20190928 11354600 1.0 TRUE Recreation - CRMC Public Shoreline Access <DIV STYLE="text-align:Left;font-size:12pt">Thanks for bringing the Arnold Park appraisal question back to my attention. This is a common issue with older LWCF sites that have had landfill or lease activity over time. Under 36 CFR § 59.3(d)(3) and LWCF Manual Vol. 72, Ch. 3.D, the converted land must be appraised at current fair market value based on its highest and best use (HBU)—that is, what is legally permissible, physically possible, and financially feasible.Because the site is a capped landfill, the appraisal should reflect the restrictions and environmental conditions that limit its use. Missy’s earlier direction to appraise the site “as a landfill” aligns with LWCF guidance; the HBU would likely remain constrained open space or utility use, not unrestricted development.The solar lease should be acknowledged but not used to inflate the land value. The appraisal should focus on the underlying capped landfill’s fair market value, since the LWCF equivalency test is based on the property’s recreational potential and the real property interest being removed from protection—not on non-recreational or income-generating leases</DIV>