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We support a timber appraisal system which is fair to all purchasers 

 a nd the Government . 



The current T.E.A. (Transaction Evidence Appraisal) system in use in 

 USPS Region II has been subject to gerry mandering and arbitrary interpretation 

 by Regional Forest Service officials. This has resulted in improper appraised 

 rates and a upward ratcheting effect on timber prices. We need and support 

 a reasonable, simple, and sensible appraisal system which will allow legitimate 

 competition to determine fair market rates. 



Another Item related to timber sale appraisals is the manufacturing 

 point to which timber is appraised. Traditionally the Forest Service has 

 appraised timber sales to the nearest operation facility with reasonable 

 capability and capacity to manufacture the quantity being offered. Recently 

 Regional Forest Officers have arbitrarily designated appraisal points which 

 have no f acilitles-merely to force a higher than proper appraised rate. Two 

 speclTTc examples of this situation are the use of Kremmllng, Colorado and 

 Custer, South Dakota, As appraisal points when neither have facilities capable 

 of handling Forest Service sales. 



Continental Lumber Co. Inc. appreciates the opportunity to enter these 

 comments in the Record. If indeed the Government cares about the Small Business 

 community, it must help instead of hinder the overall climate in which we 

 operate and try to survive. 



Maurice Williams 

 General Manager 



