I appreciate the vote of confidence. Unfortunately, I have a lot going on right now, and I'll probably be scrambling to submit my comment in the final hours. My first blush impression is that the draft is a good step forward, but perhaps too vague. Someone could argue that land swaps are "rare" right now, and they typically result in a net increase in public holdings, with the acquired land often having more ecological and historical value than the land TVA gives up. Whether the language in the draft would actually preclude something like the Nickajack/Little Cedar Mt swap with Thunder Thornton is a matter of interpretation.

With TVA being run by a large and diverse board instead of just Bill Baxter, the potential for maverick decision making is diminished, but I'd like to see clearer parameters on what constitutes an exceptional case. For example, TVA could swear off land swaps as a revenue source or pledge to share profits with the landowner or heirs who were forced to give up their deed.

TVA also owns signfiicant coal deposits in the Tennessee Cumberlands, and those holdings could be more explicitly addressed in the document.