority basis. REASONS CITED FOR THE RELATIVELY SLOW PACE OF GEOTHERMALENERGY DEVELOPMENT Responses tram Government and industry were mixed in explaining the relatively slow development of geothermal Several developers told us that resource uncerenergy. tainty was a primary factor, and they felt that geothermal exploration has not borne fruit to become a major future Unless more promising sites are discovered for industry. future development, the industry will not grow beyond its current size and may lose the large capital investment some major developers currently have in geothermal energy. In fact, lack of sufficient capital for development was mentioned by three large developers as a factor for the slow rate of geothermal development to date. Other reasons given were that (1) Federal agencies have assigned low priority to processing geothermal leases, (2) these agencies lack sufficient staff and money to process leases, (3) there are too many review levels within and among these agencies, (4) there is too much concern with environmental matters, especially 1n California, and (5) Federal agencies took too long to implement the act. The Forest Service was singled out by industry as the biggest offender. It was said to be lacking interest in and knowledge of geothermal resour(:es, and interested only in surface resources. Several developers said that Forest Service personnel have not been sufficiently trained in geothermal resources. APPENDIX I APPENUIX I developers also said BLM, On the other hand, several and particularly USGS, have been very professional in One developer said carrying out their responsibilities. that USGS personnel on several occasions worked overtime Proand through weekends to complete lease requirements. viding Federal agencies with more staff and money and easing the environmental process was suggested by several developers as the most appropriate solution for the leasing delays. Also, delays in the environmental review process could be reduced by requiring concurrent reviews by Federal agencies rather than the current practices of sequential agency review. More uniformity in leasing practices among BLM offices was also suggested as a remedy to the leasing backlog. Accordinq to several developers, the activities of BLM offices are too heavily influenced by the personalities of the office directors. The case cited was the California BLM State Director, who was very sensitive to environmental interests, which resulted in an overly cautious approach toward geothermal development by the California ELM office. The result has been an elongated leasing approval process in California. USGS officials believe that--considering the time necessary to develop a new industry--geothermal development appears to be proceeding at a reasonable rate (it has only been 5 years since the issuance of the first Federal lease. However, they indicate the following factors have prevented more rapid development: --Lack of "off the shelf" technology inhibited large-scale development to a certain extent, each project research and development project. has and, is an --Lack of trained people in the industry has caused both Government and industry staffing shortages. --There are overlapping requirements of county, regulatory agencies. and sometimes conflictinq State, and Federal USGS also noted that extremists from both the pro-environment and the pro-energy development groups have opposed each other, using the checks and balances built into the laws affecting geothermal development to the point of stifling those voices of moderation which seek an equitable compromise between environmental and pro-energy concerns. APPENDIX I APPENDIX I other delays are inadvertent products In addition, such as wilderness manner in which national goals, are being pursued. tion, Other officials, ment were reasons, for the of the preserva- given by both industry and Government relatively slow pace of geothermal develop- --the price controls on oil and gas, making more economical than geothose resources thermal resources; --the lack of desire (emphasis) at the local level to issue leases and too much discretion in lower level Federal offices: --extremely activities low priority at the field given to geothermal level; --fear of legal action by especially in California: environmental --the lack favorable advancements development; of technological economics for --finding a market so the developers on a demand for their product; groups, allowing can count --the need for direct Federal assistance to the first-generation utilities in the field--specifically, financing to prove out demonstration projects and to install transmission lines; --the lack of or permits; time and limitations --the lack of and locations reliable information of resources. on issuing leases on the extent At no time in our discussions or in our review of available records did we find indications that the pace of geothermal development is being deliberately slowed. One industry spokesman summed up the major problems quite well, Y APPENDIX I during a recent hearing before we believe, Energy Committee when he stated: 1/ - APPENDIX I the Senate that the first. time around "The key issues are it takes a lot longer. There is on everything, Policy is being made as no po:: cy t.hat exists. the various steps are taken, and that is one of the obstacles; in addition, we find that. when the Congress has an intent to provide the finansuch as the alternative energy cial incentiive, then the implementation of the tax credit, * * * is delayed by a year cr more. regulations This has happened sequentially in every one of the steps that has taken place in the past. flaws in the legislation Also, we are finding itself so that there is the need for cleanup. I think as this is done, we will find these and I think we will see that projects going, with adequate funding for the various environmental and institutional steps that have to besee future projects come along taken, we will at a better pace.'" SOME PROVISIONS OF THE GEOTHERMAL STEAM ACT OF 1970 SEEN AS IMPEDIMENTS The acreage limitation, KGRA designation, and readjustment. of lease terms are cited most. often as impediments to development built into the Geothermal Steam Act. itself. Acreage limitation Ill_r Our work at three BLM State offices as well as discussions with Government and industry officials indicated that the acreage limitation of 20,480 acres per State, as established by the Geothermal Steam Act. of 1970, is being enforced and does delay development. of geothermal resources. Our analysis showed that the primary impediment_ resulting from the acreage limitation is that it prevents developers from developing more than one pl-eject. at a time. Some of of the major developers wish to invest in multiple pr0ject.s; however, they claim that the i:urrent acreage limitation prevents this. L/Comment. by Dr. Robert Rex, President. of Republic Geothermal, Incor July 20, 1973, before Subcommittee on Energy Resources and Materials Production, Senate Energy and Natural Resources Committee.. Y APPENDIX I APPENDIX I Other include: reasons cited for increasing the limitation --There are only a handful of companies in the United States financially and technically capable of exploring and developing such acreage for the production of geothermal energy, and limiting these companies to 20,480 acres of Federal than one-twelfth of the geothermal lands --less 246,080 acres allowed for oil and gas leasinq-makes no sense. --Technology for discovering and defining geothermal resources has not been developed to nearly the degree of sophistication now found in oil and gas exploration; consequently, each project to explore for geothermal resources in a given area should consist of 15,000 to 20,000 acres. And since many companies wish to invest in multiple projects they require more than 20,480 acres per State. --Although as little as 1,000 acres of prime geothermal acreage, after reservoir characteristics and size are established, may technically be sufficient to supply one 50-mepawatt powerplant, utilities considering a commitment to purchase geothermal resources can be expected to require up to 10 or more times that acreage in order to assure the availability of sufficient reserves to make the commitment to construct transmission capacity economical. The Department of the Interior believes the present an increase to acreage limitation may be low and supports 51,200 acres, as proposed in H.R. 740: This of course differs from the proposal in S. 1388 and H.R. 5187 for a combined oil, gas, and geothermal lease acreage per State of 266,560 acres, and 248,000 acres in S. 1330 and H.R. 4471. The Department of Energy also does not consider it desirable to couple geothermal acreage limits with oil and gas limits; however, it does recommend an increase to 51,200 acres, but without any overall limit on developed plus undeveloped acreage. Although the proposed limit in S. 1388 and H.R. 5187 miqht restrain large oil companies from monopolizing geothermal areas, Interior believes it could provide the 12 APPENDIX I APPENDIX I opportunity for other parties to totally dominate geothermal The Department of Energy has leasing and development. testified that there is a reasonable mix of oil and non-oil resources at present, and that companies lei. ing geothermal smaller acreage limits for oil companies would deter some of the more active developers in an industry already growing at too slow a pace. We believe that while the present limitation of 20,480 acres per State might be unduly restrictive and an increase allowing the leasing of over is needed, the provisions 200,000 acres per State may be excessive for non-oil companies concentrating on geothermal development, while also inhibiting oil companies from further increasing their geothermal development if they have to do it at the expense Thus, we believe of oil and gas development. tl combined development total limitation for oil, gas, and geothermal could hinder some of the exploration and development of Due to that infancy of the geothermal geothermal resources. we believe that increasing industry and its technology, the limitation to an overall Sl,ZOO acres, as introduced in H.R. 740, would be appropriate. RGRA designation The KGRA designation criterion was also prominently mentioned as a major impediment to geot hermal development. The Geothermal Steam Act detir?es a KGRA as: "An area in which the geoloqy, nearby discoverinterests, or other indicia ies, competitive would, in the opinion of thf? Secretary (of the Interior), engender a belief in men who are experienced in the subject matter that the prospects for extraction of geothermal steam or associated geothermal resources are good enough to warrant expenditures of money for that purpose." Forty-seven of the 108 exls..:~l:j KGKAs were designated as such entirely on the basis :>t "competitive interest." This term, as defined in the regulations, actually means "competitive overlap" (i.e., the entire acreage covered by a noncompetitLve lease application is designated a KGRA if at least one-half of the lands af:e also covered by another application filed during the sar'rc? calendar month). This approach was derived on the premise that if more than one party expressc:d interest in an d!:ea, the arca ,nust be put. up for compet?tive bid. APPENDIX I APPENDIX I Several industry spokesmen voiced the opinion that many times KGRAs are arbitrarily established under questioncase, a company able circumstances by USGS. In one notable inadvertently created a KGRA through erroneously filing twice 0n some of the same land in a calendar month, Inappropriate KGRA designations are also very costly for the Federal Government since Federal agencies are required to complete all the steps necessary for leasing, including environmental even though developers are not interested in assessments, competitively bidding for these lands. Oftentimes these lands go through several lease offerings without any bids being submitted-305,000 acres in past lease sales have received no bids. Several developers also object to the overlapping lease application criteria for KGRA designations. They said that this is not sufficient justification for KGRA classification, applicants know very little concerning the actual Generally, geothermal potential of these lands when they file their applications. When two developers with limited knowledge apply for the same area, or areas which overlap by at least 50 percent, such lands suddenly become KGRAs and, therefore, are available only through competitive bidding. Several developers also said that the period in which USGS can classify lands as KGRAs after a noncompetitive lease application is submitted is too long and prevents developers from moving ahead with more extensive exploration efforts. According to these developers, the risk of having their noncompetitive applications rejected through KGRA classification during the lease approval process is too great for them to spend their money exploring these lands. They said they could lose their total investment should something trigger USGS to designate the area as a KGRA. This jeopardy has been, and continues to be, a major constraint to early-on geothermal exploration of Federal lands. We believe, as stated in recent testimony, future KGRA designations should be limited to an area in which a well has been drilled and demonstrated to be capable of producing geothermal resources suitiable for the production of electric power in commercial quantities. Many companies favor readjustment of lease terms We were told that the provision in the Steam Act--subsection 8(a)-- which allows the Secretary of the Interior to unilaterally readjust the terms of a lease after 10 years, has APPENDIX I APPENDIX I led to caution and restraint by many utilities) who are reluctant to invest a powerplant under such conditions. readjustment of :hese terms 30 years tion of a plant is finished to allow costs. companies (primarily in the construction of They favor, instead, a from the time construcfor amortization of The Interagency Geothermal Coordinating Council has recommended eliminating the subsection 8(a) provision on the basis that it is both an impediment to geothermal development It is and reciundant to other provisions in the Steam Act. noted that subsection 8(b) of the act already authorizes the Secretary to adjust rentals and royalties on geothermal In addition, leases every 20 years after production begins. section 24 of the act gives the Secretary blanket authority to establish rules and regulations to protect the public conserve natural resources, and protect water and interest, other environmental qualities. Present diligence provisions not a serious impediment The geothermal leasing regulations provide the following incentives to lessees for early exploration and development during the initial 5 years of a lease. --Rental fees on the leased increased after the fifth no production. --Rental tion fees will acreage year if be eliminated will be there is once produc- beyins. --Certain in the rental expenditures for diligent exploration first 5 years may be credited against fees after the fifth year. For succeeding years, however, the regulations provide a formula for computing the minimum expenditures necessary to qualify as a diligent exploration. The following table summarizes the minimum rents and expenditures necessary to maintain a lease for 2,560 acres, L/ if no commercial production takes place during the lo-year lease. that a geothermal lease -l/The law provides reasonably compact area of not more than shall embrace 2,561) acres. a Y APPENDIX I APPENDIX I Year of the primary lease 1 to 5 Annual and escalating rent (note a) -- Minimum expenditures for diligent exploration (note ---~a) $12,800 $ - Total $ 12,800 6 5,120 10,240 15,360 7 7,680 15,360 23,040 8 10,240 20,480 30,720 9 12,800 25,600 38,400 10 15,360 30,720 46,080 -__ Total $64,000 $102,400 $166,400 -a/No minimum has been during the first 5 minimum expenditure and the escalating established for diligent exploration After the fifth year, the years. is twice the sum of the annual rental rental due. Interior officials feel that it is difficult to say whether the diligence provisions are adequate because few of the leases have reached the escalation point (after the fifth year the minimum expenditure is twice the rent). Another Interior official said that the provisions were neither a hindrance nor a stimulant and even if the rental is stiffened it would have little effect because exploration costs are so Several developers told us that diligence requirements high. were relatively unimportant in terms of other problems they must face. The Department of Energy currently supports the diligence provisions proposed in S. 1388 and H.R. 5187. These provisions (1) require that a plan of operation for exploration be filed within 3 years of the issuance of a lease, or in the case of a no-surface-occupancy lease, within 3 years after the removal of the no-surface-occupancy limitation, and (2) provide that drilling c:ommence no later than 2 years after approval of such plan. While we support strict diligence provisions for the development of Federal resources, it is not clear that such diligence will potentially affect the speed of geothermal .6 I APPENDIX I APPENDIX I Y The rationale is that geothermal develresource development. opment is primarily constrained by economic and technological we believe the diligence proNevertheless, considerations. visions in pending legislation are reasonable and will assist geothermal development in the future. SLOW GEOTHERMAL DEVELOPMENT IN CALIFORNIA--WOULD PHASED ENVIRONMENTAL ASSESSMENT HELP? USGS feels three factors contribute to the relatively the most First, slow rate of development in California. resources in California occur in areas of exceptional aestheand recreational value (Lassen and Monobiological, tic, or in regions where minor subsidence could Long Valley), result in potentially severe economic problems (Imperial has developed exceptionally Second, California Valley). elaborate environmental review procedures at both the State a portion of the resource is in Third, and county levels. National Forests which have competing land uses. Developers generally feel that leasing in California has been more difficult because of environmentally sensitive office has taken more of a lands. Also, ELM's California pro-environmental stance than other State offices because of strong environmental pressure from public officials. Developers also believe that both RLM and the Forest Service have given geothermal leasing a low priority because they lack sufficient funds and staff to increase their efforts. In order to reduce the delays in lease issuance on all especially in California, phased environFederal lands, mental assessments have been recommended by several study The Secretary of Agriculture groups and Government. agencies. has recommended a similar approach through the use of a "conditioned development lease" which would allow a lessee to receive a lease and engage in casual (essentially nonsurface-disturbing) use and controlled exploration but would condition development of any discovery, including actual operations, on a second decision to proceed. The Secretary believes this procedure would expedite leasing of geothermal resources on lands administered by the Forest Service and still fulfill the environmental protection mandate of various statutes. 17 E APPENDIX I APPENDIX I The Streamlining Task Force has recommended a similar as an alternative to developers, approach, i.e., to provide, leases based upon separate environmental assessments of the The Task Force recomexploration and development phases. mendation is intended as an elective option and would allow developers to also obtain leases under the current system. According to the Task Force report, the present leasing process involves the issuance of leases that grant rights to development of any discovered resource subject to terms, It has been estimated and special stipulations. conditions, that 24 out of 25 geothermal leases will never be developed because no commercially exploitable resource will be found. But current practice is to conduct a pre-lease environmental review which evaluates the potential effects of full development from exploration through production. Interior's Associate Solicitor (Energy and Resources) concluded in June 1979 that the Secretary may issue qeotherma1 leases which withhold subsequent development rights until The Solicitor further concluded further approval is given. that detailed environmental impact consideration can be deferred until a time when concre%e information about the nature and extent of activities is available. In addition, the Director of BLM recently testified that the Department supports the concept of phased leasing, and that authority exits under the Geothermal Steam Act. Legislation may be necessary to clarify this issue. The phased review process does offer further risk to a developer in an already high-risk business. If a developer accepts a conditional lease and finds that he has a commercial resource, he could (1) be denied the opportunity to develop because of environmental sensitivity of the land or 2) have such severe restrictions imposed that development in the areas is no longer economical. To help expedite geothermal development, however-- particularly since the vast exploitable-portion of leases will never be commercially we believe that in certain instances the Government ought to give developers the option of accepting leases based on separate environmental assessment of the exploration and development phases. However, where such an option is exercised, it should be incumbent upon the Government agencies involved to provide the most comprehensive assessment possible in the initial stages in order to minimize uncertainties for the lessees. After decades of land management experience, 10 years of environment assessment experience, and at least. 5 years of geothermal leasing experience, last minute changes should occur infrequently, if at all. 3.8 Y APPENDIX I APPENDIX I GEOTHERMAL DEVELOPMENT WITHOUT FEDERAL GOVERNMENT INVOLVEMENT NOT ADVISABLE The consensus of both Federal and industry officials is that private and State-owned lands alone do not have sufficient geothermal resources to support a viable industry (recognizing the development that has taken place in the Geysers) e We were also told that most of the land with potential geothermal resources is owned by a mixture of State and Federal governments and private parties; therefore, it feasible to develop only the priwould not be economically vate and State-owned lands. According to USGS, the likelihood of developing a major geothermal industry on private and State-owned lands without encouraging development on Federal lands is remote. Many areas of geothermal potential contain private and Federal lands as a result of early homesteading laws. Since all types of land can occur in an area of geothermal potential, the Office of the Area Geothermal Supervisor (Menlo Park) feels the Federal lands must be inter-locked with private and State lands to realize our Nation's total geothermal potential. CONCLUSIONS AND RECOMMENDATIONS Although over 8 years have passed since the Geothermal Steam Act was enacted, there still has been no commercial geothermal production from a Federal lease--this despite the fact that the Geological Survey estimates that the Federal Government owns close to two-thirds of this Nation's total geothermal resources. Reasons offered for the slow pace of development are many and varied, but certainly delays in Federal leasing have been an important factor. since Federal lands are critical to the future of geoAnd, thermal development, we believe certain actions--indicated belowneed to be taken. However, it is important to remember that Federal leasing delays are not the only or even necessarily the primary reasons for the slow pace of geothermal development. As we stated in recent testimony before Senate and House Subcommittees, 1/ the main reasons probably have more to do with economic and technological considerations. Legislation now being considered includes various financial incentives ancl other initiatives addressing this part of the problem. -l/See footnote, page 2 of 1ettPr precetliny this appendix, APPENDIX I APPENDIX I a substantial amount a slow start, Since 1974, after of Federal land has been offered and leased for geothermal About 815,000 acres, or 37 percent of development. federally owned KGRA lands, have been so offered and, of this, over 444,000 acres were under lease as of June 1979. Another 2.25 million acres of non-KGRA lands have also been 1.67 million of which were still under lease as of leased, June 1979. Most of the land leased has been under the jurisdiction of BLM. The Forest Service-- which also manages a significant portion of Federal lands with high geothermal development potential-has made considerably less progress, however, While in leasing its lands , particularly in California. considerable interest has been shown by industry in leasing no lease sales have yet been held such lands in California, and no leases have been issued. Unless geothermal leasing is given higher priority within the Forest Service, we believe it could be a matter of concern for future development. We found no indication that the pace of geothermal development is being deliberately slowed. As of June 30, close to 2,000 noncompetitive lease applica1979, however, tions were awaiting action, about half involving Forest Service lands. Quicker action is needed on these applications. We also noted that over l/2 million acres of land on which leases have been relinquished or terminated are not being made available for re-leasing in a timely manner. We believe BLM needs to determine the extent of any interest in such lands and make them available for re-leasing. We recommend that the Secretary of Agriculture assure that geothermal leasing is given appropriate priority within the Forest Service. We also recommend that both the Forest Service and BLM process lease applications in a more timely manner and that BLM make available for re-leasing lands on which leases have been relinquished or terminated. In addition, we believe certain provisions of the Geothermal Steam Act of 1970-- particularly the acreage limitation and the present method of designating KGRAs--may act as impediments to future development. Thus-- as we have stated in recent testimony--WC: favor: --Increasing the acreage limitation per State for any person, association, or corporation from 20,480 to 51,200 acres--as introduced in H.Ii. 740. L0 APPENDIX 1 APPENDIX I --Limiting future KGRA designations to an area in which a well has been drilled and demonstrated to be capable of producing geothermal resources suitable for the production of electric power in commercial quantities. to help expedite geothermal development--parFinally, ticularly since the vast portion of leases will never be commercially exploitable --we believe that in certain instances the Government ought to give developers the option of accepting leases based on separate environmental assessments of the exploration and development phases. Legislation may be necessary to clarify this issue. Y Several bills introduced by Senator Church, Senator Representatives Udall and Santini, and RepresentaMcClure, tive Symms (S. 1388, S. 1330, H.R. 5187, and H.R. 4471, respectively) relating to Federal geothermal leasing activiafter recommendations included ties appear to be patterned in a recent report by the Interagency Geothermal Streamlining Task Force. As indicated, our review disclosed many of the same problems and generally led to the same kinds of recommendations as included in the Task Force report. Thus, as indicated in our most recent testimony before the House Interior Subcommittee on Mines and Mining (see app. IV), we generally support the Task Force recommendations as well as legislation currently being considered. Whether or not legislation is adopted, however, we recommend that the Secretaries of Agriculture, Energy, and the Interior implement those changes they can make administratively. In addition, the Interagency Geothermal Coordinating Council should monitor the actions taken on these recommendations by the respective Departments and include in its 1980 annual report a summary of the specific steps taken. AGENCY COMMENTSAND OUR EVALUATION We sublnltted a draft of our analysis to the Department of Agriculture (Forest Service) and the Department of the Interior for their review and oral comment. Neither Departor raised other problems. ment expressed major disagreements Forest Service officials acknowledged the problem of excessive delays 11~ processing Lease applications and presented us with a 1Temorandum dated October 11, 1979 (see app. \I) sent to all Regional Foresters, expressing concern about Y APPENDIX I APPENDIX I this problem and proposing specific time limits for environmental reviews and other leasing decisions. We believe this is a step in the right direction and, in this connection, have suggested in recent testimony that time limits such as are being considered in current bills may increasingly be needed as part of the energy regulatory reform process. With regard to the re-leasing of lands on which leases had been relinquished or terminated, an Interior official stated that the BLM State offices were instructed not to make these lands available for re-leasing in order to allow BLM headquarters a chance to promulgate new regulations which would provide for a more efficient, effective procedure for re-leasing these lands. He stated these new rules have been finalized and will soon appear ,in the Federal Register. He felt that expeditious processing of those lease applications which have been pending as a result of this problem could result if legislation calling for a 60-day deadline, from the day the new regulations are issued, was established. We agree that this recommendation should be given serious consideration. Another Interior official felt that the phased environ_ mental review should not be an option of the lessee. Rather,3 Government should retain the option of deciding on whether or not to do an Environmental Impact Statement or an Environmental Assessment Review. He suggested that in areas of great resource uncertainty the lessee should not be allowed to dictate the environmental review procedure to be used. We agree that the Government should determine when the option should be offered. f 22 APPENDIX II APPENDIX The Honorable Elmer B. Staats Comptroller General of the United General Accounting Office Washington, D. C. 20548 Dear Mr. IX States Staats: Several members of the Committee on Energy and Natural Resources have expressed concern about the pace of geothermal energy development in the United States. It is my understanding that the Interagency Geothermal Coordinating Council, established by the Geothermal Energy Research, Development, and Demonstration Act of 1974, has been examining the question of impedimehts to geothermal development through a specific panel created for that purpose. Some of the impediments identified by the panel performance of the Federal agencies which manage the geothermal leasing program. It has also been argued the Geothermal Steam Act of 1970 contains impediments development. While it is possible that the manner in which it is being impediments to development, it corporations which have obtained are not moving faster to develop to the perceived impediments or I request that you initiate of the Federal geothermal leasing the following questions: 1. provision out involve that to the Federal leasing law or carried out are the principal is also disturbing that those access to Federal lands them. Whether this is due other factors is unclear. an immediate investigation program which will answer Does the Geothermal Steam Act of 1970 contain any which is a major impediment to geothermal development? 2. Is the manner impeding geothermal in which this development? 3. Are the diligence Steam Act of 1970 adequate within a reasonable period provisions to assure of time? 23 Act is being carried of the Geothermal development of leases APPENDIX APPENDIX II Roes the acreage limitation of 20,480 acres per 4a. state per corporation require change to stimulate geothermal should the provision of the 1970 development? For example, Act which would allow an increase to 51,200 acres after 15 years be accelerated? being Is 4b. abused this acreage such that it limitation requires Is being enforced? tightening? it what portion of the geothermal resource 5. Approximately How much has been leased is owned by the Federal government? and'what type of activity has been performed on these lands? government were 6. ' If the Federal are there development on Federal lands, major industry could not be established owned lands? 7a. geothermal deliberately Is there any evidence development on public slowed? not to encourage any reasons why a on private and state- to suggest (or other) 7b. What are the reasons for development of geothermal energy? the that the pace of is being land relatively slow Federally-administered lands in California offer 8. perhaps the best prospects in the country for geothermal development, yet California has had the least amount of Federal leasing. Apparently, little progress has been toward environmental assessment of the hundreds of pending lease Given that as many as 9 out of 10 Federal applications. geothermal leases do not lead to development, phased environmental assessment has been recommended in some quarters to lessen the backlog of applications and reduce the unnecessary delay in lease issuance. Phased environmental assessment would amount to a minimal analysis at lease issuance with full on-site assessment prepared if and when the lessee submits an application for a drilling permit. What are the problems associated with geothermal development on Federal lands in California and would the application of phased environmental assessment be advantageous? Chairman Mark 0. Hatfield Ranking Minority 24 Member II APPENDIX Wendell II APPENDIX 13 H. Ford Y 25 APPENDIX III APPENDIX III INTERAGENCY GEOTHERMALSTREAMLINING TASK FORCE RECOMMENDATIONS 1) Establish a Permanent Task Group to Review and Make Recommendations to Review DOI/DOA/DOE Lease StipGeothermal Regulations and Special ulation Policy Compile a Comprehensive With Flow Diagrams Handbook of Regulations 3) Initiate Federa. sibilities 4) Establish Coordinators, Modify Agreements, and Improve Coordination Among and Within Federal, and Local Government Agencies State, 5) Increase Program Priority Committment to Geothermal Require petitive cipated a Training and Education Program for Field Managers with Management Responin the Geothermal Program for and Management Development a Response Within 30 Days for Non-ComLease Applications and Indicate AntiActions and Time Requirements 7) Require a 30-Day Time Limitation Response to Permit Applications Extension and Rental Suspension With Agency Delay 8) Revise 9) Modify BLM Nationwide-Statewide Geothermal Resource Exploration Bond Form So as To Be Acceptable to All Surface Management Aqencies Geothermal Lease on Post-Lease and Allow Lease Commensurate Form 10) Modify Proposed Power Plant Siting to Clarify Readjustment Rentals Regulations 11) Review Criteria 12) Subject and Revise to Competitive KGRA at the KGKA Designation Normal Adjudication, Issue a NonLease Unless the Area is in a Time of Application 26 APPENDIX III APPENDIX III 13) as an Alternative, Leases Based Upon Provide, Separate Environmental Assessment of Exploration and Development Phases 14) Areawide Environmental AssessUse Generalized, ments Through the Land Management Planning Process in Pre-Lease Review and Detailed Site Specific Studies Only for Post-Lease Actions 15) Expedite the Wilderness/Roadless Review Process and Prioritize Study Areas Where Geothermal Potential is High 16) Provide Preferential Treatment for Local GovernNon-Profit Organizations and ment Entities, Individuals to Use Geothermal Resources for Direct Thermal (Non-Electric) Applications 171 Encourage Concerned 18) Enable Federal Government Agencies to and Use Geothermal Resources Contained Own Lands for Their Own Purposes 19) Urge Prompt Implementation of Recommendations and Provision Capability to Do So DOE to Tier Environmental Assessments with the Loan Guaranty Program the for Develop on Their Foregoing the Needed Note: Sixteen of these recommendations have been approved by the Interagency Geothermal Coordinating Recommendations 7, 12, and 16 have been remanded Council. for further study. 27 APP::NDIx 1v E'OH KELEASE ON UELIVEKY Expected At 9:45 a.m. September 6, 19'/9 Thursday, APPENDIX IV United Before anti piembers of the cover Federal omnibus Geothermal our most recent activities. I also legislation proposed as h.K. 4471, Subcommittee: the opportunity tne proposed on the llivision the Subcommittee on Mines and Mining House Committee on Interior and Insular Affairs on tinnibus Geothermal Legislation I appreciate discuss Office Statement of Louglas L. ~1cCullough Energy and Minerals blrector, Ueputy Plr . Chairmarl States General Accounting 20548 Washington, I).(J. to be here legisiation program. effort this as weil First, involving geothermal the bill Lldall introduced to as our work I would have a few comments about by Chairmen morning like to leasing the omnibus and Santini by Congressman as wail Symms. FEOEKAL GEU'I'HEKMAL LEASING ACTIVI'I'Y At the mittee, leased we looked ror Geothermal out; uelays ot the Chairman at the manner geothermal its lands. are not of i9'/0; the methods 28 Federal Energy lands used to carry has impeded We tlave conciuued themselves Senate Comare Our work was aimed at implementation in the in which development. Steam Act of anu whether on Federal tiny request that tne only leasing the it development and permit- or even the primary reasons kor the slow pace ot geothermal economic whole, be the major and technical impediments are exceptions certainly which believe regulations Accordiny to production to begln near future. or it al1 over million June acres active these oi leases). 1379, Federal resource Deen lands of is sched- in the the end result, over area" tar leased one-halt (KG&%) lands lease, and (about 440,UUU two and one-quarter about have been acres 1974. in considerable otfered have been In addltlorl, l,b'/U,UOII terms effect commercial lands For example, have in first has resulted of non-kGKA lanus about in The into in Calitornia slow, "known yeothernal one-third acres/263 from leasing went issued the Valley out acres) were Enerqy, and leased. mllllon 1.2 of and we are needed. program leases Imperial started oftered Feder;ll (about first energy pace of yeothermal being Federal department in the Although areas the of geothermal in my testimony, improvements to There development. address leasing and the the uled the that 1974, are considered to geothermal to implement in January constraints I will tin the development. remain leased. under As lease of (988 leases). Leasing isdiction, rates however, iZUtUre geothermal of E'eueral could lands under become a matter development Forest of concern (YUU,UUU acres 29 Service ot Forest jur- tar Lands j 1 APClENDIX IV APPENDIX IV are in KGRA's; believe the priority yet only becretary for 43,SOU have been leased). acres of Agriculture needs of promising leasing Forest to set We a higher Servicq geothermal lands. other In addition, have lands relinquished been competitive leases be a management on which are not being (over l/Z decision have expired macle available million problem leases for acres). This the Interior within or non- appears to Department. 1NTEKAGEP;ICY STREAMLINING TASK FORCE REPORT 'i'he President, the Departments procedures of nas conducted a stutty Force members, It and suggestions in January lY74, latlve, regulatory, improve Federal 1479. botn tne the reviews and, since representatives, a series The wnich includes Force geothermal leasing tieothermal nineteen meetings released by Task agen- to solicit its set remedies report of legis- expected to procedures. Council recommendations Streamlining 30 inceptitin, suggested Coordinating 'i'ask Force Interayency its a comprehensive and administrative their of geothermal and Government of public 'I'ask directed an Interagency and problems issues comments. The interagency of of held message, to streamline direction, was formed industry also hdS lY.77 energy and Agriculture to this Force Task April and environmental In response Streamlining sixteen Interior r'or leasing resources. cies, in his 'Task Force approved in January Report and / I APPENDIX IT7 the bills being gressman development fully for Act Steam of 1970 to remove geothermal of reviewed Dy Chairmen recommendations propose Symms Geothermal the introuucea tnese bills it our uncoveren and suggested Therefore, merit solutions as found we beiieve and should that ana revisions to unnecessary they close to we have not incorporate, recommendations. many of in the same problems the Task Force tne Task Force be given the barriers AlthOUgh seems that the Task Force analysis and Con- resources. the most part, Further, Udall/Santini Report. recommenaations have consideration. FROPBSED OMr\i1t3U5---.----_-----_-_ GEGThERMAL LEGISLA'YItiN --.---c--"-------c__---The most significant 4471 anti Chairmen visions for changes Udall's/Santinl's increasing limits for phased leasing Acreage _-_*- limitation ------__-_ leasing the the present acres as proposed in M.ii. in Chairmen Uaall 's/Santini's and geothermal acres consicler it with ant oil increase the pro- setting time anti author izing may be low ~T-KI supports iease acreage in Congressman aesiraDLe yas to 51,LUII acreage lessee 51,200 24ti,d(lU be -- per- state gas, to i-i.R. proceaures. acres proposal botn 1 imits, aecisions, 20,4tiU the in bi I1 appear Federa 1 acreage aria permittiny believes InteKiOK to be found acres, This per state aut without: 31 of an increase course to differs 266,560 acreage acres does not limits do recomlilenci an any overall ot of a combined LUE, also geothermal however r tfley of bill Sy~l,ms bill. to couple I1mits; 546, limitation from oil, and / APPENDIX IV (i.e. total) Although bill limit might Interior believes other parties to totally for of oil mix would deter Vie believe per that state per state --as at while might be non-oil companies while also their geothermal expense unduly presently total resources. industry limitation 740, and its Symms' bills--may companies if they oil, Due to technology, oil developers in an of 20,4b0 Chairmen Uaall's/ for development, further increasing have to do it at the we believe and geothermal a comdevelop- and development the of the geothermal infancy believe acres, oe aggropriate. 32 that is 2Ou,UUO exploration we 51,200 for be excessive Thus, gas, some of the to an overall would in both ana gas development. geothermal limits of over leasing from hinaer geother- the oil ment coula is and an increase on geothermal for leasing limitation concentrating limitation there restrictive worded development that geother- slow a pace. allowing inhibiting of oil dominate the more active too provide could acreage the present and Congressman it companies and smaller some of the provisions Santini's ana non-oil growing from monop- DOE has testified at present, alreaay needed, companies and development. companies industry oil acreage, Udall's/Santini's areas, mal resources H.R. in Chairmen limit geothermal a reasonable binea undevelopea large mal leasing acres plus restrain opportunity acres on developed the proposed olizing the APPENDIX IV increasing as introduced of the in APPENDIX IV APPENDIX IV Time limits for issuing ieases-ana-ier6z$s---e-c.-_------c--Interior, the provisions snould for time be establishea and not gested that environmental turely because argues that reviews of: meeting agencies ana recisions national Unaer not circumstances, since 1975, Expansion Act, quantities local we woula premaAgriculture to sched- conaitions probably reasoning. and concur However, and Interior of 'kreasury unaer found the that these and Agriculture and under security. zation Act found energy of to meet our 1977, supplies the United iuture this authority year, of Section was importing such circumstances the national of early the nation impair security to sug- with are need to it. The Secretary foreign be terminated must have discretion circumstances, and Agriculture's time Interior deaaline. according Interior's recognize decisions goals. normal normal could E fixed for issuance. that and permits than provide an inflexible responsible actions rather should. or permit suggested leases or targets such goals lease have all on processing as goals specifically changing limits ana that requirements, ule ana Agriculture Energy, the presents States increasing a serious and called neecis to eliminate 33 the second 232 of the Trade oil in such so as to threaten Triie Congress, that for that in the DOE Organidependence tnreat for to an threat. on to the energy national program t APPENDIX IV Ar)PENDIX ST7 tie do not of and by itself oil, however, consider their believe, will it is clear overall part plan. of that H.R. allows maturely under credit for time tne million acres land managers experience reclamation other through the about and over lands, working I, to be completed Udall's/Santini's be terminated we feel, pre- give have learned resource nine years a l,uOi, leasing ago, leases a and over later. The a lot about the other resource after tens of years of resource management forest management managers have gained under legislation framework planning considerable stipulations the authority the past 34 ' I on environmental requirements environmental are of and Agriculture does not, Interior's lana action coulci geothermal have learned Ana, resources For Interior managers and Agriculture's systems. are part to act. about 2 l/2 planning should schedule which Chairmen frames land was passed on the public all reviews potential amount for years. the Act inventorying Geothermal application. since values when they plan. one year these For example, considerable issue programs environmental their on imported L up to three that resource anu Agriculture on energy energy lease to argue dependence Interior security 4471 allows on a geothermal the geothermal our over that and resources the nation's bill eliminate the national funds that of course, and of NtPA ana ten years or so. APPENDIX IV It, therefore, shortchanging their ability especially timeframes, their seems that respond to effectively when their responsibility to give to national act can exercise to programs threat which issues. we would Chairman, uncier tight top management priority security In summary kr. APPE##-JCeIJke anu Agricu Interior generally agree E that time limits increasingly process. be neeaed H.R. the clauses occur 4471 by merely beyond the what happens ment. Only time limit time the term of the with if this applications activities are latter when Currently, limit requirement lease equivalent is generally are exceeded permit The Committee happens very rental. frames is reform the obligation bill no action may to consider what time annual time regulatory limits. and by removing when the limits. using address set process may want Udall's/Santini's as submitted" sider the to pay the and development time which the lessee of the Committee extending delay regulatory as part negates Chairmen the energy generally to the time of the However, carefully delays in the to conduct they taken silent on by the Governexploration "deemed to be approved by the Government may wish to carefully clause to provide "teeth" has been considerable attention given within con- to the other requirements. "Staged_-----or phasea" ---------------- leasing There of "staged or phased" leasing which 35 would allow to the the concept separation APPENDIX IV APPENDIX IV ot exploration tne environmental would allow rights for rights and development review the much raster it environmental It proces:;. lancf management they rights, is should reviews argued aqencles knew t:iey thereby staging that to issue this exploration had another opportunity the developer find an eConomiC resource. Both Interi(Jr and kgricultl~rt~ "stageu or phak;eci" leasing believe this Interior feature believes rently exists Departments staged it the the agree with speed in some Instances. also retard nies probatsly with the ever envlronmen that they auministratively. phased for leasing Steam Act oi to ex;-ilJcit statutory the concc:pt of phased up the process--and We woula geothermal would assumption ta accept that L point. cur- 197lJ but both authority for ment, or the amount ot m2.ght be the work ayalnsc are to buy the their under expeustiolus some Lither Inignt Other oi geothermal not in could it could compa- approach "pig-in-the-poke" snveitrnent case. that to comply necessary. if, it a phased wou1.11 be able stipulations nut iJe So wLli.itlg believe For example, a permit they we leasing however, out, development.. mlgnt ces could ot procedures. would ds otherwise authi)rity tieotherisdi~ do not object We would fact, that the concept and ~)c,t~h have testitiied can be lmplerlented under leasing support with what- investors arrange- be as large the latter instan- development. APPENDIX ITJ APPENDIX IV Other leasing -----.----e-L-- ----s---w - provisions Another limit provision future in which known geothermal a well of producing power definition limiting tion. Although in commercial remain, we lower with limit for to capable be the production while believes DOE recommends temperatures which repre- use in electric power genera- the KGRA's in this current country have been technology--few that the prudent man approach as proposed in Chairmen Uaall's/Santini's believe would to an area Interior quantities. and --considering designation (KGRA's) for to be more inclusive most of so designated others to a KGHA is appropriate. bill Finally, we believe alternative bidding and (2) possible ing suitable new KGRAs to resources a reasonable areas bill anu demonstrated resources needs sent Udall's/Santini's resource has been drilled geothermal of electric this Chairmen in a public need to appear of the to be in be time art if F'urtner, public period and not it could call of the for lease of non-KGRA lanas (I) sales follow- are filed for reviewed. Both woula seem to and, given the leasing of geothermal that applications carefully to the premature ten percent leasing period, competition. notice tne provisions competitive add additional state systems notice same land, that process resource needeti appears that encourage 37 development, at this the time would to assure requirement speculation. the for a APPENDIX IV Financial incentives and initiatives -II----------_c-----_I----cI-----l-I woulti financial now to adaress like incentives As I mentioned incentives lopment geothermal development and other initiatives of geothermal energy. with of geothermal And since directly development for DOE should reasons favor We believe incentive its increase for financial those the that funds before and the estimated annual way, would phases of geothermal costs be in a better incentives development. regard, we understand forgivable the most impact or other loans 38 studying In this position to judge initiatives DUE is are best considering the each development, of each incentive. geothermal use of most are enacted, aware of the for possible we would promise fully on which In this economic, any new incentives and decide aiding contribution. in geothermal which and thus the deve- expended. have on all the Congress slowness and/or constraints financial development supply incentives make the Congress could the bills. has proceeded accelerate to help to be technological appear overcome to heip in these several provide of accelerating energy generally would the onjective the primary development would proposed The two bills We agree to some of the and initiatives earlier, at a slow pace. my testimony feasibility (1) the APPENDIX of IV direct APPENDIX use industrial of and sharing to fund provision DOE should impacts provide these annual existing rantee program, assist the had in only program energy provided in made to the limited participation cates and ment a need loan to initiatives in the the the of the four guarantee in carefully effective their estimated 1974 in program 34 to effect ana can timely 1978, 1478. to encourage have and date, geothermal and amendments however, the indi- new incentives geothermal manner. been interest We believe design help gua- on accelerating for of loan resources, increased program aria DGE's expects Act they with guarantees consider that the on aiding loan Tax this for legis- have incentives Energy of geothermal and tax cost- we believe geothermal in participation so that most that development to wells loans in of program. DOE, however, due tie and use an analysis was established Only the Congress, could guarantee development, date. the with out (2) forgivable incentives point which limited to this to commercial geothermal approved loan like by heating geothermal confirmation, how the geothermal Vie would the incentives reservior and of Congress ditferent costs, space ano drilling considered the and accelerating has the Before is for purposes, confirmation. lative energy agricultural grants reservior geothermal IV develop- APPENDIX APPENDIX IV IT7 Other matters relating to financial incentives and initiatives There are two other ment on relating to the in these for and requires approved that within required to the date all 4 months that applications long review its to commentioned than the to be sure regulatory reform other guarantee applications, four be approved loan 11 months from that to review, is or no "fat" agree that time may increasingly process. 40 tied up in some projects may recognizes and is working towards is not not prepared the in limits at this appropriate assessment remains submitted DOE already We are DOE's current to and discourage funds Although frames. approved the date frustrate delays or dis- filing. guarantees as a problem 4 months carefully process to establish of date projects. time suggest regulatory of process but would generally of Energy who have significant review to say that of: loan These and more time We would like and initiatives Secretary of the an average developers reducing time we would such applications approved. geothermal this the processing We have noted require incentives 4471 requires new procedures these which bills. H.K. date matters the period be eyed very review process. in the energy be needed as part of the APPENDIX IV H.R. Energy APPENDIX 4771 Tax tives to Act Electric the purpose One amendment development. Research Institute applications utility this or credit However, passea through to we question commissions, to the is enacted, its to be considered. public impact favor geothermal a hot water could be a substantial consumers whether pleased to that answer they Before on geothermal for the credits. utility, incentive end up regulatory act this as an provision development needs - concludes any would offer involve credits by State utilities. - - I Chairman energy tax credit tax distribution these would tax such the discen- DOE and of if of removing that utilities. would of We understand appears Mr. provisions equipment. an electric incentive for various investment most being 1978 amend 10 percent Power Since also an additional geothermal for of geothermal utilities it woulo IV my prepared questions. 41 statement. We APPENDIX APPENDIX V UNITED ST,&TES DlrPARl MLN rOnCST hEPLY TO. 2820 Leases I 1 'I' SERVICL. AGRiCULl V URE WO and Permits OCT I 1 1979 Reorientation SUE$CT: of Mineral-Related Activ;ties * To; Regional Foresters REPLY DUE DECEWER With the with the minerals While we ness, we litigation substantially .I deepening of our Nation's energy problems, we are faced need for a deliberate Service-wide reorientation of our program, especially in regard to leasable energy minerals. have made great progress ~JI the past few years in effectiveSome of these are reflected in current still have problems. and proposals for legislation, the outcome of which could affect our programs. Our primary concerns at this time are with excessive delays in the processing of lease applications (and similar leasing actions), duplicative stages of reviebir for leasing, aqd too conservative leasing decisions. Our objectives must be to (1) make National Forest System lands available for mineral development at levels commensurate with national needs, (2) make decisions on leasing anC operations promptly * with a minimunl of paperwork and without duplicative reviecs, (3) make our decisions with full consideration of the potential value of mineral deposits, and (4) protect our limited discretionary authority through its prudent application, We understand that some units have been delaying leasing decisions pending completion of land management plans under ti;e National Forest Management Act. That may be a reasonable approach if plans are nearly completed and there is no urgency in the leasing decision. However, leasing decisions need not be delayed pending plan completion. We interpret Section 6(c) of NFMA as allowing continuation of all normal activities by iqhatever plans or process available prior to NFMA. You ma continue to process oil andqas or other lease applicaticns -+l----__ t\rough the FiEFA process whether or .___ not Iear~~rasspecificall~ covered l';;?ormcr plans and regardless of the lack of a completed Forest plan ---I under FiI7;A Several pending legislative bills provide for time 1in:its on leasing/ permitting decisIon5, and for some new or interagency body to have jurisdiction over schedules. The Uepartments of Agriculture and the Interior, in response to this issue, promised--as an alternative--to initiate effective means within our organizstiol\s to accomplish the same purposes, We intend to set reasonable time limits for decisions, 42 APPENDIX APPENDIX V to require prompt scheduling of environmental proposals and notification of applicants if delays in decisions, and to make scheduling through our normal appeal process. We plan to revise the FSM 2820 chapter receiving your comments on the concepts. otherwise, we intend to set the following other reviews there will decisions after Unless we can be persuaded time limits for decisions: For leasing proposals on known geothermal 1. competitive leasing proposals--Z years. . 3. For action on concurrence ne exploration or operations cation) in prelease reviews; as geothermal power plants. l to accomplish this, resource 2. For applications to lease or for simultaneous inqu ries--1 year if not covered by a Land Management ing 1 easing' EAR/EIS; 2 months if so covered. rout imp1 such on leasing be significant appealable V areas leasing Plan or or exist- with operating plans--l month for (directly or by which were considered I year for major development proposals l We presently have a backlog of approximately 6,000 oil and gas lease applications. Some of these have been pending for several years. Our objective is to eliminate this backlog within 2 years, while keeping current (within above-stated time limits) on new applications. Please inform us by December your plans for implementation, J+.&++ 1 of your comments and of the impact adJ--- Ttio/,tAS C. NELSON @?E?;ITY Ck!!E' 43 on these on your issues, of total program. APPENDIX F.?PENDIX V UNITED STATES Drrn~ FOREST I MI:NT OF SERVICE V AGRICULTURE NO ----_-- REPLY TO *"EJ'~~ TO: 2820 Leases Reorientation !Ammend. to Regional In out the --- awl Permits of Mineral-Related 10/11/70 ltr.) Activities Foresters next to reference for last to paragraph a backlog Our applications. period 111 of of intention elimination of sweral is the that backlog LIMITED DISTRIBUTION cc : the NFS (Nelson) NFS (Hilmon) IMP (Snyder) RN IJoy) M&G (Gray) M&G:SGray:cb:10/16/79 Dot. %1148C 44 letter, we inadvwtent1.v hundred the shall time geothermal limits apply left lease and two to all year minerals. Single copies of GAO reports are available free of charge. Requests (except by Members of Congress) for additional quantities should be accompanied by payment of $1.00 per copy. Requests for single should be sent to: copies (without charge) U.S. General Accounting Office Distribution Section, Room 1518 441 G Street, NW. Washington, DC 20548 Requests for multiple with checks or money copies should orders to: U.S. General Accounting Distribution Section P.O. Box 1020 Washington, DC 20013 be sent Office Checks or money orders should be made payable to the US. General Accounting Office. NOTE: Stamps or Superintendent of Documents coupons will not be accepted. PLEASE DO NOT SEND CASH To expedite filling your order, Port number and date in the corner of the front cover. use the relower right GAO reports are now available on microfiche. If such copies will meet your needs, be sure to specify that you want microfiche copies. 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Happy new month In arrears lovely readers. Today I want to share this topic on how to share data on GLO, Airtel and 9Mobile network. I have seen situations where people ask about data sharing on facebook. Sometimes, we do have huge data bundles and they end up wasting because we couldn't exhaust It before the due date. Why let this data waste ?..Perhaps you can share data to your friends and loved ones on any network.
how to share data on GLO networkObviously, we all know that GLO Is the grand master of data. They offer more data than any other network here In Nigeria. So many people do not exhaust they data before the expiring date.
This Is how to share data with friends and family with GLO networks.Simply dial *127*01* your friend GLO number#
E.g *127*01*07085500211#.You can stop data sharing by dialing *127*02*friend GLO number#
how to share data on Airtel networkAirtel smart-share service allows you to share data. Sharing data On Airtel Is very easy. One can share data either In gigabyte or megabyte. You simply need to dial the USSD code. Data sharing on Airtel Is In two phase:
ME2U: You can share data from your current active data bundle.
Data Gifting: You can buy data for your friends.
Simply dial *141# then select option 5 for data sharing or data gifting..
how to share data on 9Mobile network
9Mobile data sharing can be done using USSD code. Simply dial *229*PIN*Data*Friend 9mobile Number#.
E.g: To share 50MB of data, dial *229*1234*50*08090777001#9Mobile default PIN Is (0000) but you can change It by dialing *247*Old PIN*New PIN# ..
I hope you like my article. Sharing Is caring.

subset: commoncrawl


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The NCAA announced that they were suspending Syracuse Basketball coach Jim Boeheim for nine conference games next season and vacating more than 100 of his wins as coach. This decision comes after an investigation of academic fraud that started back in 2005, which raises the question what took so long?
The NCAA announced that Boeheim hired a Director of Basketball Operations to fix their academic problems. The newly hired director's solution was too essentially do the work for the players, which is how one of the first red flags was raised when a player went from ineligible to eligible too quickly. The NCAA also states that the organization wrote papers for players, spoke to professors over email impersonating the players, and even signing up the players for bogus classes that only required a research paper which got high marks no matter what. The players were also given improper benefits, which has been a problem throughout the college system for years, and failure to enforce the drug policy.
It should be stated at this point that University has admitted to breaking and skewing numerous NCAA rules.
In all the NCAA has punished Boeheim by suspending him and taking away wins, but they are also taking away twelve scholarships over four years, the basketball and football programs are on probation for five years, and there will only be two off-campus recruiters allowed to recruit for the university from June 1, 2015 and ending May 31, 2017. Of course, Syracuse has to pony up a lot of money too.
Now Syracuse is not the first university to be dealt such harsh penalties. They join the ranks of University of Miami, whose struggles have been well documented in both The U and The U Part 2 of the ESPN documentary series. It was found in the end that the NCAA had boached the investigation into improper benefits from boosters to the university, could the same be said about the investigation into the Syracuse academic fraud?
Why did the investigation take so long? It's hard to believe that the NCAA could not find any evidence into the academic fraud between 2005 to now. This investigation could be one of the most lengthy investigations in the history of the NCAA, which could have some negative backlash on the organization. Some could claim that the investigation took so long because employees involved might have been afraid to say anything for fear of backlash, but that claim is laughable. Employees could have given the NCAA anonymous tips about the dealings of the organization without there being any backlash, so simply the NCAA took their good old sweet time to do a through investigation and then dropped the hammer.
The last part of this whole scandal is the suspension of Boeheim and the current students. Can you really blame the coach for what the director and his staff were doing? While, it might be hard to believe that Boeheim had nothing to do with it, he might not have known exactly how they were going about getting players academic eligibility up to par. So to suspend him seems as if they just picked the highest profile person in the organization to punish to send the message.
It is then also fair to punish the current and future students of Syracuse for the actions of those that came before them? It's been the problem with investigations and punishments for quite some time. It's as if a young teenager would be punished for the actions of their parents, it would laughable.
The organization should be punished for their actions, there is no doubt about that; but to hurt the current team and future teams reeks of injustice.


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Analysis Workspace use cases
Examples of how to use data tables, segments, and uses case ideas for Analysis Workspace.
You can direct research across your data to answer specific questions and put together narratives about your customer's interactions and audience interests. In a freeform environment you can apply dimensions, metrics, and segments over a time period to directly retrieve targeted data. Craft your analysis to customize for specific questions, and then publish information in rich reports and visualizations to be shared and easily interpreted by even the most time-constrained frontline business user.
- As a media company, you might want to compare your new visitors, your repeat visitors, and your most loyal visitors to see how content consumption changes over time for each different segment.
- Compare the conversion rates for branded and non-branded keywords.
- Break down page views by internal search, external search, landing pages, and so on, to understand why branded and non-branded terms perform differently.
- Compare day against next day to compare columns or rows to analyze growth across multiple metrics.
- Do a simple query such as bounces per a dimension.
Retail Example
Assume you are a marketing analyst for an outdoor gear retailer and you are tasked with examining how a recent Thanksgiving promotion performed, and with making recommendations on how to improve onsite campaigns. This example shows how you can compare campaign revenue data for different segments and add breakdowns to drill down further into the campaign.
- Select the appropriate report suite.
- Search, for example, for your Internal Campaign Placements dimension and drag it into the left-hand section of the table canvas (this data will make up the table rows.)
- Now click the segment icon on the top left and drag different customer loyalty segments into the right half of the canvas. You are going to compare the segments to each other on the fly. These will constitute the table columns.
- Click the Events (Metrics) icon on the top left and add the revenue metric underneath each segment. Notice how the report generates automatically. You can now start comparing campaign revenue for these customer segments.
- Now, if you would like to see which products were most effective in the left banner slot on your pages, break down Left Banner by Product Name. Just click the Dimensions icon and drag the Product name dimension on top of Left Banner.
- But you can drill down even more. You might ask which search terms people used to get to your top-selling product, Norfolk Highland. All you have to do is drag the Internal Search Term dimension on top of the product name:A new breakdown result will appear:You have already broken down the data in a way that can result in recommendations and cross-sells for your merchandising teams to implement in other campaigns and realize even more revenue for your company. You can do further breakdowns until you get the results you are looking for.Now you can share the report with those merchandising teams.


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Press Ctrl / CMD + C to copy this to your clipboard.
This post will be reported to the moderators as potential spam to be looked at
We have products that use variants (for size and colour).
We have just found that when using Courier to copy those products from one environment to another - the Variant data does not transfer happily :-(
Is there, by any chance, an existing Courier extension to handle Variant data?
Where is the Variant data stored?
Hi Gordon,
The variant data is saved in a property on the node. It's saved as a text json blob.
To my knowledge there's no courier extension made.
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text: Cavatina GW, a company from Cavatina Group, as the general contractor, has commenced construction of the multi-functional complex Global Office Park in the area of Mickiewicza, Sobieskiego, Dąbrówki and Zabrska streets in Katowice. Let us recall that the enterprise is going to entail the construction of a complex with an area of over 86,000 sqm, where 60,000 sqm will be taken up by office space, and the remaining part by over 670 flats. Design works have been carried out by the company's in-house architects, including Jan Juraszczyk. ■


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I am the original owner of this true Safe Queen. Bought 9 years ago. Exactly 21 rounds have been fired down the barrel, all at the range. There is not a mark on her anywhere. Obviously can't call it New since I have shot it, but if there is such thing as a 99% rating, then this firearm gets it.
Here's what's included:
- - Winchester Model 70 Featherweight with Original Box
- - Baraska 3-12x56 IR scope (illuminated Reticle) with mounts & rings
- - 8 boxes of .308 Win ammo (see photo for specifics) Note: One box has 19 rounds in plastic case
Price is $875 for a local transfer at FFL if you are a NYS resident. I am in Westchester County, NY and will travel up to an hour.
Otherwise, we would need to figure out exact shipping charge for gun & ammo to your FFL in contiguous 48 and scope to you (would need to remove from firearm to ship).
Not interested in any trades.


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