Managing for Excellence - Submit a Comment

U.S. Department of the Interior | Reclamation Internet

Search Reclamation

Reclamation Home

Managing for Excellence

Submit Comment

U.S. Department
of the Interior

Back To Comments Home
Comment	Submit Date
Opportunities for Beneficial Transfer and/or Outsourcing of O&M Responsibilities Managing for Excellence Action Items 26 & 27 – 7/23/07 Draft Benefits of O&M Transfer, p.13 – to assist the reader in getting a complete set of information and for Reclamation to provide full disclosure, the Team should consider adding a Cost of O&M Transfer Section. O&M transfer may be economically beneficial from some perspectives, but there are hidden costs, both economically and socially, to the taxpayer which include environmental compliance, habitat loss, hazardous material spills and cleanup, proper care for historic properties, reduced Federal oversight, and the potential for reduced public access to the facilities and information. O&M Transfer Opportunities, p.16, 1st paragraph – Because many of Reclamation’s facilities are historic properties, and because transferees mostly lack the knowledge and skill of how to value and appropriately protect and preserve historic properties it is imperative that heritage preservation be cited with equal vigor as public safety and design/construction. The following language is recommended: “The O&M entity is generally given broad authority to perform many of Reclamation’s responsibilities. Reclamation, as owner of the facility, remains accountable for certain responsibilities related to public safety, design/construction, and historic preservation and cannot transfer those responsibilities.” List of issues that should be considered by Reclamation when developing a transfer agreement, p.17 – Recommend adding to this list specific reference to Historic property management and Indian trust assets. These are significant enough to get separate listing, rather than be subsumed under Environmental commitments. O&M Contracting Opportunities, p.18, 1st paragraph – The term “stewardship” generally refers to ownership and conveys a sense of heightened accountability rather than day-to-day management and control. Recommend changing “stewardship” to “involvement.” Appendix C, O&M Transfer, Environmental Commitments – Identifying cultural resources as an environmental commitment is important, however, its mere mention here does not convey the significant issues involved with management of heritage properties. Both Reclamation staff who prepare O&M transfer agreements and the prospective O&M Service provider must understand that in many cases the O&M provider will be occupying and managing historic properties. It is critical for Reclamation that this knowledge is worked into the day-to-day O&M activities, and that all decisions made by the O&M service provider incorporate heritage assets considerations. In addition, historic property and heritage asset issues must be separated from other Environmental Commitments and placed under its own heading.	09/10/2007

Back To Comments Home

Comment

Submit Date

Opportunities for Beneficial Transfer and/or Outsourcing of O&M Responsibilities

Managing for Excellence Action Items 26 & 27 – 7/23/07 Draft

Benefits of O&M Transfer, p.13 – to assist the reader in getting a complete set of information and for Reclamation to provide full disclosure, the Team should consider adding a Cost of O&M Transfer Section. O&M transfer may be economically beneficial from some perspectives, but there are hidden costs, both economically and socially, to the taxpayer which include environmental compliance, habitat loss, hazardous material spills and cleanup, proper care for historic properties, reduced Federal oversight, and the potential for reduced public access to the facilities and information.

O&M Transfer Opportunities, p.16, 1st paragraph – Because many of Reclamation’s facilities are historic properties, and because transferees mostly lack the knowledge and skill of how to value and appropriately protect and preserve historic properties it is imperative that heritage preservation be cited with equal vigor as public safety and design/construction. The following language is recommended:

“The O&M entity is generally given broad authority to perform many of Reclamation’s responsibilities. Reclamation, as owner of the facility, remains accountable for certain responsibilities related to public safety, design/construction, and historic preservation and cannot transfer those responsibilities.”

List of issues that should be considered by Reclamation when developing a transfer agreement, p.17 – Recommend adding to this list specific reference to Historic property management and Indian trust assets. These are significant enough to get separate listing, rather than be subsumed under Environmental commitments.

O&M Contracting Opportunities, p.18, 1st paragraph – The term “stewardship” generally refers to ownership and conveys a sense of heightened accountability rather than day-to-day management and control. Recommend changing “stewardship” to “involvement.”

Appendix C, O&M Transfer, Environmental Commitments – Identifying cultural resources as an environmental commitment is important, however, its mere mention here does not convey the significant issues involved with management of heritage properties. Both Reclamation staff who prepare O&M transfer agreements and the prospective O&M Service provider must understand that in many cases the O&M provider will be occupying and managing historic properties. It is critical for Reclamation that this knowledge is worked into the day-to-day O&M activities, and that all decisions made by the O&M service provider incorporate heritage assets considerations. In addition, historic property and heritage asset issues must be separated from other Environmental Commitments and placed under its own heading.

09/10/2007