Overview
Title
Submission for OMB Review; Comment Request
Agencies
ELI5 AI
The Defense Department wants to make sure that when they give old military places to towns to redevelop, the towns use the money from them to help the community grow for seven years. They're asking people to read their plan and say what they think by February 18, 2021.
Summary AI
The Department of Defense (DoD) is seeking public comment on a proposal submitted to the Office of Management and Budget (OMB) regarding the collection of information related to Revitalizing Base Closure Communities. This proposal would require Local Redevelopment Authorities (LRAs) that have received property from closed military installations to reinvest proceeds from its use to support economic redevelopment for at least seven years. The DoD aims to ensure compliance through annual financial statements. Comments can be submitted online by February 18, 2021.
Abstract
The DoD has submitted to OMB for clearance the following proposal for collection of information under the provisions of the Paperwork Reduction Act.
Keywords AI
Sources
AnalysisAI
The document in question is a public notice from the Department of Defense (DoD), which has been submitted to the Office of Management and Budget (OMB) for review. The notice seeks public comments on a proposal related to the collection of information under the Paperwork Reduction Act. Specifically, it pertains to Local Redevelopment Authorities (LRAs) responsible for properties from closed military installations. The main requirement is that these LRAs reinvest proceeds from these properties back into the community to support economic redevelopment for no less than seven years.
General Summary
The proposal aims to ensure that the proceeds from the use of properties obtained through Economic Development Conveyances (EDCs) are reinvested into the local communities from which they originate. To verify compliance, the LRAs are required to submit an annual financial statement certified by an independent Certified Public Accountant (CPA). The deadline for public comments is February 18, 2021, and the proposal impacts state and local governments.
Significant Issues and Concerns
An issue raised by the document is the lack of detailed information regarding the total cost or budget allocation for this information collection activity. Without this, it is difficult to assess whether the proposal is financially prudent.
There is also some ambiguity concerning the process by which the Secretary of Defense could recoup proceeds not used for redevelopment. Greater clarity on the recoupment criteria could help LRAs understand the full scope of their obligations.
The technical language used may pose challenges, especially for those unfamiliar with governmental or military processes. Simpler language could facilitate broader understanding and engagement from non-expert stakeholders.
The requirement for a certified financial statement could disproportionately burden smaller LRAs. These organizations might lack the financial resources to comply comfortably, potentially giving an advantage to larger entities.
Moreover, the proposal does not provide detailed compliance criteria beyond the submission of financial statements. This vagueness could lead to varying interpretations of what constitutes compliance, complicating uniform enforcement.
Finally, the absence of a standardized form could result in inconsistencies in reporting, potentially complicating the review process and making comparisons or evaluations more difficult.
Impact on the Public and Stakeholders
For the general public, this proposal reflects efforts to ensure that federal assets contribute positively to local economic conditions after military base closures. If successful, such activities could lead to revitalized communities and improved regional economies.
However, the potential challenges faced by LRAs, particularly smaller ones, suggest that some stakeholders might find compliance difficult. This could result in fewer organizations able to participate and benefit from such federal programs, potentially limiting local economic growth in some areas.
State and local governments, as the affected public, may face additional administrative burdens and financial obligations as part of this compliance process. The proposal requires careful consideration of resource allocation to meet its demands effectively.
In conclusion, while aiming for broad economic revitalization, the DoD's proposal comes with several issues that need addressing to achieve its intended outcomes effectively and equitably across various stakeholders.
Issues
• The document does not specify the total cost or budget allocation for the proposed information collection activity, making it unclear if the spending could be considered wasteful or excessive.
• Language regarding the recoupment process by the Secretary of Defense is somewhat ambiguous and could benefit from further clarification, specifically regarding under what circumstances and how the proceeds not used for redevelopment would be recouped.
• The explanation of requirements and obligations for Local Redevelopment Authorities (LRAs) might be too technical for those not familiar with military or governmental processes, potentially limiting accessibility and understanding.
• The need to certify financial statements by an independent Certified Public Accountant could burden smaller LRAs with limited budgets, potentially favoring larger organizations with more resources to comply.
• The document does not provide specific guidance or criteria for what constitutes compliance, only that it must be checked by an annual financial statement, which might be too vague and open to interpretation.
• Lack of a specific form requirement might lead to inconsistencies in how information is reported and evaluated, potentially complicating the review process.