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Comments on: Managing for Excellence – Action Items 26 & 27, Opportunities for Beneficial Transfer and/or Outsourcing of O&M Responsibilities, Draft Report, 07-23-07 Page 17: the list of “issues that should be considered by Reclamation when developing a transfer agreement” should include the following items: • the need for National Historic Preservation Act (NHPA) and National Environmental Policy Act (NEPA) compliance for the initial transfer of O&M • the need for NHPA and NEPA compliance for subsequent activities performed by the transferee Page 18: the list of “issues that should be considered when contracting for O&M services” should include the following items: • the need for NHPA and NEPA compliance for contracting for O&M • the need for NHPA and NEPA compliance for subsequent activities performed by the contractor Appendix C, first page, Level of Oversight: This section should discuss the need for Reclamation to receive advance notice of O&M activities so that NHPA and NEPA can be completed. Advance notice can be provided on a case by case basis, or in an annual work plan which lists the activities to be conducted in the coming year. Appendix C, fourth page, Nature or Complexity of Work: This section should also mention NHPA compliance as an activity which Reclamation must perform.	08/29/2007

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Comments on: Managing for Excellence – Action Items 26 & 27, Opportunities for Beneficial Transfer and/or Outsourcing of O&M Responsibilities, Draft Report, 07-23-07

Page 17: the list of “issues that should be considered by Reclamation when developing a transfer
agreement” should include the following items:

• the need for National Historic Preservation Act (NHPA) and National Environmental Policy Act (NEPA) compliance for the initial transfer of O&M
• the need for NHPA and NEPA compliance for subsequent activities performed by the transferee

Page 18: the list of “issues that should be considered when contracting for O&M services” should include the following items:

• the need for NHPA and NEPA compliance for contracting for O&M
• the need for NHPA and NEPA compliance for subsequent activities performed by the contractor

Appendix C, first page, Level of Oversight: This section should discuss the need for Reclamation to receive advance notice of O&M activities so that NHPA and NEPA can be completed. Advance notice can be provided on a case by case basis, or in an annual work plan which lists the activities to be conducted in the coming year.

Appendix C, fourth page, Nature or Complexity of Work: This section should also mention NHPA compliance as an activity which Reclamation must perform.

08/29/2007