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ments, which would make it more difficult to just file automatic 

 appeals. Those amendments have failed. The question is what is 

 the standard used by the Sierra Club or others in filing these ap- 

 peals? 



Mr. Brademeyer. We assume that when the Congress of the 

 United States passes a law, they expect it to be obeyed. We assume 

 that vv^hen the forest plans, State regulations and what they will 

 maintain for quality on the forest, that they will follow through. 

 Appeals could be entered tomorrow. The Forest Service would obey 

 the law. The Congress would direct the Justice Department to en- 

 force the law. 



Senator Pressler. Well, I don't want to get into a debate here, 

 but I think the appeals process is open and if you feel that there's 

 something being violated 



Mr. Brademeyer. You can file frivolous appeals. There are ap- 

 peals on small business set aside actually. It's one out-of-State cor- 

 poration on one side versus another out-of-State corporation on the 

 other. Anyone can file appeals. If you don't cite violations of the 

 law, you will not get anywhere. 



Senator Pressler. What I'm trying to get to here is how can we, 

 in a positive way, fix this process so that appeals would be filed 

 only when there's an actual, substantive objection to a particular 

 sale? To file an appeal against every proposed sale seems to be an 

 abuse of process. Maybe the law invites that. If it does, it should be 

 changed, and we've tried to change it. I'm not trying in any way to 

 put you down or argue here, but what can we do to improve that 

 process so that when the Sierra Club has a substantive objec- 

 tion 



Mr. Brademeyer. We have substantive objections. We've been 

 raising them for 3 years. We haven't got a substantive response. 

 Have the Forest Service answer the questions. 



Senator Pressler. Could I ask what criteria the Sierra Club used 

 in determining which areas should be considered for the wilderness 

 proposal? 



Mr. Brademeyer. Those required by law, 5,000 acres with rela- 

 tively unengineered roads in them, which were the only ones in the 

 Black Hills were those six. 



Senator Pressler. Mr. Satrom, The Nature Conservancy, I be- 

 lieve, owns properties in South Dakota. How are these properties 

 managed with respect to livestock and watershed, and what are the 

 long-range goals with respect to placing additional South Dakota 

 properties under control of The Nature Conservancy? 



Mr. Satrom. Well, first of all, we — the buzzword of the hearing is 

 multiple use, and I've been thinking I suppose a majority of our 

 larger properties represent multiple use because we have — in addi- 

 tion to the conservation function of those properties, we do have 

 generally grazing and in some cases haying contracts. In a number 

 of our preserves, we also have hunting on a very limited basis — or 

 a controlled basis, I should say, because they are often small pre- 

 serves where we feel there is some endangerment of participants. 



With respect to our long-term goals, we view ourselves as an or- 

 ganization that will probably have staff in western South Dakota 

 within the next several years and have been actively looking at 

 properties for some time. Perhaps some people here are aware that 



