IRS APPRAISAL REQUIREMENTS

                  FOR GIFTS OF LAND AND CONSERVATION EASEMENTS

   A landowner's desire to protect the land is the primary reason for
   donating property or a conservation easement to Western Pennsylvania
   Conservancy. However, it is frequently the tax incentives that make it
   possible to give generously and accomplish significant land protection
   goals.

   In order to take a tax deduction for gifts worth more than $5,000,
   including land and conservation easements, the following federal IRS
   requirements (Treas. Reg. 1.170A-13(c)) must be met. Donors should consult
   with their tax advisers concerning the details of these regulations

   * The donor must obtain a written "qualified" appraisal. The Treasury
   regulations outline specific information that must be included in the
   appraisal. The following information must be contained in the appraisal:

     * A description of the property including its location and its physical
       condition.

     * The actual or expected date of the gift, and the date on which the
       property was valued by the appraiser.

     * The terms of any agreement or understanding which restricts Western
       Pennsylvania Conservancy's use or disposal of the property.

     * The name, address, and social security number of the appraiser, and a
       statement describing the appraiser's qualifications.

     * A statement that the appraisal was prepared for income tax purposes.

     * The appraised fair market value of the property on the actual or
       expected date of the gift, a description of the method of valuation
       used, and the specific basis for the valuation, such as comparable
       sales.

     * A description of the fee arrangement between the donor and appraiser.

     * The signature of the appraiser and the date of the report.

   * The appraisal must be current. The timing of the appraisal is essential:
   it cannot be made earlier than 60 days before the date of the gift, and
   must state the fair market value of the gift as of the date of the
   contribution. The entire written appraisal and Appraisal Summary (IRS Form
   8283) must be received by the donor on or before the due date (including
   extensions) of the tax return on which the deduction is claimed. In other
   words, the appraisal can be prepared after the easement is donated,
   provided it is completed before the donor's income tax return is submitted
   to the IRS.

   * The appraisal must be prepared by a "qualified" appraiser. Generally,
   the qualifications are:

    1. The individual performs appraisal work for the public as a

   profession; and

   2. He or she is experienced in performing appraisals of conservation
   easements or gifts of land; and

   3. The appraiser has no relationship to the taxpayer and Western
   Pennsylvania Conservancy that would cause a reasonable person to question
   the appraiser's independence.

   The appraisal fee must not be based on a percentage of the appraised value
   of the property.

   * An Appraisal Summary (IRS Form 8283), signed by the appraiser and the
   donee, must be attached to the federal income tax return on which the
   deduction for the contribution is first claimed. This form, available from
   the IRS and Western Pennsylvania Conservancy's Land Protection Department,
   asks for information required by Treasury Department regulations. It
   should first be signed by the appraiser, and then sent to the Land
   Protection Department for Western Pennsylvania Conservancy's authorized
   signature. The donor must attach a "fully completed appraisal summary" to
   the tax return for the year in which the gift is made. The appraisal
   summary must be on IRS Form 8283. The appraisal report itself is not filed
   with Form 8283.

   * The donor must maintain records containing certain information required
   for property contributions in general, including the complete written
   appraisal.

   Appraisals of raw land are substantially different from typical
   residential property appraisals. Appraisals of conservation easements are
   even more highly specialized and can be costly. However, obtaining an
   appraisal is a necessary expense if you are seeking a charitable income
   tax deduction for your land or easement donation. Not only is it an IRS
   requirement, but a well-substantiated appraisal can head off IRS
   challenges and ensure your deduction.

   An appraisal is necessarily the responsibility of the donor. The donor
   should, however, seek an appraiser with experience appraising land and
   improvements of the type to be appraised.

   For more information on easement appraisals, we recommend that you consult
   Appraising Easements, available from the Land Trust Alliance, 1331 H
   Street NW, Suite 400, Washington, DC 20005, (Tel.202-638-4725).

   If you have questions, please contact the Land Protection Department at
   (412) 288-2777.