FACT SHEET 11

May 2004

WHAT CONSTITUTES A 

LANDHOLDING CHANGE? 

 

Reclamation Reform Act of 1982 (RRA) 

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LANDHOLDING CHANGES AND THE RRA FORMS REQUIREMENTS

What if My Landholding Changes During an Irrigation Season?

Section 426.18(k) of the Acreage Limitation Rules and Regulations (43 CFR part 426) provides that if a

landholder's ownership or leasing arrangements change in any way after submitting RRA forms for a

particular water year and that change occurs during an irrigation season, the landholder must notify

the district, either verbally or in writing, within 30 calendar days of the change and submit new

standard RRA forms to all districts where nonexempt land is held (directly or indirectly owned or leased)

within 60 calendar days of the change. An exception to this requirement is if the landholder has

finished receiving Bureau of Reclamation (Reclamation) irrigation water for the water year in question

before the 60-calendar-day time period expires. In such cases, landholders must submit new standard

RRA forms before receiving Reclamation irrigation water in the next water year. 

L Nonexempt land means either irrigation land or irrigable land that is subject to the acreage

limitation provisions.

What if My Landholding Changes Do Not Occur During an Irrigation Season?

If a landholding change occurs outside the irrigation season, the landholder must submit new

standard RRA forms to all districts in which nonexempt land is held prior to receiving any Reclamation

irrigation water following such changes.

An exception to this requirement is if a landholder submits a standard RRA form in advance of the

upcoming irrigation season, and a landholding change occurs after submission of the RRA form but

before the start of Reclamation irrigation water deliveries. Because the landholder has already

submitted an RRA form for the water year in question, the landholder must notify the district, either

verbally or in writing, within 30 calendar days of the change and submit new standard RRA forms to

all districts where nonexempt land is held (directly or indirectly owned or leased) within 60 calendar

days of the change.

What if I am a New Landholder in a District?

L A new landholder is considered to be an individual, legal entity, or public entity that did not

directly or indirectly own or lease land in a specific district during the water year immediately
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preceding the water year in question. For RRA forms submittal purposes only, a landholder

whose landholding changes from “not exceeding” to “exceeding” the district’s applicable

RRA forms submittal threshold during the water year will be considered to be a

“new landholder.” 

The time period for submitting new standard RRA forms when landholding changes occur does not

apply to new landholders because it only applies after the initial RRA form submittal for a water year

has occurred. New landholders who acquire land through purchase or lease (either directly or

indirectly through entities) must submit standard RRA forms before receiv ing any Reclamation

irrigation water on land subject to the acreage limitation provisions. This even applies to a landholder

who has RRA forms on file in other districts and becomes a landholder in yet another district. That

landholder must have an RRA form on file in the new district before he/she/it receives Reclamation

irrigation water on land in that district, although the landholder will have 60 calendar days to file new

RRA forms in the other districts.

General Exception to the Landholding Change Requirements

If a landholding change results in a landholder’s westwide landholding no longer exceeding the

applicable RRA forms submittal threshold, the landholding change requirements are not applicable.

The remainder of this Fact Sheet highlights what constitutes a landholding change.

WHAT CONSTITUTES A LANDHOLDING CHANGE?

Direct Landholders

Landholders who hold land DIRECTLY must submit either a standard or verification form on an annual

basis. They are also required to submit new standard RRA forms in the time periods specified above if

they experience a landholding change. Some examples of landholding changes that require the submittal

of new standard RRA forms are:

1. Change in the number of acres owned or leased.

2. Change in the specific parcels owned or leased.

3. Change in who is the lessor or lessee.

4. Change in the effectiv e date or term (length) of a lease. However, a 

Form 7-21VERIFY, “Verification of Landholdings,” may be submitted annually in 

place of a new standard RRA form if all the following conditions are met:

(a) You are ONLY renewing or extending the length of an existing annual lease which 

(i) has an effective term of 12 months or less and (ii) has either a clause requiring the

parties to agree annually to continue the lease or provides an annual opportunity for

withdrawal from the lease;

(b) The renewal or extension is for a term of 12 months or less; AND

(c) There is no change in the lessor(s), lessee(s), or land being leased. 
FACT SHEET 11 (continued)

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5. Change in the acreage limitation status of the landholder (i.e., change from being

subject to prior law to being subject to discretionary provisions, or change from being a

qualified recipient to being a limited recipient).

6. Change in the identity of the landholder (i.e., change in marital status or death of 

a landholder).

If land does not pass directly to the surviving spouse (i.e., an estate or trust is created),

a landholding change has occurred. However, the RRA form(s) filed by the deceased

landholder for the current water year will remain valid until the next water year

PROVIDED (1) the applicable land was eligible to receive Reclamation irrigation water while

held by the deceased, and (2) the applicable land remains in the holding of the entity or

individual that initially involuntarily acquired the land upon the landholder's death. If either of

these criteria is not met, or if the deceased landholder failed to file an RRA form for the

current water year, an RRA form(s) must be filed by the appropriate party(ies) before any

eligible land can receive Reclamation irrigation water. 

If the land in question should leave the holding of the entity or individual that initially

involuntarily acquired the land, the landholding change provisions are immediately applicable. 

In any event, the appropriate standard RRA forms must be filed by all applicable landholders

prior to receiving Reclamation irrigation water for the water year immediately following

the landholder’s death.

7. Change in the number of part owners or beneficiaries.

8. Change in the percentage or acreage of the legal entity's holding attributed to

any part owner or beneficiary.

9. Change in the number of excess acres.

L All requests for redesignations of land (from excess to nonexcess or from

nonexcess to excess) must be accompanied by a new standard RRA form and a

new Form 7-21XS, "Designation of Excess Land." If Reclamation approval is

required for a redesignation, these forms must be submitted to Reclamation 

and the redesignation approved in writing before the forms are filed with the

district. A copy of the approval letter should be attached to the new Form 7-21XS.

10. Change in lands selected as full cost. However, landholders who wish to change the

lands selected as full cost and who are otherwise eligible to submit a Form 7-21VERIFY are

not required to submit a new standard RRA form. Such landholders need to only submit

Form 7-21VERIFY and a new Form 7-21FC, "Selection of Full-Cost Land," if RRA forms

are being submitted for a new water year. If RRA forms have already been submitted for a

water year and the landholder would like to reselect the nonfull-cost and full-cost lands with

no other landholding change, that action may be taken by submitting only a

Form 7-21FC to the district(s) if the following criteria are met:

(a) the landholder has not already received Reclamation irrigation water during the water

year in question on a westwide landholding that equals or exceeds the applicable

nonfull-cost entitlement; AND
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(b) the land the landholder wants to reselect as nonfull-cost or full cost has not yet

received Reclamation irrigation water during the water year in question. The district

must be able to verify that the land in question has not yet been irrigated with such

water or the original selection will stand.

11. Change in the Internal Rev enue Serv ice classification of a legal entity from a

partnership to a corporation, or v ice v ersa.

12. Transfer of directly owned land from a landholder to a 100-percent family-owned

entity (this does not include adding a “doing business as” [dba] name).

When a landholding change occurs between a lessee and a sublessor, it is the the lessee and

sublessor that must each submit a new standard RRA form within 60 calendar days of the change. 

The lessor (from whom the lessee leases the land) does not have to submit a new standard RRA form.

Indirect Landholders

Landholders that hold land ONLY INDIRECTLY through a legal entity must complete an initial standard

RRA form. Generally, such landholders are not required to submit any RRA forms in subsequent years

UNLESS one of the following occurs:

1. A direct purchase or lease of land subject to the acreage limitation provisions by a part

owner.

2. Acquisition of additional land that is held indirectly through a legal entity.

3. Any change by the entity that results in an alteration to the information included on the part

owner’s RRA forms, such as the amount of acreage attributed to the part owner(s).

4. A change to the acreage limitation status or identity (e.g., change in marital status) of the part

owner. NOTE: A change to the acreage limitation status of a partnership, tenancy,

corporation, or other legal entity does not affect the acreage limitation status of its part

owners.

In the cases described immediately above, a new standard RRA form must be submitted by the

landholder within the time periods specified at the beginning of this Fact Sheet.

L Any change in land attributed to a part owner, including beneficiaries of trusts or estates,

constitutes a landholding change regardless of who initiates the action. For example, if the

landholding of a trust should be changed by a trustee or grantor, then new standard RRA forms

must be submitted for, at a minimum, the trust and any affected beneficiary.

Landholders Who Hold Land Directly and Indirectly

Landholders who hold land BOTH directly and indirectly are required to submit either a standard

RRA form or Form 7-21VERIFY on an annual basis. In addition, if any of the landholding changes listed

on this Fact Sheet should occur, these landholders must submit new standard RRA forms within the time

periods specified at the beginning of this Fact Sheet.
FACT SHEET 11 (continued)

Mission of the Bureau of Reclamation: To manage, develop, and protect water and related resources in an environmentally and economically sound

manner in the interest of the American public.

The Department of the Interior has established a 24-hour toll-free telephone number (1-800-424-5081) for anyone wishing to report suspected violations

of the Reclamation Reform Act of 1982 (RRA). Anyone reporting suspected violations will be protected under Federal privacy laws.

Distributed by the Bureau of Reclamation, United States Department of the Interior.

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WHAT DOES NOT CONSTITUTE A LANDHOLDING CHANGE?

When a spouse dies and land passes directly to the surviving spouse, no landholding change has

occurred. However, before the surviving spouse receives Reclamation irrigation water during the next

water year, a new standard RRA form will be required because the marital designation would change

and only one signature would be required. 

If a landholding change results in a landholder’s westwide landholding no longer exceeding the district’s

applicable RRA forms submittal threshold, the landholding change requirements are not applicable.

L The information prov ided abov e DOES NOT include all possible changes which may

require the submittal of new standard RRA forms. If you hav e questions about

whether a specific change will require the submittal of a new RRA form, contact your

district or the appropriate Reclamation office.

NEED MORE INFORMATION?

For questions about: See Fact Sheet:

When and where RRA forms must be filed 1

A complete list of RRA forms 1

Signature requirements for RRA forms 10

Also visit www.usbr.gov/rra for more information.