; (E) the November 2015 completion of a Final Environmental Impact Statement on the mining operation and the land exchange; (F) the November 2015 issuance of a Forest Service draft Record of Decision approving the NorthMet Land Exchange; and (G) the December 2016 execution of a Memorandum of Agreement under section 306108 of title 54, United States Code (former section 106 of the National Historic Preservation Act). (4) The 6,650 acres of Federal land proposed for conveyance to Poly Met in the NorthMet Land Exchange is National Forest System land, the surface estate of which is administered as part of the Superior National Forest, but which is underlain by the privately owned NorthMet ore body. (5) Poly Met owns and controls the mineral rights to the NorthMet ore body through long-term mineral leases and proposes to build an open pit mine to recover the minerals. (6) The United States owns the remainder of the property rights, including the surface that would be removed to access the minerals as proposed by Poly Met, and this separate ownership of the surface and subsurface, known as a split estate, raises fundamental legal and land management conflicts. (7) The Federal land was purchased by the Forest Service, for National Forest System purposes, under the authority of section 6 of the Act of March 1, 1911 (commonly known as the Weeks Law