Early Submission Justification eMail

8/3/2017

DEPARTMENT OF THE INTERIOR Mail - Fwd: ICRs ready in ROCIS: 1006-0005, 0006, and 0023

Nagode, Jill

Fwd: ICRs ready in ROCIS: 1006-0005, 0006, and 0023
1 message
Nagode, Jill
To: Jill Nagode

Thu, Aug 3, 2017 at 11:15 AM

---------- Forwarded message ---------From: McPhee, Stephanie
Date: Mon, Jul 10, 2017 at 12:33 PM
Subject: Re: ICRs ready in ROCIS: 1006-0005, 0006, and 0023
To: "Nagode, Jill"
Jill This may be more than you need, but here goes (3 paragraphs):
The main reason the RRA forms are submitted for early approval is adherence to a necessary printing and distribution
schedule for hard copy forms in order to provide current, approved RRA forms to respondents in ample time for them to
complete and submit the forms as an annual statutory and regulatory prerequisite for the receipt of Reclamation irrigation
water. As background, the RRA forms are completed by a landholder who wishes to receive Reclamation irrigation water
(i..e., the forms in 1006-0005). Water districts also submit annual forms in fulfillment of statutory and regulatory
requirements associated with their repayment contract with Reclamation (i.e., the forms in 1006-0006). Reclamation
provides the RRA forms electronically; however, many respondents choose not to use the electronic format. Beyond the
fact that Reclamation has no authority or funding to require or assist contracting water districts with the actions that would
be required to mandate the sole use of electronic forms, there are also many landholders who do not have the necessary
technological equipment to access or utilize electronic RRA forms. It is the landholders (i.e., the respondents for 10060005), not the water districts, who represent the vast majority of respondents for all of the RRA information collections
and to whom Reclamation must be the most responsive with regard to providing ways to reduce the burden associated
with reporting. Therefore, Reclamation continues to provide hard copy RRA forms to address the needs of landholders
who do not, or simply cannot, use electronic RRA forms and must instead use hard copy forms as the only means by
which they can meet the statutory and regulatory requirements for receipt of Reclamation irrigation water. With regard to
water districts, although most districts do possess the required technology, some districts choose to use hard copy forms,
and there are districts/water user associations that operate out of a private residence and do not have the required
technology for electronic form usage. In these cases, hard copy forms are, again, the only means by which districts can
meet statutory and regulatory reporting requirements.
In order to get the RRA forms printed each year, the forms have to be submitted through the Government Printing Office
procedures for contracting a printer, and the printer has to have time to print and deliver the printed product to
Reclamation. Thereafter, Reclamation must have ample time to distribute the forms to the appropriate water districts so
they are available to each district prior to the contractual start date of each district's irrigation season, and so that
landholders can then have ample time to complete and submit their forms prior to first delivery of Reclamation irrigation
water. These processes can take several months, which is why OMB approval is sought well in advance of the current
expiration date. It is also necessary to try to time the approval renewal so that we do not have RRA forms that are
expiring while an irrigation season is still in force. We accomplish this timing by making sure the new approval, printing,
and distribution processes are all completed well in advance of the next water year, which also happens to be well in
advance of any given RRA forms' expiration date. For example, the 2018 RRA forms that are involved in this renewal
request must be approved, printed, distributed, and completed in advance of the 2018 water year, which in many cases
corresponds to January 1, 2018, of the calendar year. We cannot wait until closer to the October 31, 2018, OMB
expiration date to renew approval because (1), there will be no time for printing, distribution, completion, and submittal,
and (2) In October 2018, many landholders will still be receiving Reclamation irrigation water as part of the 2018 water
year, and may be required to submit new RRA forms with a new expiration date (doubling their annual reporting burden)
so they are not using expired forms to continue their irrigation activities for the year.
Section 17 of the Supporting Statement for each of the three RRA information collections details our need for early
approval. In fact, for many years we have requested and been granted the approval to make the OMB expiration date
correspond with the end of a calendar year. For example, in the current renewal requests, we would have requested an
OMB expiration date of December 31, 2019, instead of what will likely be a Fall 2020 expiration date. Our requests for an
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8/3/2017

DEPARTMENT OF THE INTERIOR Mail - Fwd: ICRs ready in ROCIS: 1006-0005, 0006, and 0023

altered expiration date eliminated the possibility of expired RRA forms being used during an ongoing water year because
the OMB expiration date coincided with the end of the vast majority of contractual water years and irrigation seasons.
However, our requests for an altered expiration date have been denied in the last few OMB approval cycles, and we are
now seeing the questions that appear without that altered date. Specifically, if during the last OMB approval cycle we had
been granted our requested date of December 31, 2017, our current renewal requests under review now would not have
appeared to be nearly as premature as they do with the current October 17, 2018, expiration date. Although we have
chosen not to belabor the request for an altered OMB expiration date by requesting it again, we remain hopeful that we
can adequately explain and be mindful of the fact that our timing needs have not changed with regard to the schedule for
approval/printing/distribution/completion/submittal of the RRA forms, whether or not the OMB expiration date is at the end
of a calendar year or at the end of the usual 3-year approval period.

Stephanie K. McPhee
Bureau of Reclamation
Reclamation Law Administration Division
Denver CO
303-445-2897
smcphee@usbr.gov

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