ed from id. at 80 (appendix B). 1972] ECOLOGY LAW QUARTERLY reasons for invalidating the permit, District Court Judge Sweigert had found that the permits were in practice irrevocable, because revoking them, with the result of destroying the development, would result in an embarrassment to the Forest Service. 19 The Ninth Circuit ignored this point. The Disney Productions development would have permanent structures on approximately 400 acres and would ultimately affect 13,000 acres of the 15,000-acre valley. It is questionable whether such a vast development was within the intention of Congress when enacting 16 U.S.C. § 497.'9 As the district court found, comments by the Forest Service to Congress clearly indicate that eighty acres was to be the maximum limit for permits involving permanent structures for non-Forest Service use.' 97 This is the first case to challenge the operation of the Forest Service permit system. The Ninth Circuit's failure to view this case as one that would affect the future of Forest Service administration of lands under its control may have serious consequences in the event of numerous future Mineral Kings. If the decision stands there will be no project too huge for execution by issuance of numerous permits to accompany a single term permit. The only check on the Forest Service permit policy will apparently have to come from within the Service if future large-scale developments of this kind are to be scrutinized. It can be argued that preservation of our natural environment can only be achieved through the National Park System,' or through the classification of wilderness areas,' 99 but such lands may not be sufficient to meet future demands on the environment that peace, solitude, and escape from the man-made world may require,- ° particularly if existing park lands are licensed for large-scale, man-made developments. It is precisely because of the severely limited public input in 195. The very opinion of the Attorney General relied on by Agriculture warns of just such a possible danger to the public interest in granting revocable permits, saying: In cases where it appears that the permittee intends to make substantial improvements the removal of which would cause him a great loss in the case of revocation of the permit, it is a matter of departmental policy whether a situation should be created by the issue of a permit which may afterwards embarrass the head of the department in the exercise of the powers of revocation. District Court opinion, supra note 2, at 6. See text accompanying note 57 supra. 196. See Affidavit of Michael McCloskey filed June 4, 1969, at 7, District Court opinion, supra note 2. 197. District Court opinion, supra note 2, at 3. 198. See 16 U.S.C. § 1 (1970). 199. See id. §§ 1131 et seq. 20