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GRFS has long been recognized as being cumbersome and expensive to 

 administer. More importantly, it cannot be demonstrated that the 

 GRFS represents "fair market value" as required by the 19 86 Act. 

 Accordingly, on July 13, 1995, the Department published a proposed 

 policy in the Federal Register that would replace GRFS with a new 

 permit fee system. 



The proposed system improves on GRFS in two significant ways. 

 First, it attempts to estimate "fair market value" for ski areas 

 and is based on site-specific appraisals of the use of National 

 Forest System lands by ski areas- -a necessary step in determining 

 "fair market value." Secondly, it would eliminate the need for 

 burdensome audits of ski area assets and revenues making it 

 simpler and less costly to administer. Current plans call for the 

 new system to be in place for fiscal year 1997. 



Our proposed system has not been tested. Because of the nature of 

 the appraisal process, some parties may not agree that the fee 

 level determinations reflect "fair market value." We look forward 

 to receiving comments on the Department's proposed policy to help 

 address these concerns . 



While the fee system described in H.R. 1527 would be less 

 burdensome and less expensive to apply than our proposed system 

 for both the permittee and the Government, it is not without its 

 faults. Because it is intended to maintain the same fee levels as 



