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EMD-81-70 1 (1981-04-02)

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APRIL 2. 1981


B-202645


The Honorable James G. Watt     t,33

Secretary of the Interior      D

Dear Mr. Secretary:


     Subject: Questions Concerning Proposed Utah Power and
               Light Company Coal Lease Exchange (EMD-81-70)

     As you know, we have been reviewing the proposed Utah
Power and Light Company coal lease exchange--involving the
relinquishment of preference right lease applications (PRLAs)
for coal in southern Utah in return for coal leases in central
Utah. We plan to have a draft report ready for the Department's
review on this matter sometime in April. But, meanwhile, we
understand you may be close to making a decision which could
consummate such an exchange, perhaps even before our April
draft. Thus, in advance of our draft report which will provide
a full treatment of our evaluation, we would like to highlight
some concerns we have about the desirability of making the
exchange. Basically our concerns boil down to:


--A question concerning the validity of the
  PRLAs themselves.

--The lack of data, particularly on coal
  reserves, for making the required equal
  value determination.

--The effect giving over highly desirable
  coal lands in central Utah would have on
  opportunities for competitive leasing in
  that area.


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     Most basically, we believe there is an unanswered question
as to whether Utah Power and Light Company has a valid right to
be issued a preference right lease--thus whether an exchange
is even appropriate. This has never been resolved. The prior
administration entered into an exchange agreement with the
company and began its evaluation on the basis that this ques-
tion did not need to be addressed because Congress authorized
the exchange. However, the Congress expressed its intent that
before accepting the PRLAs the Secretary would first satisfy

                                                    (008970)


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ENERGY AND MINERALS
    DIVISION


UNITED STATES GENERAL ACCOUNTING OFFICE
        WASHINGTON, D.C. 20548


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