GAO

United States General Accounting Office

Report to the Chairman, Subcommittee 

on Government Management, 

Information, and Technology, Committee 

on Government Reform, House of 

Representatives

September 2000 NATIONAL PARK 

SERVICE

Agency Should 

Recover Costs of 

Validity Examinations 

for Mining Claims

GAO/RCED-00-265

Page 1 GAO/RCED-00-265 National Park Service

Contents

Letter 3

Appendixes Appendix I: Validity Examination Tasks and Time Requirements 16

Appendix II: Comments From the Department of the Interior 17

Appendix III: GAO Contacts and Staff Acknowledgments 18

Tables Table 1: Mining Claims Located on Land Managed by the Park

Service 6

Table 2: Estimated Costs Associated With Seven Validit

Examinations Performed by Park Service Personnel in the 

California Desert Parks, Fiscal Year 1995 Through

June 1, 2000 9

Table 3: Costs of Fieldwork and Report Preparation Associated

With 10 Validity Examinations Performed by Contractors

in the California Desert Parks, Fiscal Year 1995 Through

June 1, 2000 10
Page 2 GAO/RCED-00-265 National Park Service
Page 3 GAO/RCED-00-265 National Park Service

United States General Accounting Office

Washington, D.C. 20548

Resource, Community, and

Economic Development Division

B-285504 Letr

September 19, 2000

The Honorable Stephen Horn

Chairman

Subcommittee on Government Management,

Information, and Technology

Committee on Government Reform 

House of Representatives

Dear Mr. Chairman:

The notion of mining operations in the national parks may be surprising to 

many people.1

 However, in 1999 there were 50 private mining operations in 

16 parks, including 17 operations on mining claims located under the 

Mining Law of 1872. While all parks are now closed to location of new 

mining claims, many mining claims, which represent possible private 

property rights that could be developed in the future, exist on national park 

lands. For example, there are about 875 such mining claims on public land 

in the three national parks established by the California Desert Protection 

Act of 1994—Death Valley National Park, Joshua Tree National Park, and 

Mojave National Preserve.2

 In order to conduct mining operations on an 

existing claim, a claimant must, among other things, demonstrate the 

discovery of an economically valuable mineral deposit and submit a plan of 

mining operations for approval. The National Park Service (Park Service) 

verifies the existence of such deposits in national parks by conducting or 

contracting for reviews, which are called validity examinations. Park 

Service policy requires that a validity examination be conducted before 

approving a claimant’s plan of operations, which is a proposal to begin 

mining activities. Park superintendents may initiate examinations, even 

without a proposal to begin mining activities, to address environmental 

concerns on specific claims, among other reasons.

1

 In this report parks means any unit of the National Park System. 

2

 In this report a mining claim refers to an “unpatented” claim for which title remains with 

the federal government because the claimant has not gone through the process of 

“patenting” the claim and thereby receiving title.
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The Park Service conducts these examinations under an interagency 

agreement with the Bureau of Land Management (Bureau), which has 

primary responsibility for managing mining claims on public land.3

 Validity 

examinations consist of (1) an administrative review of the Bureau’s mining 

claim records to determine whether the claimant has complied with all 

pertinent laws and regulations, (2) a mineral examination of the claim site 

(fieldwork) to assess whether the claimant has discovered an economically 

valuable mineral deposit, and (3) a detailed mineral report prepared by the 

examiner. If an examiner finds that a claimant has not complied with 

requirements or that the mineral deposit on a claim cannot be mined 

economically, the Park Service will seek to have the claim eliminated by 

requesting that the Bureau declare the claim invalid. Validity examinations 

can take from several months to more than a year to complete because of 

their technical and complex nature and legal appeals from claimants can 

add more time to the process.

Concerned about the federal costs of conducting validity examinations at 

the three California Desert parks, you asked us to determine (1) whether 

data are available on the Park Service’s costs of conducting validity 

examinations at these parks since 1994 and (2) whether the Park Service 

recovers the costs of such examinations from claimants. 

Results in Brief The Park Service does not know how much it is spending to conduct 

validity examinations because it does not routinely track the direct costs of 

examinations—such as examiners’ salaries and time—and does not have a 

system to allocate the appropriate indirect costs—such as fringe benefits, 

supplies, and utilities. Although it cannot produce an accounting of its 

actual expenses, the Park Service estimated it has spent about $668,000, 

primarily on direct costs, for the 17 validity examinations it has initiated at 

the three California Desert parks: about $281,000 on contracts for 

fieldwork (for 10 examinations) and about $387,000 on examiners’ salaries, 

travel, and mineral tests (for 7 examinations). These estimates are less than 

the full costs, however, because the Park Service has not determined all of 

its direct or indirect costs that can be attributed to the examinations. 

The Park Service does not recover any costs of its validity examinations 

from claimants. The Secretary of the Interior is authorized to establish 

3

 Both the Bureau and the Park Service are agencies within the Department of the Interior.
B-285504

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reasonable charges for processing documents relating to public lands. 

Relying on this authority, the Department of the Interior’s (Interior) 

Solicitor issued an opinion in December 1996, stating that the Bureau’s 

costs of processing mining documents, including validity examinations and 

plans of operations, can and should be recovered from claimants. The 

Bureau has drafted regulations—which are expected to be published in the 

Federal Register in fall 2000—to recover various costs incurred in 

managing its minerals program, including the costs of its validity 

examinations. Interior officials believe that the Park Service also could 

recover the costs of a validity examination when a claimant has submitted 

a plan of operations, and the Park Service has been working with the 

Bureau to be included in the regulations. However, 7 of the 17 examinations 

initiated by the Park Service since 1994 were not undertaken to process 

and approve claimants’ plans of operations but were instead initiated by 

park superintendents for other reasons, such as a need to address 

management or environmental problems posed by particular claims. Such 

problems include, for example, unauthorized occupancy of a claim site or 

destruction of habitat for the desert tortoise, a threatened species. 

According to Interior’s Office of the Solicitor and Park Service officials, it 

has not been determined whether the Park Service can recover the costs of 

such discretionary validity examinations. Furthermore, the Park Service 

has no written guidelines to guide its park superintendents in making 

decisions about when it is appropriate to initiate discretionary 

examinations.

This report makes recommendations for the Park Service to (1) develop an 

accurate accounting of the costs of its validity examinations, (2) take steps 

to recover the costs of validity examinations to the extent allowed by law, 

and (3) develop guidance that describes the circumstances under which 

discretionary validity examinations—for which costs may or may not be 

recoverable from claimants—are appropriately initiated. We provided 

Interior with a draft of this report for its review and comment. Interior 

agreed with the report’s recommendations and stated that the Park Service 

will work closely with the Bureau and other Interior offices to determine 

the most efficient and effective means to implement them.
B-285504

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Background Under the Mining Law of 1872, as amended, individuals or parties who 

comply with pertinent laws and regulations may locate one claim or more 

than one claim, which is called a claim group, to mine certain minerals—

such as gold, silver, and copper—on public lands. For example, at the 

Mojave National Preserve, individual claim groups contain from 2 to 88 

claims and vary in size from 5 to almost 3,000 acres. Public lands on which 

mining claims may be located may subsequently be designated as National 

Park System or wilderness lands, and no new mining claims can be located 

on these park and wilderness lands. For example, the California Desert 

Protection Act of 19944

 designated over 9 million acres for three national 

parks—Death Valley National Park, Joshua Tree National Park, and Mojave 

National Preserve—and 69 wilderness areas in the California Desert. While 

new mining claims cannot be located on these designated lands, claims that 

existed prior to designation continue to exist and can be mined after the 

Park Service approves their plans of operations. There are 11 national 

parks that contain about 1,200 preexisting mining claims on public land; 

about three-quarters of these claims are in two of the three California 

Desert parks, as shown in table 1. 

Table 1: Mining Claims Located on Land Managed by the Park Service

Source: Data provided by the Park Service as of June 1999.

4

 P.L.103-433, Oct. 31, 1994.

Park State Number of claims

Mojave National Preserve California 584

Death Valley National Park California 292

Yukon − Charley Rivers National Preserve Alaska 129

Denali National Park and Preserve Alaska 115

Wrangell − St. Elias National Park Alaska 27

Bering Land Bridge National Preserve Alaska 17

Great Basin National Park Nevada 10

Bighorn Canyon National Recreation Area Montana 5

Kenai Fjords National Park Alaska 3

Joshua Tree National Park California 1

Saguaro National Park Arizona 1

Total 1,184
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Park Service data indicate that the number of claims in the parks has 

declined over time. For example, the Park Service estimated there were 

about 2,400 claims within the boundary of the Mojave National Preserve 

when it was designated in 1994. By June 2000, the number of claims at the 

Preserve had declined to about 600. Park Service officials attributed this 

decline to claims having been eliminated through an active program to 

determine the status of claims within the parks and to claimants having 

forfeited their claims by failing to pay a required $100 per claim annual 

maintenance fee. According to Park Service officials, claimants have also 

been encouraged to donate claims to the park to protect park resources. 

Within national parks, because mining operations may conflict with the 

Park Service’s preservation and conservation mission, the Park Service is 

responsible for the oversight of mining claims. The Mining in the Parks Act 

of 1976 makes all activities resulting from valid mining claims within any 

area of the National Park System subject to regulations prescribed to 

preserve and manage those park areas, and the Park Service has issued 

regulations to implement the act. The Bureau is responsible for developing 

and promulgating policies for administering the mining laws on public 

lands, including conducting validity examinations. Through an interagency 

agreement, the Park Service agrees to perform validity examinations of 

mining claims in national parks, but the Bureau retains responsibility for 

approving the examinations. The Bureau also provides guidance and 

requirements for validity examinations and certifies federal mineral 

examiners. The Park Service’s mineral examiners conduct validity 

examinations and oversee any examinations performed by contracted 

examiners.

To conduct mining operations in the parks, a claimant must, among other 

things, demonstrate the existence of a valuable mineral deposit capable of 

sustaining a profitable mining operation. However, historically, many 

claimants hold their claims without discovering such deposits or 

conducting any significant mining operations. Before claimants begin 

development activities, Park Service regulations require that they submit, 

and obtain Park Service approval of, a plan of operations. The plans are to 

contain, among other things, a description of the proposed mining activity 

and a plan for reclaiming the mine site. As part of the approval process, 

Park Service policy requires a validity examination to verify that there has 

been a discovery, by the claimant, of a valuable mineral deposit. 

Furthermore, the California Desert Protection Act requires the Secretary of 

the Interior to determine the validity of claims at the Mojave National 

Preserve before approving any plan of operations; the act did not impose 
B-285504

Page 8 GAO/RCED-00-265 National Park Service

this requirement on the other two parks. In addition to conducting validity 

examinations to process and approve plans of operations, park 

superintendents may initiate validity examinations for other purposes—for 

example, to address environmental concerns such as threats to wildlife 

habitat that could result from mining activities on specific claims. 

If the Park Service finds, on the basis of a validity examination, that the 

mineral deposit is not economically valuable, the Park Service can request 

that the Bureau declare the claim invalid, meaning that the claim can be 

legally extinguished. However, claimants who disagree with the finding can 

contest the Bureau’s decision and may appeal to the Interior Board of Land 

Appeals and ultimately to federal court. This process can result in lengthy 

administrative and judicial proceedings. If, on the other hand, the claimant 

has met all requirements and the mineral deposit is found to be 

economically valuable, the claim is valid and mining operations may occur 

subject to Park Service regulations; alternatively, the Park Service may 

preclude mining through a buyout of the claimant’s property right interest 

at fair market value. For example, the Park Service recently negotiated to 

acquire six valid claims located in an environmentally sensitive wilderness 

area for $2.5 million. 

The Park Service Does 

Not Know How Much 

Its Validity 

Examinations Cost

The Park Service does not know the full cost of its validity examination 

program. The agency does not routinely track the direct costs of the 

examinations it conducts—such as the examiners’ time and salaries—nor 

does it have a system under which it accurately identifies or allocates the 

appropriate indirect costs to the program. Indirect costs could include 

those for items such as fringe benefits (medical insurance and retirement), 

physical overhead, supplies, and utilities. Because of the technical and 

contentious nature of mining claims, the validity examination process is 

lengthy and detailed (see app. I), and the direct and indirect costs of the 

examinations are likely to be substantial. In response to our request, the 

Park Service developed an estimate of the costs associated with the 17 

validity examinations that it has initiated at the three California Desert 

parks since the passage of the California Desert Protection Act of 1994. For 

examinations conducted by Park Service examiners during this period, the 

Park Service estimated direct costs and some, but not all, indirect costs. 

This estimate included examiners’ salaries for conducting fieldwork and 

writing reports, costs for travel and mineral tests, and 26 percent of the 

examiners’ salaries to reflect employee benefits. Table 2 shows the Park 

Service’s estimated total costs of about $387,000 for the seven 

examinations, which ranged from about $104,000 to $21,000. Park Service 
B-285504

Page 9 GAO/RCED-00-265 National Park Service

officials attributed the range in costs to the unique nature of each 

examination, including the number of claims that were examined, the type 

of mineral deposit, the extent and type of exploration or mining activity, 

and the remoteness and accessibility of the claim site. 

Table 2: Estimated Costs Associated With Seven Validity Examinations Performed by Park Service Personnel in the California 

Desert Parks, Fiscal Year 1995 Through June 1, 2000

a

A contractor performed most of the examination at a cost of about $75,000. 

b

The report was not written because the examination was halted when the claimant failed to pay the 

maintenance fees for 1999.

Source: GAO’s analysis of data provided by the Park Service.

The Park Service also provided costs for the contracts it awarded for 

fieldwork and report preparation associated with the other 10 mineral 

examinations it initiated at Mojave National Preserve and Joshua Tree 

National Park since the passage of the California Desert Protection Act of 

1994. Park Service examiners monitor these contracts, review the validity 

examination reports prepared by the contractors, and develop report 

conclusions and recommendations. The costs of these or other associated 

services provided by Park Service personnel are not included in the 

contract data the Park Service provided to us. Table 3 shows the Park 

Service’s contract costs totaled about $281,000 and ranged from about 

$57,000 to $13,000. Again, Park Service officials attributed the range in 

costs to the unique nature of each examination. 

Estimated costs

Name of claimant or 

claim group Park

Number of

claims Fieldwork Reporting Travel Testing Total

Golden Quail Mojave 16 $14,000 $83,000 $4,000 $2,850 $103,850

Volco Mojave 9 7,800 15,600 2,000 75,250a 100,650

Rainbow Talc Death Valley 6 11,500 45,200 4,000 4,220 64,920

Blair Mojave 7 6,400 34,600 3,000 490 44,490

U-Thor Joshua Tree 3 3,600 23,400 1,000 450 28,450

J.O . Death Valley 7 10,900 0b 4,000 9,135 24,035

Lucky Day Mojave 2 6,650 13,640 0 700 20,990

Total 50 $60,850 $215,440 $18,000 $93,095 $387,385
B-285504

Page 10 GAO/RCED-00-265 National Park Service

Table 3: Costs of Fieldwork and Report Preparation Associated With 10 Validity 

Examinations Performed by Contractors in the California Desert Parks, Fiscal Year 

1995 Through June 1, 2000

a

The examination was not completed because the Bureau declared the claim null and void for other 

reasons. 

Source: Data provided by the Park Service.

The Park Service Is 

Seeking to, but Does 

Not Yet, Recover the 

Costs of Its Validity 

Examinations

The Park Service is seeking to recover the costs of its validity 

examinations. The Secretary of the Interior is authorized to establish 

reasonable charges—or user fees—for processing documents relating to 

public lands. Relying on this authority, Interior’s Solicitor issued an opinion 

in December 1996 concluding that the Bureau should recover the costs of 

processing mining-related documents, including plans of operations and 

the costs of validity examinations, from claimants. Because the Park 

Service conducts validity examinations in national parks under its 

interagency agreement with the Bureau, officials in the Solicitor’s Office 

believe that the Park Service should also recover these costs. This position 

is consistent with Interior’s policy, which states that agencies should 

recover, to the extent authorized by law, the costs of activities that provide 

a special benefit to a nonfederal recipient above and beyond those benefits 

that accrue to the general public. 

Name of claimant or claim 

group Park

Number of

claims Contract cost

Soda Lake Mojave 4 $57,400

Barnett Mojave 8 40,353

Moonstar Mojave 8 39,723

Telegraph Mojave 12 28,808

Coxcomb Eagle Joshua Tree 1 27,126a

Oro Fino Mojave 12 26,813

Maxfield Mojave 19 17,541

Gyron Mojave 1 15,505

M.H.B.G. #5 Mojave 1 14,088

Storm Jade Joshua Tree 1 13,291

Total 67 $280,648
B-285504

Page 11 GAO/RCED-00-265 National Park Service

The Bureau is drafting regulations that will, among other things, require it 

to recover the costs of validity examinations undertaken when claimants 

submit plans of operations to begin mining. However, Park Service officials 

we contacted were unaware of the Bureau’s efforts in this regard until we 

told them. The Park Service then initiated discussions with the Bureau and 

Interior’s Solicitor seeking to clarify and amend the draft regulations to 

cover validity examinations performed by the Park Service. The Bureau 

anticipates it will publish the draft regulations in the Federal Register for 

public comment in fall 2000. The draft regulations do not specifically 

provide for recovery of the cost of examinations conducted by the Park 

Service. However, they leave open the possibility that the Bureau—the 

agency responsible for promulgating policies on validity examinations—

may, in the final regulations, require claimants to reimburse the Bureau for 

both agencies’ validity examinations. The agencies would then have to 

establish a means for the Park Service to recoup its costs from the Bureau, 

for example, through an Economy Act transaction.5

 Officials from the 

Solicitor’s Office said that the Park Service, as an alternative to being 

included in the Bureau’s draft regulations, could issue similar regulations of 

its own. However, the Park Service’s position is that it would be most 

expedient and efficient to the government and claimants for the Bureau to 

include the Park Service in the final rule rather than having two sets of 

regulations and processes for claimants to follow. 

The Park Service’s discretionary validity examinations—that is, 

examinations that are not initiated to process and approve plans of 

operations submitted by claimants—are not covered by the Bureau’s draft 

regulation. Officials from the Solicitor’s Office said that they have not 

specifically addressed whether the Park Service is authorized to recover 

the costs of discretionary examinations. They and Park Service officials we 

contacted were uncertain whether or not recovery for such examinations is 

possible. Seven of the 17 validity examinations initiated by the Park Service 

since 1994 were discretionary and were initiated by the park 

superintendents.

The Park Service has no internal written direction or guidance on when to 

initiate such discretionary examinations. When no plan of operations is 

submitted, park superintendents have broad discretion in deciding whether 

and when to initiate such validity examinations. Park officials provided a 

5

 The Economy Act provides authority for agencies to enter into reimbursable agreements to 

furnish materials or to perform work or services.
B-285504

Page 12 GAO/RCED-00-265 National Park Service

variety of reasons for initiating these discretionary examinations, including 

(1) ascertaining whether nonfederal property rights, that is, a valid mining 

claim, exist in the park and (2) addressing management or environmental 

problems posed by particular claims. For example:

• In one case, a claimant constructed a cabin and several other structures 

on the claim site and conducted some mining activities. However, the 

claimant had been using the site primarily for recreational purposes for 

many years before the land was designated by the Congress as Park 

Service wilderness. The Park Service believes that the claimant does not 

have a right to occupy the site and has initiated a validity examination. If 

the examination proves that the claim is invalid and this conclusion is 

upheld, the Park Service would then possess full rights to the land in 

order to manage it as wilderness.

• In another case, the claims are in an environmentally sensitive area, in a 

desert wilderness as well as on a national natural landmark. Mining 

operations here would also disturb fragile habitat for the desert tortoise, 

a threatened species. The Park Service is conducting a validity 

examination to determine if the claims contain a mineral deposit that is 

economically valuable and meet other requirements, and thus are valid; 

if not, the claims could be extinguished. 

Without any written direction or guidance on initiating discretionary 

validity examinations, we found a wide range of opinions within the Park 

Service about their appropriateness. Several officials believe the Park 

Service should systematically conduct validity examinations on all claims 

located in the national parks regardless of whether claimants submit plans 

of operations. These officials noted that it is important to obtain a clear 

title to park lands to better protect and manage resources; it is less 

expensive to do examinations in the near term, thus avoiding possible 

future cost increases; and there is greater likelihood that claimants will 

relinquish claims they believe have marginal value, knowing that a validity 

examination will be performed. Other Park Service officials said that 

validity examinations should not be conducted unless a plan of operations 

has been submitted or activity on a specific claim presents a serious threat 

to park resources. These officials noted that there is little or no activity on 

most claims and thus they do not pose an immediate threat to park 

resources; many claims of this type are likely to be relinquished over time; 

examinations may prove a claim to be valid when it might have otherwise 

been relinquished; and examinations themselves may disturb some park 

resources. An official in Interior’s Solicitor’s Office said that there is no law 
B-285504

Page 13 GAO/RCED-00-265 National Park Service

or regulation that requires the Park Service to generally perform 

examinations other than those needed to process a plan of operations.6

Conclusions The Park Service does not recover the costs of its validity examinations 

from claimants who submit plans of operations but is beginning to explore 

the possibility. And, by not accounting for the costs of the examinations, it 

is not in a position to recover the costs. Furthermore, seven of the 

examinations at the three parks since 1994 were conducted at the park 

superintendents’ discretion, and it is uncertain whether the Park Service 

can recover the costs of discretionary examinations. In addition, there is no 

guidance that describes when it is appropriate for the Park Service to 

conduct such discretionary examinations.

Recommendations for 

Executive Action

We recommend that the Secretary of the Interior require that the Director 

of the Park Service 

• develop an accurate accounting of the costs of its validity examinations,

• take steps to recover the costs of validity examinations to the extent 

allowed by law, and

• develop guidance that describes the circumstances under which 

discretionary validity examinations—for which costs may or may not be 

recoverable from claimants—are appropriately initiated.

Agency Comments We provided Interior with a draft of this report for its review and comment. 

Interior agreed with the report’s recommendations and stated that the Park 

Service will work closely with the Bureau and other Interior offices to 

determine the most efficient and effective means to implement them. 

Interior’s comments are in appendix II.

To obtain data on the cost to the Park Service of conducting validity 

examinations at the parks established by the California Desert Protection 

6

 He noted that an exception was provided in the Mining in the Parks Act of 1976, which 

required the Park Service to determine the validity of all unpatented claims in Death Valley 

National Monument—now Death Valley National Park—and certain other parks within 2 

years of enactment. 
B-285504

Page 14 GAO/RCED-00-265 National Park Service

Act of 1994, we obtained and compiled cost estimates for validity 

examinations performed since 1994 (as of June 1, 2000) from Park Service 

officials at the Geologic Resources Division in Denver, Colorado, and at 

those parks. We discussed the development of these costs and the tasks 

and time requirements for validity examinations with certified mineral 

examiners. To determine whether the Park Service can recover its costs of 

conducting validity examinations, we reviewed pertinent laws, regulations, 

and policy and procedural manuals. We discussed these requirements with 

the Chief of the Park Service’s Policy and Regulations Branch of the 

Geologic Resources Division, Bureau headquarters officials, and the 

Interior’s Office of the Solicitor headquarters officials. We also visited 

mining claims at the Mojave National Preserve and Death Valley National 

Park and interviewed Park Service representatives at both parks. We 

conducted our review from May through August 2000 in accordance with 

generally accepted government auditing standards. 

As requested, unless you publicly announce its contents earlier, we plan no 

further distribution of this report until 30 days from the date of this letter. 

At that time, we will send copies of this report to the Honorable Jim Turner, 

Ranking Minority Member, Subcommittee on Government Management, 

Information, and Technology, House Committee on Government Reform; 

the Honorable Bruce Babbitt, Secretary of the Interior; the Honorable 

Robert Stanton, Director of the National Park Service; the Honorable 

Thomas Fry, Director of the Bureau of Land Management; and other 

interested parties. We will also make copies available to others upon 

request.

If you or your staff have any questions about this report, please call me at 

202-512-3841. Key contributors to this report are listed in appendix III.

Sincerely yours,

Jim Wells

Director, Energy, Resources,

and Science Issues
Page 15 GAO/RCED-00-265 National Park Service
Page 16 GAO/RCED-00-265 National Park Service

Appendix I

Validity Examination Tasks and Time Apendxies

Requirements ApendxiI

Tasks to be completed Time needed

Records research 2 to 3 weeks

Check Bureau of Land Management database and claims files to determine if a claim is administratively current.

Research county records.

Contact claimants to resolve discrepancies or inconsistencies.

Preliminary literature search 2 to 4 weeks

Obtain appropriate maps, commodity data, production history, and geologic reports.

Contact industry and agency information sources.

Field examination preparation 2 weeks

Send letter to claimant giving 30-day advance notice of the field examination.

Arrange logistics and travel, develop sampling strategy, and assemble and pack field equipment and materials.

Field examination 2 to 3 weeks

Contact claimant to identify claim boundaries, discovery points, sample points, and workings.

Traverse claims and photo-document survey claim corner and discovery monuments.

Generate map with geology, topography, surface features, and sample sites.

Map, describe, and photo-document workings.

Describe geologic structures, mineralization, ore deposit, associated mill sites and facilities.

Take samples and photo-document them, following established protocol.

Assay and laboratory analysis 2 to 8 weeks

Deliver samples to assayer or laboratory.

Analyze and interpret results.

Report preparation 4 to 6 months

Research literature on site geology, mining history, exploration, Park Service documents.

Research laws, Park Service and Bureau of Land Management policies, Interior Board of Land Appeals.

Research appeal decisions, other federal and state decisions.

Prepare photos, maps, and illustrations.

Prepare economic evaluation: ore volume, assay and market analyses, and cost calculations.

Prepare draft report and obtain internal review.

Bureau of Land Management review 2 to 4 weeks

Assemble and mail report for Bureau of Land Management review.

Bureau reviews report and returns for revision.

Edits, corrections, and final Bureau approval 2 to 4 weeks

Revise draft and return for second Bureau review.

Finalize and mail to Bureau and claimant.

Total time needed 8 to 13 months
Page 17 GAO/RCED-00-265 National Park Service

Appendix II

Comments From the Department of the 

Interior ApendxiI
Page 18 GAO/RCED-00-265 National Park Service

Appendix III

GAO Contacts and Staff Acknowledgments ApendxiI

GAO Contacts Barry T. Hill, (202) 512-3841

Sue Ellen Naiberk, (303) 572-7357

Acknowledgments In addition to those named above, Arleen L. Alleman, Brian W. Eddington, 

Richard P. Johnson, William J. Temmler, and William F. Wright made key 

contributions to this report.

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