1006-0023 Supporting Statement 06-13-09

Supporting Statement for Paperwork Reduction Act Submissions
FORMS TO DETERMINE COMPLIANCE BY CERTAIN LANDHOLDERS
43 CFR PART 426
CURRENT OMB APPROVAL NO. 1006-0023
Terms of Clearance: None
General Instructions
A Supporting Statement, including the text of the notice to the public required by
5 CFR 1320.5(a)(i)(iv) and its actual or estimated date of publication in the Federal Register,
must accompany each request for approval of a collection of information. The Supporting
Statement must be prepared in the format described below, and must contain the information
specified in Section a below. If an item is not applicable, provide a brief explanation. When
item 17 of the OMB Form 83-I is checked “Yes,” Section B of the Supporting Statement must be
completed. OMB reserves the right to require the submission of additional information with
respect to any request for approval.
A. JUSTIFICATION
1. Explain the circumstances that make the collection of information necessary.
Identify any legal or administrative requirements that necessitate the collection. Attach a
copy of the appropriate section of each statue and regulation mandating or authorizing the
collection of information.
The Reclamation Act of 1902 established a policy of Federal assistance through irrigation
development. Among other requirements, the Reclamation Act of 1902 provided that federally
developed water (irrigation water) could not be delivered to more than 160 acres per individual
ownership. The delivery of irrigation water to leased land was not restricted.
These provisions were amended on October 12, 1982, when President Reagan signed into
law the Reclamation Reform Act of 1982 (RRA). The RRA permits individual landholders
and irrigation districts (districts) the option of remaining subject to the ownership and pricing
provisions of prior law (prior law) or becoming subject to the ownership and pricing provisions
of the new law (discretionary provisions). The discretionary provisions, found in sections 203
through 208 [except for section 203(b)], of the RRA allow for the delivery of irrigation water to
up to 960 acres owned by an individual or an entity benefiting 25 or fewer persons and up to
640 acres owned by an entity benefiting more than 25 persons. The new law also sets forth
conditions for charging a full-cost rate for irrigation water deliveries. In addition to other
full-cost requirements, section 205(a)(3) of the RRA directs any limited recipient (which is an
entity benefiting 25 or more natural persons) that did not receive Reclamation irrigation water
prior to October 1, 1981, to pay the full-cost rate for all Reclamation irrigation water deliveries.

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Section 426.18 of the Acreage Limitation Rules and Regulations (regulations) describes
forms submittal requirements for landholders (direct or indirect landowners or lessees). In
addition to other requirements, 43 CFR 426.18 specifies forms submittal thresholds for entity
landholders. Specifically, a “qualified recipient” (an individual or legal entity that benefits
25 natural persons or less) must submit an RRA form only if he/she/it holds at least 80 acres, and
more often, at least 240 acres; a “limited recipient” (a legal entity that benefits 25 or more
natural persons) must submit an RRA form only if it holds more than 40 acres.
Section 214 of the RRA provides an exemption from application of the acreage limitation
provisions to trustees acting in a fiduciary capacity. Section 426.7 of the regulations
establishes the criteria all trusts must meet in order to benefit from this exemption. In order to
ensure the criteria are met, 43 CFR 426.7(b) requires that Reclamation review and approve all
trusts.
2. Indicate how, by whom, and for what purpose the information is to be used. Except
for a new collection, indicate the actual use the agency has made of the information
received from the current collection. [Be specific. If this collection is a form or a
questionnaire, every question needs to be justified.]
The RRA forms described below are to be completed only upon Reclamation’s request by
certain entity, trust, public entity, and religious or charitable organization landholders subject to
the acreage limitation provisions of Federal reclamation law. Reclamation will identify the
specific entity, trust, public entity, and religious or charitable organization landholders that must
complete and submit to Reclamation one of the RRA forms described below. Once completed,
a copy of the “Limited Recipient Identification Sheet,” “Trust Information Sheet,” “Public Entity
Information Sheet,” or “Religious or Charitable Organization Identification Sheet” will be
retained by the entity, trust, public entity, or religious or charitable organization landholder
(as applicable), a copy will be retained by the district office for retention in the district’s
landholder files, and the original will be retained by Reclamation.
The changes made to the currently approved forms in order to obtain the draft forms
proposed for approval are predominantly editorial and typographical in nature, with the intent to
facilitate the respondents’ ease in form completion and increase the clarity of the forms for the
respondents. Such changes were also designed to improve the specificity of the information
provided by the respondents so that Reclamation can ensure proper administration of the acreage
limitation provisions.
List of forms
Following is a list of the four forms in this information collection (IC), and a brief discussion of
the purpose of each form. A detailed discussion of the purpose of each question on the forms is
provided in Attachment 1.
Limited Recipient Identification Sheet, Form 7-2536: Some entities that receive
Reclamation irrigation water may believe themselves to be under the applicable RRA threshold,
and consequently may not submit the appropriate RRA form(s). However, some of these entities
may, in fact, have a different RRA forms submittal threshold than what they believe it to be due
to the number of natural persons benefiting from each entity and the location of the land held by
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each entity. In addition, some entities that are exempt from the requirement to submit
RRA forms due to the size of their landholdings may in fact be receiving Reclamation irrigation
water for which the full-cost rate must be paid because the start of Reclamation irrigation water
deliveries occurred after October 1, 1981 [43 CFR 426.6(b)(2)]. In accordance with the
requirements of the RRA and 43 CFR 426.6(b)(2), the “Limited Recipient Identification Sheet”
will enable Reclamation to determine whether an entity landholder that is not submitting
RRA forms (1) is, in fact, a limited recipient required to submit RRA forms, and (2) is remitting
the appropriate rate for Reclamation irrigation water deliveries.
Trust Information Sheet, Form 7-2537: In accordance with the requirements of 43 CFR
426.7(b)(2), Reclamation is required to review all trusts to ensure that they meet the regulatory
criteria specified in 43 CFR 426.7. Land held in trust generally will be attributed to the
beneficiaries of the trust rather than the trustee if the criteria are met. When Reclamation
becomes aware of trusts with a relatively small landholding (40 acres or less), we may extend to
those trusts the option to complete and submit for Reclamation’s review the “Trust Information
Sheet” instead of actual trust documents. If Reclamation finds nothing on the completed “Trust
Information Sheet” that warrants further investigation of a particular trust, that trustee will not be
burdened with submitting trust documents to us for in-depth review.
Public Entity Information Sheet, Form 7-2565: In accordance with the requirements of
Public Law 91-310 (enacted July 7, 1970) and 43 CFR 426.10, Reclamation is required to
ascertain whether or not public entities that receive Reclamation irrigation water can be
considered exempt from the application of the acreage limitation provisions. This determination
is made based on whether or not a public entity meets certain criteria pertaining to the revenue
generated through the entity’s farming activities. Per statute and regulation, Reclamation must
make this determination regardless of how much land a public entity directly or indirectly owns
or leases. As such, making this determination becomes difficult for those public entities that are
below the 40-acre RRA forms submittal threshold. Such public entities are not required to
submit the standard RRA form for public entities, the “Declaration of Public Entity’s
Landholdings” (Form 7-21PE), which is currently approved in another IC under OMB clearance
number 1006-0005. The “Public Entity Information Sheet” will enable Reclamation to
determine whether or not a public entity that holds 40 acres or less and receives Reclamation
irrigation water is exempt from application of the acreage limitation provisions. In addition, for
those public entities that Reclamation determines are not exempt from the application of the
acreage limitation provisions, the “Public Entity Information Sheet” will allow Reclamation to
determine the proper rate to charge for Reclamation irrigation water deliveries.
Religious or Charitable Organization Identification Sheet, (Form 7-2578): Some religious or
charitable organizations that receive Reclamation irrigation water may believe that they are
under the RRA forms submittal threshold and, consequently, may not submit the appropriate
RRA form(s). However, some of these organizations may in fact have a different RRA forms
submittal threshold than what they believe it to be depending on whether these organizations
meet all of the required criteria for full special application of the acreage limitations provisions
to religious or charitable organizations [43 CFR 426.9(b)]. In addition, some organizations that
(1) do not meet the criteria to be treated as a religious or charitable organization under the
acreage limitation provisions, and (2) are exempt from the requirement to submit RRA forms due
to the size of their landholdings (directly and indirectly owned and leased land), may in fact be
receiving Reclamation irrigation water for which the full-cost rate must be paid because the start
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of Reclamation irrigation water deliveries occurred after October 1, 1981 [43 CFR 426.6(b)(2)].
The “Religious or Charitable Organization Identification Sheet” will allow Reclamation to
establish compliance with Federal reclamation law by certain religious or charitable
organizations.
All four forms in this IC include a section for Reclamation completion. In this section
Reclamation identifies the entity that is to complete the form, the district in which the entity
holds land, and the date by when Reclamation requested that the entity needs to complete this
form. All of this information is required for Reclamation’s record keeping purposes. All four
forms also include the statement of protection by the Privacy Act of 1974 (system of records
INTERIOR/WBR-31) to assure landholders of the protection of certain information that may be
on the landholders’ forms.
3. Describe whether, and to what extent, the collection of information involves the use
of automated, electronic, mechanical, or other technological collection techniques or other
forms of information technology, e.g., permitting electronic submission of responses, and
the basis for the decision for adopting this means of collection. Also describe any
consideration of using information technology to reduce burden [and specifically how this
collection meets GPEA requirements].
Reclamation has made all of the OMB-approved RRA forms and the associated instructions
(i.e., all RRA forms approved under OMB approval numbers 1006-0005 and 1006-0006)
available on the Internet for either printing and manual completion, or electronic completion,
and manual submission. This effort was fully accomplished in October 2004. All RRA forms
approved under OMB approval number 1006-0006 can be electronically completed and
submitted. This option is available for only the forms under OMB approval number 1006-0006
for reasons detailed in the supporting statement for that IC. The “Limited Recipient
Identification Sheet,” the “Trust Information Sheet,” the “Public Entity Information Sheet,” and
the “Religious or Charitable Organization Identification Sheet” will not be included in
Reclamation’s electronic RRA forms efforts because (a) they are used only under very limited
circumstances, and (b) they are used only at Reclamation’s specific request. As shown below in
section 12 (“Provide estimates of the hour burden of collection of information . . .”), of the
thousands of landholders and 210 water user organizations that complete the RRA forms
currently approved under OMB approval numbers 1006-0005 and 1006-0006, Reclamation has
cause to request only a very select few to complete the “Limited Recipient Identification Sheet,”
the “Trust Information Sheet,” the “Public Entity Information Sheet,” or the “Religious or
Charitable Organization Identification Sheet”. When Reclamation has reason to request that a
landholder complete one of these four forms, Reclamation contacts that landholder in writing
(rather than through electronic means) since Reclamation neither maintains nor has any reason to
request landholder e-mail addresses. Because Reclamation’s initial contact with the landholder
in question is, by necessity, of written format, attaching a paper copy of the required form for
landholder completion proves to be more efficient than trying to coordinate the electronic
completion and submittal of the required form, which would include the ascertainment of
whether the respondent in question has the capability to electronically complete and/or submit an
electronic form.

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It should be noted that as shown below in section 12 (“Provide estimates of the hour burden
of collection of information”), the “Limited Recipient Identification Sheet” and the “Trust
Information Sheet” each take an average of 5 minutes to complete which results in only 27 total
annual burden hours. The “Public Entity Information Sheet” takes no more than 15 minutes to
complete, and because there are very few public entities that use this form, there are only 25 total
annual burden hours for this form. The “Religious or Charitable Organization Identification
Sheet” takes no more than 15 minutes to complete, and there are only 19 total annual burden
hours for this form because there is anticipated to be a very small subset of religious or
charitable organizations that will use this form. Furthermore, each form is generally completed
only once by a particular landholder upon Reclamation’s specific request.
4. Describe efforts to identify duplication. Show specifically why any similar
information already available cannot be used or modified for use for the purposes
described in item 2 above.
The acreage limitation provisions of Federal reclamation law apply only to certain
Reclamation projects that provide irrigation water for agricultural purposes; consequently,
similar data are neither collected nor available through any other Federal agency, State or local
government, or private organization.
These findings are detailed by an attachment to a letter from Mr. Scott J. Cameron, Deputy
Assistant Secretary for Performance and Management (Department of the Interior), to
U.S. Representative Doug Ose regarding an April 11, 2002, hearing on Paperwork Reduction
Act issues. Specifically, pages two and three of the attachment to Mr. Cameron’s letter detail the
following general findings:
a. Not all of Reclamation’s customers participate in USDA programs, and most of USDA’s
customers do not receive Reclamation irrigation water.
b. Reclamation and USDA do not use the same categories of program respondents due to
statutory and regulatory program requirements.
c. The level and nature of detail in USDA and Reclamation ICs differs in such ways that it
is clear USDA data would not be sufficient to allow Reclamation to properly
administer and enforce the acreage limitation provisions of Federal reclamation law.
d. RRA forms are filed at the local (district) level; USDA forms are filed at county offices
with little centralization of that data.
For the foregoing reasons, it has been determined that there is no duplication with regard to
this particular data collection.
5. If the collection of information impacts small businesses or other small entities
(item 5 of OMB Form 83-I), describe any methods used to minimize burden.
Small organizations, such as family trusts, are among the respondents to this requirement.
These forms will be given to only a small portion of such respondents, and only at Reclamation’s
discretion. Reclamation has carefully analyzed this requirement to ensure that the information
requested of all potential respondents is the minimum necessary to implement and enforce the
acreage limitation provisions of Federal reclamation law. For example, the “Trust Information
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Sheet” reduces the burden placed upon trustees by eliminating the need to submit to Reclamation
copies of actual trust documents.
6. Describe the consequence to Federal program or policy activities if the collection is
not conducted or is conducted less frequently, as well as any technical or legal obstacles to
reducing burden.
By failing to gather the information described above, the Department of the Interior would
risk violating the provisions of laws previously cited. Enforcement of the acreage limitation
provisions of Federal reclamation law and the collection of appropriate water charges would be
hampered if this information were not collected.
Generally, these forms will be submitted only once per identified entity, trust, public entity,
or religious or charitable organization. In other words, although Reclamation encounters new
entities, new trusts, new public entities, and new religious or charitable organizations annually,
field data have shown that the burden hours for this IC do not increase significantly because each
form is completed only once per identified entity, trust, public entity, or religious or charitable
organization. Since the information will generally only be collected once per identified entity,
trust, public entity, or religious or charitable organization, it would not be possible to conduct the
collection on a less frequent basis.
7. Explain any special circumstances that would cause an information collection to be
conducted in a manner:
a. Requiring respondents to report information to the agency more often than
quarterly.
Not applicable. Generally, these forms will be submitted only once per identified entity,
trust, public entity, or religious or charitable organization. Any additional requirements will
generally only be determined on, at most, an annual basis.
b. Requiring respondents to prepare a written response to a collection of
information in fewer than 30 days after receipt of it.
There is no requirement to submit these forms within a timeline that is less than 30 days.
c. Requiring respondents to submit more than an original and two copies of any
document.
Not applicable. Each entity, trust, public entity, or religious or charitable organization that is
identified to complete the applicable form will only be required to complete the original.
Reclamation will make and distribute any needed copies.

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d. Requiring respondents to retain records, other than health, medical, government
contract, grant-in-aid, or tax records, for more than 3 years.
In general, any of these forms that are submitted to the district will be retained in the
landholder’s file as long as the entity, trust, public entity, or religious or charitable organization
holds land in the district. This is because these forms help establish the acreage limitation status
of the entity, trust, public entity, or religious or charitable organization.
e. In connection with a statistical survey, that is not designed to produce valid and
reliable results that can be generalized to the universe of study.
The forms in this IC will not be used this way.
f. Requiring the use of a statistical data classification not reviewed and approved by
OMB.
Statistical data classification will not be used.
g. That includes a pledge of confidentiality that is not supported by authority
established in statute or regulation, that is not supported by disclosure and data security
policies that are consistent with the pledge, or which unnecessarily impedes sharing of data
with other agencies for compatible confidential use.
A pledge of confidentiality is not used.
h. Requiring respondents to submit proprietary trade secrets, or other confidential
information unless the agency can demonstrate that is has instituted procedures to protect
the information’s confidentiality to the extent permitted by law.
The forms are protected by the Privacy Act of 1974, system of records
INTERIOR/WBR-31.
8. If applicable, provide a copy and identify the date and page number of publication in
the Federal Register of the agency’s notice, required by 5 CFR 1320.8(d), soliciting
comments on the information collection prior to submission to OMB. Summarize the
public comments received in response to that notice [and in response to the PRA statement
associated with the collection over the past three years] and describe actions taken by the
agency in response to these comments. Specifically address comments received on cost and
hour burden.
Notice was given in the Federal Register on October 24, 2008 (73 FR 63507, Oct. 24, 2008).
No comments were received on this IC.

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a. Describe efforts to consult with persons outside the agency to obtain their views on
the availability of data, frequency of collection, the clarity of instructions and
recordkeeping, disclosure, or reporting format (if any) and on the data elements to be
recorded, disclosed, or reported. [Please list the names, titles, addresses, and phone
numbers of persons contacted.]
Every year that Reclamation renews OMB approval for its ICs, all districts subject to acreage
limitation receive a letter from Reclamation that announces the start of the public comment
period. In that letter is a copy of the corresponding Federal Register notice, a list of the
proposed changes to the RRA forms, a draft copy of any proposed new form (if any), and an
announcement regarding the availability of copies of the draft form upon request. Regarding the
current request for IC approval, all districts subject to acreage limitation received such a letter
from Reclamation dated December 4, 2008.
b. Consultation with representatives of those from whom information is to be
obtained or those who must compile records should occur at least once every 3 years –
even if the collection of information activity is the same as in prior periods. There may be
circumstances that may preclude consultation in a specific situation. These circumstances
should be explained.
This IC contains forms that are completed by an extremely small number of landholders
when compared to the many thousands of landholders that complete RRA forms each year. The
landholders that submit the forms in this IC are among a small subset of landholders who are not
required to submit standard RRA forms (specifically, the forms in OMB clearance number 10060005) because their total landholdings do not exceed the applicable RRA forms submittal
threshold specified in the regulations. This small subset of landholders is further limited to those
whose landholdings are specifically identified (by Reclamation) as possibly being subject to
aspects of the acreage limitation provisions other than RRA forms submittal (such as land
attribution and water pricing). The burden hour estimate associated with each form in this IC is
an average figure because not all sections of each form in this IC are applicable to every
landholder. While some landholders may utilize the full burden hour estimate to complete
multiple, applicable sections of a form in this IC, other landholders may utilize only a fraction of
the burden hour estimate to complete the one section that is applicable to them. The respondent
group and the burden hour estimates for the forms are both so small that consultation with
persons outside the agency would likely yield inaccurate results and in most cases be more
burdensome (from a time perspective) than completing the form itself. Throughout each year,
Reclamation conducts regularly scheduled water district reviews at district offices that are
subject to the acreage limitation provisions. Discussions between Reclamation RRA staff and
district staff are held at those reviews during which burden hour feedback is addressed. In other
words, Reclamation continually assesses burden hour estimates for the RRA forms through
discussions with district staff that are in direct contact with the respondents of the forms in this
IC.
9. Explain any decision to provide any payment or gift to respondents, other than
remuneration of contractors or grantees.
No payments or gifts will be provided to respondents.
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10. Describe any assurance of confidentiality provided to respondents and the basis for
the assurance in statute, regulation, or agency policy.
Personal and financial information collected on these forms is protected under the Privacy
Act of 1974. The Privacy Act system of records notice associated with this IC is
INTERIOR/WBR-31, Acreage Limitation.
11. Provide additional justification for any questions of a sensitive nature, such as
sexual behavior and attitudes, religious beliefs, and other matters that are commonly
considered private. This justification should include the reasons why the agency considers
the question necessary, the specific uses to be made of the information, the explanation to
be given to persons from whom the information is requested, and any steps to be taken to
obtain their consent.
No questions of a private or sensitive nature will be asked.
12. Provide estimates of the hour burden of collection of information. The statement
should:.
a. Indicate the number of respondents, frequency of response, annual hour burden,
and an explanation of how the burden was estimated. Unless directed to do so, agencies
should not conduct special surveys to obtain information on which to base hour burden
estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable.
If the hour burden on respondents is expected to vary widely because of differences in
activity, size, or complexity, show the range of estimated hour burden, and explain the
reasons for the variance. Generally, estimates should not include burden hours for
customary and usual business practices.
See response to item 12(b) [next paragraph].
b. If this request for approval covers more than one form, provide separate hour
burden estimates for each form and aggregate the hour burdens in item 13 of OMB Form
83-I.
Based on actual numbers of completed forms year-to-year, the estimated number of total
respondents for all four forms is 500. The estimated number of annual responses per respondent
is 1.00 annually, or 500 total annual responses (175 respondents multiplied by 1.00 response per
respondent for the “Limited Recipient Identification Sheet,” plus 150 respondents multiplied by
1.00 response per respondent for the “Trust Information Sheet,” plus 100 respondents multiplied
by 1.00 response per respondent for the “Public Entity Information Sheet,” plus 75 respondents
multiplied by 1.00 response per respondent for the “Religious or Charitable Organization
Identification Sheet”). The total number of annual responses for the four forms has remained
constant from previous years.

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The total estimated annual burden hours for this IC are 72 hours. The estimated annual
burden hours per form are listed below:

Form Name
Limited Recipient
Identification Sheet
Trust Information
Sheet
Public Entity
Information Sheet
Religious or Charitable
Identification Sheet
TOTAL

Burden
Estimate
Per Form
(in minutes)

Estimated
No. of
Respondents

Frequency
of
Response

Total
Annual
Responses

175

1.00

175

5

15

150

1.00

150

5

13

100

1.00

100

15

25

75

1.00

75

15

19

500

1.00

500

Total
Burden
Hours

72*

The average annual hour burden per response is 8.64 minutes (0.144 hours). The total
annual hour burden is 72* hours (500 annual responses multiplied by 0.144 hours per response).
This represents no net increase or decrease of burden hours from previous years.
* Due to rounding when figuring the total burden hours for certain forms, the total
burden hour figure is higher by 2 (the actual figure is 70). However, the 72 figure is used for
ease of depiction and uniformity with the previous years’ justification.
c. Provide estimates of annualized costs to respondents for the hour burdens for
collection of information, identifying and using appropriate wage rate categories. The cost
of contracting out or paying outside parties for information collection activities should not
be included here. Instead, this cost should be included in item 14.
The average annual cost per response is estimated to be $3.02 (as rounded from actual
figure of $3.024). This is based on a wage rate (including benefits of a 1.4* multiplier) of
$21 per hour for clerical staff multiplied by 0.144 hours per response. The total annual cost is
$1,512 ($3.024 per response multiplied by 500 responses). The wage rate figure of $21 for the
appropriate private sector employee category applicable to this IC was obtained from the
March 12, 2009, Bureau of Labor Statistics news release containing December 2008 employer
costs for employee compensation figures (http://www.bls.gov/news.release/pdf/ecec.pdf). *BLS
news release USDL: 08-1802, December 10, 2008.
The respondents for this IC are primarily private sector clerical employees. For the 100
estimated public entity respondents that could possibly be state or local government workers, the
wage rate figure for clerical employees in state and local governments is $26 per hour.
Assuming all of the 100 estimated public entity respondents are in fact state or local government
employees, this represents an hourly wage increase of $5 per hour from that of private sector
clerical employees. A negligible annualized cost increase results from applying the $5 per hour
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wage difference toward the 100 responses affected by this wage rate difference (the 100
applicable responses represent only 20 percent of the total responses for this IC).
13. Provide an estimate of the total annual [non-hour] cost burden to respondents or
recordkeepers resulting from the collection of information. (Do not include the cost of any
hour burden shown in item 12 and 14.)
a. The cost estimate should be split into two components: (1) a total capital and
start-up cost component (annualized over its expected useful life), and (2) a total operation
and maintenance and purchase of services component. The estimates should take into
account costs associated with generating, maintaining, and disclosing or providing the
information [including filing fees paid]. Include descriptions of methods used to estimate
major cost factors including system and technology acquisition, expected useful life of
capital equipment, the discount rate(s), and the time period over which costs will be
incurred. Capital and start-up costs include, among other items, preparations for
collecting information such as purchasing computers and software; monitoring, sampling,
drilling and testing equipment; and record storage facilities.
The estimated total capital and start-up cost to respondents is $0.00. The estimated total
operation and maintenance and purchase of services component is estimated to be $0.00.
b. If cost estimates are expected to vary widely, agencies should present ranges of
cost burdens and explain the reasons for the variance. The cost of purchasing or
contracting out information collection services should be a part of this cost burden
estimate. In developing cost burden estimates, agencies may consult with a sample of
respondents (fewer than 10), utilize the 60-day pre-OMB submission public comment
process and use existing economic or regulatory impact analysis associated with the
rulemaking containing the information collection, as appropriate.
Cost estimates will not vary.
c. Generally, estimates should not include purchases of equipment or services, or
portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance
with requirements not associated with this information collection, (3) for reasons other
than to provide information or keep records for the government, or (4) as part of
customary and usual business or private practices.
Cost estimates do not include these purchases.

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14. Provide estimates of annualized cost to the Federal Government. Also, provide a
description of the method used to estimate cost, which should include quantification of
hours, operation expenses (such as equipment, overhead, printing, and support staff), and
any other expense that would not have been incurred without this collection of information.
Agencies also may aggregate cost estimates from item 12, 13, and 14 in a single table.
Annual cost to the Federal Government is estimated as follows:
Item
Printing
Personnel
Miscellaneous administrative costs
TOTAL

Costs
$ 300
$20,175 (50 person-hours x $40.35 per hour)*
$
75
$20,550

* Wage rate figure is based on the following:
• The average grade level of staff included in this cost estimate is GS-11 step 5.
• The 2009 hourly base wage for a GS-11 step 5 Federal employee is $26.90.
• The total hourly wage with benefits is $40.35 ($26.90 base wage X 1.5 benefits
multiplier)
• Information was obtained from the Office of Personal Management
(http://www.opm.gov/oca/09tables/html/gs_h.asp)
15. Explain the reasons for program changes or adjustments reported in items 13 or 14
of the OMB Form 83-I.
We are reporting through this document no change in the hour burden of the IC budget due to
review of actual field data pertaining solely to annual “Limited Recipient Identification Sheet,”
“Trust information Sheet,” “Public Entity Information Sheet,” and “Religious or Charitable
Identification Sheet” completion.
16. For collections of information whose results will be published, outline plans for
tabulation and publication. Address any complex analytical technique that will be used.
Provide the time schedule for the entire project, including beginning and ending dates of
the collection of information, completion of report, publication date, and other actions.
The results of this IC are not intended for publication.
17. If seeking approval to not display the expiration date for OMB approval of the
information collection, explain the reasons that would make display inappropriate.
Reclamation also has landholder and district RRA forms that we submit to OMB for
approval on a biennial basis under OMB approval numbers 1006-0005 and 1006-0006. For
reasons detailed in the supporting statements for ICs 1006-0005 and 1006-0006, Reclamation
requests a 2-year (rather than 3-year) approval period in an effort to reduce the respondents’
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confusion by trying to correlate as much as possible the expiration of the RRA ICs with the end
of a water year.
The forms in this IC will display the OMB expiration date. However, we are requesting that
the OMB approval expiration date for this IC be December 31, 2011 (to coincide with the
closure date of Reclamation’s 2011 water year), instead of the usual 3 years from the date
OMB approval is issued. If granted, this will shorten the usual 3-year OMB approval timeframe
to 2 years, but the OMB approval schedule for the forms in this IC will then coincide with the
OMB approval schedule for the other two RRA ICs. Another request for OMB approval will be
initiated for this IC in advance of the 2012 and 2013 water years, concurrently with the OMB
approval requests for the other two RRA ICs.
18. Explain each exception to the certification statement identified in item 19,
“Certification for Paperwork Reduction act Submissions,” of OMB Form 83-I.
No exceptions to the certification statement are being requested.

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ATTACHMENT 1
List of information collection questions and justifications