20250225_Supporting_Statement_A (508)_WAUSP2024

Supporting Statement A for paperwork reduction act submission for the USGS WATER USE DATA ACQUISITION

OMB Control Number 1028-New

Terms of Clearance: None – new application

General Instructions: A completed Supporting Statement A 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 below. If an item is not applicable, provide a brief explanation. When the question “Does this ICR contain surveys, censuses, or employ statistical methods?” is checked "Yes," then a Supporting Statement B must be completed. OMB reserves the right to require the submission of additional information with respect to any request for approval.

Specific Instructions

Justification

1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection.

The SECURE Water Act (42 USC Ch. 109B SECURE WATER) authorizes the U. S. Geological Survey (USGS) to engage in water-use research and nationwide data-collection and monitoring activities to provide basic information needed to efficiently manage and use the water resources of the United States. The USGS Water Availability and Use Science Program (WAUSP) fulfills the Water Resources Mission Area's objectives to provide comprehensive water availability and use science to the Nation by advancing the understanding of processes that determine water availability. The WAUSP includes the USGS National Water Use Information Program and is responsible for compiling and disseminating the nation's water-use data. USGS has historically served as the lead agency for water information coordination among Federal agencies, per the OMB Memorandum 92-01, which recognized the collection of water information is “integrally tied to partnerships with non-Federal entities” and supported “effective working relationships with State and local agencies, with Indian Tribes, and with the private sector, as appropriate.” This information collection is necessary for the USGS to acquire water-use information needed to meet the administrative requirements of the above requirements.

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 information is used by USGS scientists for estimating water use by category including public-supply, domestic, irrigation, thermoelectric-cooling, industrial, mining, aquaculture, and livestock applications. Estimates of annual water use by category aggregated at the county and state level have been made every 5 years since 1950. Estimates beginning for year 2020 will be model-based, made at a higher temporal and spatial resolution than previous estimates, and derived from the data collected nationally for specific water-use facilities. The water use data collected through this information collection are used as model input, model validation data, and model verification of national water use estimates. The data are also used by national, regional, and local groundwater flow models, ecologic flow assessments, and water availability studies. Stakeholders, such as water resource managers, researchers, and institutions, rely on estimates of water availability and use for water-resource development, planning and management.

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.

The information is collected employing automated, electronic, and other technological methods to the maximum degree possible. Information is commonly collected by way of electronic database file attachments in email exchanges or by download of information from online databases maintained by the respondent state water-resources-management agencies. Respondent data are expected to be in different digital formats stored in local data systems, therefore, this collection does not provide a prescribed output, rather, it accepts data output with metadata in a machine-readable format and is then reformatted for entry into USGS database.

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.

Water-use data are unique in terms of specific categories of use, seasonal patterns and long-term trends, regional location, and operating characteristics of water-use establishments, such that the available historical data are insufficient to meet program goals related to national model-based estimates of water use. These data are not available in any other national data system, and annual updates/collections are needed.

5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.

The information collection will not significantly impact small businesses or entities as respondents are state or local water-resources management agencies that maintain this information as part of their normal operations.

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.

The collection aids in the USGS and Department of Interior reporting to Congress.  This new collection is important for estimating water use in the United States in that it is used by many USGS projects that are reported in various components to Congress. The next USGS report to Congress in planned to be delivered in 2026.  After the 2026 report, the next major deadline is to include estimates of water use up through 2025 in the National Water Census in 2028.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner:

* requiring respondents to report information to the agency more often than quarterly;

* requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;

* requiring respondents to submit more than an original and two copies of any document;

* requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records, for more than three years;

* 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;

* requiring the use of a statistical data classification that has not been reviewed and approved by OMB;

* 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; or

* requiring respondents to submit proprietary trade secrets, or other confidential information, unless the agency can demonstrate that it has instituted procedures to protect the information's confidentiality to the extent permitted by law.

There are no circumstances that require us to collect the information in a manner inconsistent with OMB guidelines.

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 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.

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.

Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every three 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.

On November 16, 2023, we published in the Federal Register (88 FR 78780) a notice of our intent to request that OMB approve this information collection. In that notice, we solicited comments for 60 days, ending on January 16, 2024.

We received the following comments in response to that Notice:

Comment 1: Is this a 60-day or 30-day notice? The text is confusing as to which it is. Also, the text refers to year 2020 in the future tense.

Agency Response to Comment 1: The link provided is to the 60-day notice. Regarding the reference to 2020, it was not a mistake, as models are being developed to estimate water use for 2020.  The models will continue to be expanded to estimate water use for additional years, 2021, 2022, etc.  We will work to clarify this in subsequent documents.

Comment 2: Can you send me the draft ICR materials, particularly the draft data-collection instruments and supporting statements parts A and B?

Agency Response to Comment 2: No response or action taken as data-collection instruments and supporting statements were not final.

In addition to the Federal Register Notice, we consulted with the seven (7) individuals from water-resource management agencies identified below, who are familiar with this collection of information, in order to develop our time burden estimate and asked for comments regarding the questions below. These or similar respondents at other state water-resource management agencies will also be contacted for feedback in the future.

Indiana Department of Natural Resources	402 W. Washington St., Rm W264, Indianapolis, IN, 46204
Source Protection and Water Appropriation Division, MDE	1800 Washington Blvd., Baltimore, MD, 21230
ODNR Division of Water Resources	2045 Morse Road, Building B-3", Columbus, OH
Oregon Water Resources Department	2045 Morse Road, Building B-3", Columbus, OH, 43229
Texas Water Development Board - Water Use and Planning Data	P.O. Box 13231, Austin,TX, 78711-3231
New Mexico Office of the State Engineer	PO Box 25102, Santa Fe, New Mexico, 87504
Delaware Department of Natural Resources and Environmental Control (DNREC)	89 Kings Hwy, Dover, DE, 19901

“Whether or not the collection of information is necessary, including whether or not the information will have practical utility; whether there are any questions they felt were unnecessary”

Comments: No comments were obtained as to the necessity and utility of the information collection, as the collection requests respondents merely provide the water-use data that the state agencies already collect as part of their normal water-resources-management activities.

“The accuracy of our estimate of the burden for this collection of information”

Comments: Outreach respondent estimates of time required to respond annually to this information collection ranged from one-half to 80 hours, with a median of about 5 hours.

Agency Response/Action Taken: These hours burden estimates were taken into consideration in preparing the respondent hours burden estimate, which is 4 hours annually. This was estimated recognizing that several state agencies place their water-use data online for public access as part of their routine operations, so in these cases there is little or no agency time burden for USGS to collect their information. Some state agencies are developing new online applications for public access of their water-use data, so overall state agency time burdens will diminish over time.

“Ways to enhance the quality, utility, and clarity of the information to be collected”

Comments: An outreach respondent reported desire to know more about USGS processing of their water-use data and to be provided the estimates of annual water use made by USGS. Another respondent reported they are implementing an upgrade to their water-use data-management system for improved efficiency.

Agency Response/Action Taken: USGS has in past year published reports and journal articles presenting methods and national estimates for annual water use in public supply, irrigation, and thermoelectric-power generation. USGS administers grant funding to state water-resources-management agencies to support enhancements to their water use databases, including automation of their state’s data collection and reporting.

“Ways to minimize the burden of the collection of information on respondents”

Comments: A variety of responses: 1) Information requests should be timely and well in advance of when information is needed. 2) USGS should prepare a list of data needs and expected timeline for reporting so that we can also plan ahead or update our annual work plan and timeline on our end accordingly. 3) USGS should continue supporting our efforts to get our new data management system up and running. It was estimated that the new system will be operational in 2 years. 4) We collect water use data regardless if we provided it to the USGS. Once the data is compiled, it is not a burden to provide the data to the USGS. 5) None - data requests of this nature are routine for our program.

Agency Response/Action Taken: USGS works with state agencies to facilitate exchange of water-use information, for example, by providing grants to state agencies for enhancement of their databases. A list of data needs is included as an attachment to this information collection and will be provided to respondents.

Additional comments received during the outreach:

Comments: Several comments: 1) I think we've been having a very good working relationship with the USGS. They give us enough time to prepare the data and are very responsive to our questions. We are looking forward to learning more about the USGS new annual estimates methods and hopefully being able to utilize the output data and methods for our annual estimates work. Additionally, it would be nice if the USGS regularly share their updates regarding the annual water use work (news, changes, progress, etc) with the state data providers. 2) No. We usually provide the data in spreadsheets and send it via email. 3) Suggestions to help my reporters get their data in on time?

Agency Response/Action Taken: USGS welcomes respondent feedback and ongoing collaborations to facilitate exchange of water-use information.

9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.

No payments or gifts are provided to the respondents.

10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

Any sensitive, nonpublic data with official, restricted data-use agreements or respondent agency confidentiality policies will not be released.

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 questions 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.

Not applicable--no sensitive questions are asked.

12. Provide estimates of the hour burden of the collection of information. The statement should:

* 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.

* If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens.

* Provide estimates of annualized cost to respondents for the hour burdens for collections 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.

We estimate that we will receive 160 responses totaling 640 burden hours. We estimate the annual dollar value of the burden hours is $39,300. We used $61.37 per hour including benefits for state and local government workers, as reported in the of Bureau of Labor Statistics (BLS) News Release USDL-24-1863, September 10, 2024, Employer Costs for Employee Compensation—June 2024, to calculate the cost of the total annual burden hours.

Annual Number of Potential Respondents	Annual Number of Responses	Estimated Completion Time per Respondent (hours per year)	Total Annual Burden Hours	Dollar Value of Burden Hour (Including Benefits)	Total Dollar Value of Annual Burden Hours
160	160	4	640	$61.37	$39,300

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 already reflected in item 12.)

* The cost estimate should be split into two components: (a) a total capital and start-up cost component (annualized over its expected useful life) and (b) 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 for form processing). 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.

* 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.

* 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 the 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.

We have identified no reporting and recordkeeping “non-hour cost” burdens associated with this proposed collection of information.

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, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information.

The estimated annual cost to the Federal Government is $1,503,500 as itemized below showing Federal Staff and grade level performing various tasks associated with this collection of information and time spent processing and reviewing information received as a result of this collection. Year 2025 federal pay rates were used (SALARY TABLE 2025-RUS (opm.gov)).

Position	Grade/ Step	Hourly Rate	Hourly Rate Incl. Benefits (1.7 X Hourly Pay Rate)	Total Annual Hours	Annual Cost
WUDM Function Manager	GS 13/1	$50.49	$85.83	400	$34,333
Hydrologists – 3 Data Specialist Support (400 hours each per year)	GS 12/1	$42.46	$72.18	1200	$86,618
52 Hydrologists: USGS State Water-Use Specialists (400 hours each per year)	GS 12/1	$42.46	$72.18	20800	$1,501,386
Total				22,400	$1,622,337

15. Explain the reasons for any program changes or adjustments in hour or cost burden.

Not applicable—this is a new information collection.

16. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques 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 dates, and other actions.

This will be on-going information collection without an ending date. Statistical analyses will be only for the purpose of data quality assurance reviews. Data will be stored in the internal-only USGS Water Use Data System (WUDS) and used for purposes of developing and training machine-learning and other models used for estimation of water use nationally. Any sensitive, nonpublic data with official, restricted data-use agreements will not be released.

17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

Not applicable.

18. Explain each exception to the topics of the certification statement identified in "Certification for Paperwork Reduction Act Submissions."

Not applicable. No exceptions to the certification are being made.

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