EPA Region 4 Policy and Practices for Environmental Protection in Indian Country (November, 2001)
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TABLE OF CONTENTS
EPA/State/Tribal Relations (July 10, 1991) (PDF, 58K)
DISCLAIMER NOTICE TO THE PUBLIC: The policies set out herein are not final Agency action, but are intended solely as guidance. They are not intended, nor can they be relied upon, to create any right, benefit or responsibility enforceable by any party in litigation with the United States. EPA decision officials may decide to follow the policies provided in this memorandum, or to act at variance with it, based on an analysis of specific circumstances. The Agency reserves the right to change this guidance at any time without public notice.
The U.S. Environmental Protection Agency (EPA), Region 4, has developed this document to provide guidance and information to Regional managers and staff. This guidance is intended to respond to and clarify questions that are most frequently raised by our internal and external customers and constituents, relating to: (1) Agency protocol in working with federally recognized Tribes,1 (2) Agency support of federally recognized tribal governments in building capacity to manage environmental programs, and (3) Agency positions on environmental program responsibilities and jurisdiction.
In November 1984, Administrator Ruckelshaus formally signed and adopted the “EPA POLICY FOR THE ADMINISTRATION OF ENVIRONMENTAL PROGRAMS ON INDIAN RESERVATIONS” (attached). Subsequently, Administrator Reilly in February 1990 and Administrator Browner in March 1994 formally reaffirmed the 1984 Indian Policy. Although much has been accomplished in the intervening years, much of the work of establishing environmental programs on Indian Reservations remains to be done. Thus, in recognition of its responsibility to human health and the environment throughout the Region, Region 4 has adopted this Policy to implement the 1984 EPA Indian Policy and to meet Region 4 goals as specified in the Agency Strategic plan, developed in response to the Government Performance and Results Act of 1993.
The overarching task in implementing the 1984 Indian Policy is to develop and implement environmental programs for Indian Country2 that are as comprehensive and thorough as necessary to protect human health and the environment in Indian Country. This effort will emphasize the central role of tribal government cooperation with EPA in environmental protection, and will give high priority to developing EPA/tribal partnerships patterned after the EPA/state partnerships already in place.
The Region's approach to implementing the 1984 Indian Policy is presented only in part in the guidance of this policy document. Additional information about Regional program implementation may be obtained from the Indian Program Coordinator and may be published on the Region 4 Indian Program Coordination Office’s web site.
There are four foundational principles which define the EPA role in environmental activities in Indian Country, derived from Treaty and Constitutional law, Supreme Court and lower court decisions, Public Laws as passed by the Congress, and Executive Orders and Memoranda:
(1) Trust Responsibility. EPA will protect resources (the environment and human health) as a fiduciary for the benefit of the Tribes. This implies a higher degree of protection than is due the average citizen of the U.S.
(2) The Government to Government Relationship. EPA will consult with the Tribes at all phases of planning and implementation activities, and will implement a broad range of cooperative actions with Tribes.
(3) Tribal Self-Determination. EPA recognizes that Tribes have the inherent authority to govern themselves, and will assist in program development and delegation to the extent requested and allowed by law.
(4) Direct Implementation. EPA has the responsibility to oversee all programs in Indian Country within its statutory and regulatory authority where not delegated or authorized to be operated by Tribes. EPA will protect human health and the environment using a variety of program styles, including full EPA program implementation, cooperative program operations with Tribes, and delegation of programs to Tribal governments, as permitted by law and encouraged by policy.
In order to apply these principles, EPA is committed to these activities:
(1) Consultation. Region 4 will communicate with tribal governments before making decisions, or changing policy, on environmental matters affecting tribal governments and/or tribal natural resources (other than certain enforcement actions.)
(2) Cooperation between Governments and Agencies. Region 4 will encourage cooperation between tribal, federal, state and local governments to address environmental issues. Region 4 will work cooperatively with other federal agencies to protect reservation environments.
(3) Public Participation. Region 4 will work with tribal governments to encourage the development of public participation processes as part of authorized or delegated tribal environmental programs.
The federal government has broad jurisdiction over pollution sources throughout the United States, including Indian Country. EPA presumes that, in general, Tribes are likely to possess the authority to regulate activities which are regulated by EPA statutes and which affect resources on the reservation. States generally do not have regulatory authority in Indian Country3. Region 4 retains responsibility for direct federal implementation of all programs in Indian Country in the absence of an authorization/delegation to a State or Tribe. States applying to administer federal environmental programs within Indian Country must adequately demonstrate their jurisdiction to do so.
The 1984 EPA Indian Policy states clearly that EPA recognizes tribal governments as the “... primary parties for setting standards, making environmental policy decisions and managing programs for reservations consistent with Agency standards and regulations.” It goes on to state:
“The Agency will assist interested tribal governments in developing programs and in preparing to assume regulatory and program management responsibilities for reservation lands....Until tribal governments are willing and able to assume full responsibility for delegable programs, the Agency will retain responsibility for managing programs for reservations.”
In accordance with the Agency's national policy, Region 4 supports tribal government assumption and management of environmental programs for Indian Country, to the maximum extent permitted by law. Until such programs are in place, Region 4 retains responsibility for direct implementation of environmental programs for Indian Country in the Region. Most of the programs for which Region 4 is responsible are regulatory programs requiring enforcement of environmental standards and rules. Accordingly, jurisdiction is an important factor in policies and decisions relating to the assumption and management of regulatory programs in Indian Country. Jurisdiction in Indian Country is a matter of federal law, based upon the U.S. Constitution, treaties, statutes and decisions of the federal courts.
EPA generally does not give "advisory" opinions on state and
tribal jurisdiction. To date, EPA has given opinions on state and tribal
jurisdiction only when faced with a federal decision, such as an application
for "treatment in the same manner as a state," or request for
program approval, that requires a prior determination of jurisdiction.
In such cases, EPA has based its decision upon the relevant statutes and
principles of Federal Indian Law, Executive Orders, treaties, and other
documents. The Agency has, in appropriate cases, consulted with legal
experts in the Department
of the Interior and the Department of Justice, and the Agency has had the benefit of the views of States, Tribes and other interested parties as part of a public record.
Region 4 is responsible for direct implementation of environmental programs for Indian Country in the Region until tribal governments are formally authorized to implement programs, consistent with (1) the criteria set forth in EPA statutes and regulations, (2) the principle, reflected in the 1984 EPA Indian Policy, that tribal governments are the appropriate non-Federal parties for making decisions and carrying out program responsibilities affecting Indian reservations, their environments, and the health and welfare of the reservation populace, and (3) the objective, reflected in the 1991 EPA/State/Tribal Concept Paper (attached) of providing for coherent and consistent environmental regulation on reservations and preventing checkerboarding. To the extent permitted, Region 4 will provide grant or contract support to Tribes to manage all or part of the Federal program.
(1) Direct Implementation. Region 4 will establish priorities for its direct federal implementation activities by addressing as its highest priority the most serious threats to public health and the environment in Indian Country that are not otherwise being adequately addressed substantively. This priority implements the mandate of the EPA and the principle that the primary focus in Indian Country will be to protect human health and the environment.
(2) Budgeting and Activity Plans. Region 4 will incorporate the expressed priorities of the Tribes into its annual budget request and activities plan preparations. The final budget request of the EPA as a whole is prepared by the Office of Management and Budget for the President.
(3) Program Management. Region 4 is responsible for program management in Indian Country. As it sets priorities and implements environmental protection activities, Region 4 will work with the affected tribal governments to reach agreement on program management issues.
(4) Standards. Region 4 will work with tribal governments in the development and adoption of environmental standards (e.g., water quality standards) for Indian Country under control of the Tribes. All standards must meet applicable federal requirements.
(5) Grant Support. Region 4 may provide grant support (as appropriate and to the extent permitted by applicable law) to a Tribe to develop or manage all, or part of, a federal environmental program. Region 4 may provide grant or contract support to a State to manage all or part of a federal program if the Tribe and State have reached a freely negotiated/mutually agreeable, written arrangement for the management (other than enforcement) of a federal program in Indian Country, to include funding support to the state.
(6) Permits. Region 4 is responsible for issuing permits in
Indian Country until a tribal permitting program expressly applying to
Indian Country is formally authorized. EPA will ensure
regular compliance inspections and appropriate enforcement of permits, in consultation with the appropriate tribal government and environmental staff.
(7) Enforcement Actions. Region 4 has primary enforcement authority and responsibility, until primacy is formally granted to a tribal or state government that has demonstrated adequate jurisdiction over Indian Country. On January 17, 2001, EPA issued “Guidance on the Enforcement Principles Outlined in the 1984 Indian Policy” (attached). The Region also has issued an enforcement Directive (also attached) which delineates internal enforcement procedures. EPA retains criminal enforcement authority for cases involving Indian lands.
Region 4 will strive to ensure compliance with environmental statutes and regulations in Indian Country as set forth in the 1984 Indian Policy which states:
"In those cases where facilities owned or managed by tribal governments are not in compliance with federal environmental statutes, EPA will work cooperatively with tribal leadership to develop means to achieve compliance, providing training, technical support and consultation as necessary to enable tribal facilities to comply. Because of the distinct status of Indian Tribes and the complex legal issues involved, direct EPA action through the judicial or administrative process will be considered where the Agency determines, in its judgment, that: (1) a significant threat to human health or the environment exists, (2) such action would reasonably be expected to achieve effective results in a timely manner, and (3) the Federal Government cannot utilize other alternatives to correct the problem in a timely fashion."
In cases where facilities in Indian Country are clearly owned or managed by private parties and there is no substantial tribal interest or control involved, the Agency will endeavor to act in cooperation with the affected tribal government, but will otherwise respond to noncompliance by private parties in Indian Country in a similar manner as the Agency would respond to noncompliance in the private sector elsewhere in the country.
(8) Treatment as a State Determinations. Region 4 is responsible for approving the request of a Tribe to be treated in the same manner as a state (TAS) under certain federal programs. As these requests are received, the program staff will consult with the Regional Indian Program Coordinator (IPC) and the Region 4 Indian Program Attorney (Indian Attorney) when these requests are received to start the determination process. The TAS process is often the subject of scrutiny, and a set of procedures has been written to ensure that the process is complete and properly documented. The Indian Attorney is the Region 4 expert for this process, and will work with the program staff and the Tribe during the approval process. The Indian Attorney will also hold a permanent record of all TAS determinations.
Relations with federally recognized Indian tribal governments should be characterized by open communication and consultation. At this time, operation of EPA programs in conjunction with Tribes is conducted somewhat differently from the standard operating procedures of EPA, so it is necessary to delineate protocol to reduce the chance of misunderstanding or error.
The IPC has been assigned the task of overview, analysis and integration of the Regional programs that protect human health and the environment in Indian Country. It is incumbent upon the management and staff of Region 4 to implement programs as well as foster the relationship between the EPA and the Tribes in the southeast. This policy and protocol has been developed to assist the Agency in its daily operations; the IPC will work with each tribal government to determine what, if any, additions or modifications to the following protocol needs to be made, and publicize those changes within the Region.
1. It is the policy and practice of EPA Region 4 to notify the six Tribes of new policies, proposed regulations, or changes in policies and practices which significantly affect those Tribes, and provide for an opportunity for Tribes to consult with the Region prior to implementing those changes. This consultation process shall be flexible and allow enough time for the Tribes to select their level of involvement and discussion with EPA. Access to pertinent, routine governmental processes is part of the government-to-government relationship between EPA and those Tribes. This process is expressly designed to give the Tribes the opportunity to participate in the design and modification of EPA activities which affect them.
2. It is the responsibility of the Assistant Regional Administrator for Policy and Management (ARA) or appropriate Division Director to notify the Tribes in Region 4 of proposed changes in policy or practice. This responsibility not only applies to written policies, but to all agency processes where public notice or Federal Register notice is involved, and to other areas where there is significant Tribal government involvement. It is also the responsibility of the Divisions to educate policy makers and managers of their responsibility as to the notification and consultation process with Tribes.
3. Notification must be provided in writing, to the appropriate Tribal Chief or Chairman and tribal environmental official, in order to allow consultation with those Tribes. A copy of that correspondence must be sent to the IPC.
4. Tribes shall be given the opportunity to respond in writing, request telephone consultation and explanation, and/or request a meeting to provide more thorough explanations and an opportunity to discuss the issues.
1. Regional employees scheduling trips to Indian Country within the Region will inform the IPC of the intended inspection or visit, to allow for tracking of potential non-compliance issues as well as to avoid overlapping visits by staff from multiple programs. Notice will also be provided to the respective Tribe.
2. Regional Administrator/Deputy Regional Administrator non-issue-specific visits to Indian Country will be coordinated by the IPC, including coordinating the pre-visit briefing.
3. Region 4 inspectors will notify the Tribal Chief/Chairman and the tribal environmental official (typically a director of a department who reports to the chief or chairman) of inspections in Indian Country at least seven calendar days prior to the inspection, in writing. It is to be expected that Tribal environmental staff will accompany EPA inspectors on inspections within Indian Country. Other criteria and procedures for unannounced inspections may be developed in conjunction with a Tribe, EPA programs, and the IPC. Inspectors will offer entrance and exit interviews concerning inspections to the appropriate Tribal Chair and tribal environmental official.
4. In environmental emergency situations (for example, a determination of imminent and substantial endangerment) in Indian Country, the program staff will notify the Tribal Environmental Official and the IPC of the inspection/visit by phone, and coordinate activities with the Tribe to the extent it is possible.
5. Region 4 employees will take photographs of reservation areas only for official use and with tribal permission. The Tribe may designate a tribal official to accompany the photographer.
6. Generally, state government inspectors will not accompany EPA inspectors into Indian Country. If state inspectors request to accompany EPA to a reservation site, Region 4 will inform the tribal environmental official of the state's request, consider whether the state has any jurisdictional interest in an inspection, then consult with the Tribe (to include at minimum a written communication with follow-up verbal discussion), and will defer to the Tribe's conclusion on whether state inspectors will accompany EPA to the site. In Region 4, states generally do not have environmental program authority over Indian Country. The IPC will provide specific regulatory information to the States as necessary on program authorities in conjunction with the Indian Attorney. Inspectors will refer state inspectors to the IPC and/or Indian Attorney for further discussions as necessary, including those issues where the state agency has concerns about potential cross-boundary issues.
This section contains procedures for handling written correspondence with Tribal government officials or staff. A Tribe may request other procedures for any of these items, and the IPC will be responsible for communication of any changes in these procedures within Region 4.
1. Letters to the Regional Administrator from Tribal Chairs will be answered within ten working days of receipt and will be prepared for the Regional Administrator's signature using the controlled correspondence system. A copy of the letter from the Tribe (and control sheet where generated) will be provided to the IPC. The letters will be assigned, as appropriate, to the Assistant Regional Administrator, or Division or Office Director. The response will be routed through the IPC for concurrence.
If a response cannot be provided by the ten-day deadline, the program staff will consult with the IPC and reply in writing to the Tribal Chair and/or the Tribal Environmental Official indicating that the letter has been received and that a reply is being prepared. An explanation of the delay and an anticipated date of reply will be provided.
2. Letters from Tribal Officials that involve specific program issues and are directed to Division Directors or the ARA will be answered by program staff for signature by the appropriate ARA or Division Director, or his/her designee. A copy of the letter from the Tribe (and control sheet where generated) will be provided to the IPC.
3. EPA will send letters conveying inspection findings regarding non-tribally owned facilities in Indian Country to the tribal environmental official with a copy to the Tribal Chair/Chief, unless the Tribe has requested another practice. These letters will be routed via the IPC for concurrence. (Compliance and enforcement procedures are addressed later in this document.) Final inspection reports will be provided upon completion of the report to the tribal environmental official; however, if there are preliminary results or conclusions that identify significant environmental problems, the Tribal Chair, tribal environmental official, and IPC must be notified immediately.
4. EPA or State inspection reports on sites situated outside Indian Country that may have an impact on people or the environment in Indian Country will be forwarded by EPA to the appropriate Tribal Environmental Official. The IPC will act as conduit as necessary.
5. EPA or Tribal inspection reports on sites situated in Indian Country that indicate an impact on people or the environment outside Indian Country will be forwarded to the appropriate State Environmental Official. The IPC will act as conduit as necessary.
6. The disclosure of inspection reports to a Tribe or State will be consistent with regulation and policy on disclosure of EPA records and confidentiality of business information in 40 CFR Part 2. Region 4 will make the fullest possible disclosure consistent with the regulation and policy.
7. Grant documentation signed by the ARA or his/her designee, will be sent directly to the Tribal Chair with a copy to the tribal environmental official. Copies of all cover letters will be sent to the IPC.
8. Letters of decision involving broad policy issues, grant and program eligibility determinations, jurisdictional issues, delegations and significant enforcement actions (as defined in program-specific enforcement response policies) will be prepared for the signature of the Regional Administrator or Division Director as appropriate, and sent to the Tribal Chair. The IPC and Indian Attorney will be included in the preparation and concurrence process. A courtesy copy will be sent to the tribal environmental official.
1. The ARA and Division/Office Directors will notify the IPC and the Regional Administrator/Deputy Regional Administrator of upcoming visits by Tribal Chairs.
2. Visiting Tribal Chairs will be invited to meet with the Regional Administrator or Deputy Regional Administrator.
3. Region 4 staff will notify the IPC of tribal environmental official’s visits so that additional meetings can be scheduled where necessary or requested, and to avoid the scheduling of reservation visits by other EPA staff needing to meet with those officials.
The 1984 EPA Indian Policy outlines nine principles for ensuring that the Agency carries out its responsibilities on Indian reservations. The third principle asserts that EPA “... will take affirmative steps to encourage and assist Tribes in assuming regulatory and program management responsibilities for reservation lands.” This principle guides EPA in its development of a tribal capacity-building policy which will assist tribal governments in developing programs and in preparing to assume regulatory and program management responsibilities in Indian Country.
EPA views tribal governments as the appropriate party for making decisions and carrying out program responsibilities affecting the health and welfare of the reservation population and environment where they can demonstrate the capability and authority to do so. In order to achieve the Agency objective of protecting the environment and human health in Indian Country, in a manner consistent with support of tribal self-government, EPA will assist Tribes in developing the technical, fiscal, and administrative infrastructure necessary to implement environmental protection programs.
EPA is cognizant of the differences between Tribes and States, and among Tribes. In assisting Tribes in building environmental capacity, EPA will be sensitive to the unique qualities of each Tribe, including varying customs, beliefs, environmental protection experience and technical, fiscal, and administrative infrastructure.
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A. ACTIVITIES TO INCREASE CAPACITY
Region 4 programs and the IPC will provide outreach, education, training, and financial and legal assistance to develop, implement, and maintain comprehensive tribal environmental programs; and will pursue funding sufficient for every Tribe to have the ability to assess problems, rank risks, develop adequate infrastructure, and develop a core program tailored to that Tribe's specific needs. These objectives will be incorporated into the Annual Strategic, Operating and Budget Plans and any Tribal/EPA agreements.
1. Region 4 will work directly with each Indian Tribe to provide guidance and assistance for building tribal capacity, to include identification of resources and measurement of progress.
2. Region 4 will provide appropriate financial and programmatic oversight for every grant based on the needs of the Indian Tribe receiving funding, consistent with statutory and regulatory requirements. As Tribes demonstrate continuous improvement in grants management and program development, oversight will be adjusted accordingly. This oversight will include providing necessary program specific grant guidance.
3. EPA will provide training and assistance to address technical, fiscal management, and administrative capacity needs, as identified in consultation with the Tribes. This assistance will be coordinated with the Indian Program Coordination Office, so that the IPC may provide process guidance to program personnel developing technical assistance or training curricula specific to tribal programs.
4. Region 4 is committed to building tribal environmental capacity by
working with Tribes in the field. We will provide hands-on training in
applied methods (inspection, laboratory analysis, sampling, and testing)
appropriate to each reservation.
5. Region 4 will make personnel available through short-term details, Intergovernmental Personnel Act (IPA), or similar assignments, to assist Tribes in developing environmental protection programs to the extent practicable and allowable. Region 4 will also encourage tribal representatives to visit both the Atlanta, and Athens, Georgia, offices.
Region 4 will authorize tribal governments to manage environmental programs in Indian Country, if permitted to do so by law and if the Tribe applies and is qualified. Tribal governments are encouraged, but not required, to assume program responsibilities. Tribal applications for program authorization will be approved if the applicant meets the criteria for program approval under the relevant EPA statutes and regulations. Although Region 4 must be assured that the applicant has met the minimum criteria for program effectiveness set forth in regulations, the Region recognizes the need for flexibility to respond to the special circumstances and legal status of Indian Tribes. Where Region 4 has approved a tribal program, Region 4 will assist and support it in carrying out its responsibilities under the program or agreement.
As stated in the 1984 Indian Policy, where a Tribe is unwilling or unable to assume full responsibility under a program, the Agency will encourage the Tribe to participate in policy-making and to assume appropriate lesser or partial roles in the management of federally implemented programs.
Region 4 will look to the Bureau of Indian Affairs (BIA) and the Tribes for guidance concerning the boundaries of reservations and other parts of Indian Country. Relevant federal agency maps (e.g., BIA, Bureau of Land Management, U.S. Geological Survey) while possibly not legally definitive, are useful for general planning purposes. Questions as to the exact location of specific sites may need to be carefully researched.
EPA encourages cooperative agreements between Tribes, States and EPA where appropriate, for administering environmental programs in Indian Country, where this serves the mutual self-interest of the parties and the environment, as provided in the 1984 Indian Policy. The EPA American Indian Environmental Office issued policy guidance dated May 22, 1995 on tribal/state cooperative agreements. The policy guidance includes the following guidelines:
1. First and foremost EPA should be building tribal capacity and comprehensive
tribal environmental programs so that Tribes can truly negotiate with
states on an equal level to mutually determine a course of action to adequately
protect common resources.
2. Agreements should be recognized by the Tribe as a reasonable option to address their environmental concerns and the Tribe should initiate the process when the agreement is being developed to address tribal need.
3. EPA should provide financial and technical support to the Tribes during the development and implementation of the agreements to help ensure that the Tribes are truly in a position to freely negotiate and fully address their environmental concerns.
4. Agreements do not replace formal promulgation of a federal program or a delegation/authorization of a tribal program. Agreements are simply one tool, among many, for program implementation. The programs to be carried out under such agreements must still meet federal minimums/standards as set forth in the Code of Federal Regulations.
5. Agreements do not abrogate the Agency's statutory and trust responsibilities for protecting tribal health and environments in a manner which does not endanger or compromise fundamental governmental rights of the Tribe.
6. Agreements do not, independent of explicit Congressional intent or judicial finding, confer regulatory jurisdiction.
In promulgating direct, federally-implemented programs, Region 4 will accommodate cooperative agreements (to the extent permitted by applicable law) between a Tribe and a state where this serves the mutual self-interest of the parties and the environment. Region 4 participation in cooperative agreements will be governed by any national guidance that EPA may develop in the future. If, after review4, Region 4 finds that these agreements are freely negotiated and mutually beneficial, Region 4 will honor these agreements, provided that:
The Tribe and state agree upon consistent environmental standards and regulatory requirements within Indian Country.
Enforcement of standards and regulatory requirements in Indian Country is the lead responsibility of the Tribe or Region 4.
Where a Tribe cannot demonstrate jurisdiction over one or more reservation pollution sources, the Agency will retain enforcement responsibility for those sources.
Regional Administrator Date
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1 The use of “Tribes”, where capitalized in this document, refers to federally recognized Indian tribes, their governments, members, and/or their environmental agencies responsible for environmental programs.
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2 This directive uses the term "Indian
Country" as defined in 18 U.S.C. 1151 to mean "(a) all land
within the limits of any Indian reservation under the jurisdiction of
the United States Government, notwithstanding the issuance of any patent,
and including rights-of-way running throughout the reservation, (b) all
dependent Indian communities within the borders of the United States whether
within the original or subsequently acquired territory thereof, and whether
within or without the limits of a state, and (c) all Indian allotments,
the Indian titles to which have not been extinguished, including rights
of way running through the same." It is cautioned that various federal
statutes may use or define other terms (e.g., reservations) that will
control the applicability of a particular statute in Indian Country.
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3 In Region 4, the relationship between
South Carolina and the Catawba Indian Nation is an exception to this rule.
In matters affecting the Catawba Indian Nation, please refer to the Region
4 Indian Attorney for specific jurisdiction counseling.
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4 Such reviews should consider,
at a minimum (a) whether the Tribe has sufficient technical capability
needed to negotiate effectively, (b) whether there are any inequitable
factors that would impose duress on the Tribe or otherwise place it in
a disadvantaged position, and (c) whether the tribal/state agreement adversely
affects or compromises the interests of other, similarly-situated Tribes.
If a Tribe requests assistance from Region 4 to ensure a fair bargaining
position, Region 4 will try to provide such assistance.
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