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a uniform federal policy. MOAA has seriously reservations with 

 Section 8 (c) . 



New Polices for Capital Improvements and Property Appraisals 



Independent appraisals of property and businesses are 

 difficult at best. How do we determine the current market price 

 of a small business? Is it based on the value of fixed assets? 

 Yes. Is it based on past performance and customer goodwill? Yes. 

 Is it based on projected market conditions? Yes. But what formula 

 will the Federal government use? How do you set up Federal 

 rulemakings to determine fair market value that is fair to the 

 seller? Investment capitalists are constantly adjusting the 

 criteria for setting a "price" for a business and then seldom does 

 the business sel] for that price. 



MOAA believes the requirement for an independent appraisal to 

 determine the fair market value of a small business at a Federal 

 site will be impossible to obtain, will be burdensome, and will be 

 unfair to the selling party. A lack of qualified and knowledgeable 

 marina appraisal firms coupled with a lack of properly established 

 appraisal criteria will cause marina appraisals to be inaccurate 

 and highly subjective. 



We ask that H.R. 2028 be amended so that the appraisal will 

 only be one of several tools that can be used to determine fair 

 market value. In the final analysis, the market price will be the 

 selling price and will be the end value of a concessioner's 

 property. 



To conclude, MOAA believes that concession policy should 

 enhance the successful partnership between the Federal government 

 and small business. By doing so, small business will continue to 

 provide the capital investment necessary to promote the 

 recreational opportunities of the American public. 



MOAA looks forward to working with you and your staff to write 

 legislation which will do just that. Thank you. 



Sincerely, 



Greg Staudt Phil Keeter 



President Executive Director 



