Heffner_dh6.doc

June 23, 2000

VIA FACSIMILE

John D. Heffner
Rea, Cross & Auchincloss
1707 L Street NW, Suite 570
Washington, DC 20036

RE: Abandonment of the Camas Prairie

Dear John,

I trust that your flight from Idaho to back East was uneventful. I hope that after your trip to Orlando that you have had some opportunity to catch up on your sleep.

I would also like to obtain some additional documents and information concerning the proposed abandonment. More specifically, please provide the requested documents or answer the following questions:

Identify the amount of revenue that Camas Prairie currently receives (in dollars per car or other means of compensation) on interline shipment to and from the line (broken down for commodities that were originated or terminated on the line, e.g., wheat-unit train shipments, wheat-other, barley, lumber, etc.).

Please provide copies of all bridge inspection reports made by the Camas Prairie during the year 2000.

Please provide copies of all FRA inspection reports or other FRA written communications to Camas Prairie from the inception of Camas Prairie RailNet’s operation to the present.

Identify in detail the “large inventory of track materials on the property” referred to at pages 7 and 8 of the Verified Statement of Robert Finley.

What was meant by the term “average condition” in the third-from-last-line on page 7 of Mr. Finley’s Statement?

Provide copies of the Camas Prairie RailNet’s locomotive leases for Locomotives CSPR1 and CSPR5.

Please provide the basis and supporting work-papers/data for Marsh USA Inc.’s valuation of Camas Prairie’s covered hoppers at $25,000 each, Camas Prairie’s locomotives at $415,000 each, and bridge replacement cost at $2,500 per foot.

Provide a copy of the contract by which an independent consultant is employed to assist with car accounting issues for CSPR or, if not in writing, a description of the arrangement under which that consultant is paid for his services.

Provide a copy of the agreement(s) between Camas Prairie RailNet and its connecting carriers governing freight car “free time.”

Provide a copy of Rail Car Management Inc.’s computer printouts referred to at page 12 of Mr. Finley’s Statement and the calculations made from those printouts to obtain Camas Prairie car-hire costs.

Please provide all operating statistics, including but not limited to, car miles, car days, locomotive unit miles, locomotive unit hours and gross ton miles, for the entire CSPR system and separately for the Second Subdivision, to the extent that they exist for the years 1998 and 1999.

Provide the total number of CSPR employees by function (i.e., train service, bridge and building, track inspector, clerical, car maintenance and locomotive unit maintenance).

Provide a detailed list of vehicles owned by CSPR and their intended use.

Provide copies of CSPR’s car hire records for the years 1998 and 1999.

Provide a detailed list of inputs used to develop the “cost per car” values shown on page 1 of Exhibit K.

Provide the Phase III program output supporting the “cost per car” values shown on page 1 of Exhibit K.

Provide work-papers and supporting documents for Camas Prairie’s calculation of off-branch costs.

Please provide copies of salvage bid(s) used to calculate the NLV of track assets whether such bid(s) “expired or about to expire.”

Please provide a copy of the Asset Purchase Agreement between Camas Prairie RailNet and Union Pacific and Burlington Northern Santa Fe Railway Company.

Besides the Parsons Brinckerhoff, has any other railroad or consultant examined or inspected the bridges on the Second Subdivision since 1998? If so, identify the party or person(s) conducting the inspection, the date(s) of the inspection, and the conclusions or observations of such inspection. Please provide copies of any reports notes, photos, or any other documents relating to such examination or inspection.

The Application at p. 3 states that the railroad undertook a “serious focus on customer needs.” Please explain in detail the efforts undertaken, the date of the efforts, the results of such efforts. If a customer survey was conducted, please provide a copy(ies) of the survey(s) submitted to customers, copies of the completed or gathered surveys, and any prepared analysis of the results of such survey(s).

The Application at p. 3 states that the railroad “embarked on an aggressive marketing program” to stimulate additional rail traffic. Please explain in detail the elements of the marketing program, the date(s) it was effective, and the results. Provide any reports, notes, analysis or other documents related to this marketing program.

Please describe in detail all efforts undertaken by Camas Prairie RailNet to increase or obtain more favorable terms for the allocation of revenue for shipment from or to Union Pacific RR and BNSF. Include the times, dates, the names of RailNet persons involved, the names of UP or BNSF representatives, and the results of such efforts.

Has Camas Prairie RailNet included revenues originating from rail tours, speeder car clubs, the movie or film production, or other forms of recreational use applicable to the Second Subdivision? If so, please identify the amounts included in the base year and forecast year.

Please provide all reports, analysis, or other documents pertaining to any valuation of the right-of-way for the Second Subdivision, either separately or combined with other subdivisions at or prior to the purchase of the Camas Prairie in April 1998.

If you have any questions concerning these requests, please contact me at [phone].

Sincerely yours,

Donald L. Howell, II
Deputy Attorney General

Vld/Lcp:Heffner_dh6
John D. Heffner
June 23, 2000
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