-------
                                                                  11/8/84
           EPA POLICY FOR THE ADMINISTRATION OF ENVIRONMENTAL
                      PROGRAMS ON INDIAN RESERVATIONS
INTRODUCTION
     The President published a  Federal  Indian Policy on January  24, 1983,
supporting the  primary  role  of  Tribal  Governments  in  matters  affecting
American Indian  reservations.   That  policy  stressed  two  related  themes:
(1) that  the  Federal   Government  will   pursue  the  principle  of  Indian
"self-government" and (2) that it will work directly with Tribal
Governments on a "government-to-government" basis.

     The Environmental  Protection Agency  (EPA) has previously issued general
statements of policy which  recognize the importance  of  Tribal  Governments
in regulatory activities  that  impact reservation environments.   It  is the
purpose of this statement to consolidate  and  expand on existing EPA Indian
Policy statements in a manner consistent  with the  overall  Federal position
in support of Tribal  "self-government" and "government-to-government" rela-
tions between Federal  and Tribal  Governments.   This statement  sets forth
the principles that will  guide the Agency  in dealing with Tribal Governments
and in responding to the  problems of environmental  management  on American
Indian reservations in order  to protect human health  and  the environment.
The Policy is intended to provide  guidance for  EPA program managers in the
conduct of  the   Agency's  congressionally mandated  responsibilities.   As
such, it  applies  to  EPA only  and  does  not  articulate  policy  for other
Agencies in the conduct of their respective responsibilities.

     It is  important  to  emphasize that  the  implementation  of  regulatory
programs which will  realize these  principles  on  Indian Reservations cannot
be accomplished  immediately.   Effective  implementation  will take  careful
and conscientious work by EPA,  the Tribes and many  others.  In many cases,
it will require changes in applicable statutory authorities and regulations.
It will be necessary  to  proceed in  a carefully  phased way,  to learn from
successes  and failures, and to  gain  experience.  Nonetheless, by beginning
work on the priority problems that exist now and continuing in the direction
established under these principles,  over time we can significantly enhance
environmental quality on reservation  lands.

POLICY

     In carrying  out  our  responsibilities  on  Indian  reservations,  the
fundamental objective of  the  Environmental  Protection Agency is to protect
human health  and  the  environment.  The  keynote  of  this effort  will  be to
give special  consideration  to  Tribal  interests  in making  Agency  policy,
and to  insure  the  close  involvement   of Tribal   Governments   in  making
decisions  and managing environmental  programs affecting reservation lands.
To meet this  objective,   the  Agency  will  pursue the following principles:

-------

-------
                                    -3-
4.   THE AGENCY WILL TAKE APPROPRIATE STEPS TO REMOVE EXISTING LEGAL AND
PROCEDURAL IMPEDIMENTS TO WORKING DIRECTLY AND  EFFECTIVELY  WITH TRIBAL
GOVERNMENTS ON RESERVATION PROGRAMS.

     A number of serious  constraints  and  uncertainties in the language
of our statutes and  regulations have limited our  ability to work directly
and effectively  with  Tribal  Governments  on  reservation  problems.   As
impediments in  our  procedures,  regulations or  statutes  are identified
which limit our ability to work effectively with Tribes consistent with
this Policy, we will seek to remove those  impediments.

5.   THE AGENCY, IN KEEPING WITH THE FEDERAL TRUST RESPONSIBILITY, WILL
ASSURE THAT TRIBAL CONCERNS AND INTERESTS  ARE CONSIDERED WHENEVER EPA'S
ACTIONS AND/OR DECISIONS MAY AFFECT RESERVATION ENVIRONMENTS.

     EPA recognizes that  a  trust  responsibility derives  from the his-
torical relationship  between  the  Federal  Government  and  Indian Tribes
as expressed  in  certain treaties and  Federal  Indian Law.   In  keeping
with that  trust  responsibility, the  Agency  will  endeavor  to  protect
the environmental  interests  of  Indian Tribes  when  carrying  out  its
responsibilities that may affect the reservations.

6.   THE AGENCY WILL ENCOURAGE COOPERATION BETWEEN TRIBAL, STATE AND
LOCAL GOVERNMENTS TO RESOLVE  ENVIRONMENTAL PROBLEMS  OF  MUTUAL CONCERN.

     Sound environmental planning and management require the cooperation
and mutual  consideration  of  neighboring  governments,  whether  those
governments be neighboring States,  Tribes,  or  local units of government.
Accordingly, EPA  will  encourage  early  communication and  cooperation
among Tribes,  States  and local governments.  This  is not  intended to
lend Federal  support to  any one  party  to the  jeopardy of the interests
of the.other.  Rather, it recognizes that  in the field of environmental
regulation, problems  are  often  shared  and  the principle   of  comity
between equals  and  neighbors  often serves the  best  interests of both.

7.   THE AGENCY WILL WORK WITH OTHER FEDERAL AGENCIES WHICH HAVE RELATED
RESPONSIBILITIES ON  INDIAN  RESERVATIONS TO  ENLIST  THEIR  INTEREST AND
SUPPORT IN  COOPERATIVE  EFFORTS  TO  HELP   TRIBES  ASSUME  ENVIRONMENTAL
PROGRAM RESPONSIBILITIES FOR RESERVATIONS.

     EPA will  seek  and promote  cooperation between  Federal agencies to
protect human  health  and  the environment  on  reservations.   We  will
work with  other agencies to clearly identify and delineate the roles,
responsibilities and  relationships  of  our  respective organizations and
to assist  Tribes in  developing and  managing environmental programs for
reservation lands.

-------
                                      -4-
8.  THE AGENCY  WILL STRIVE TO ASSURE COMPLIANCE WITH  ENVIRONMENTAL STATUTES
    AND REGULATIONS ON INDIAN RESERVATIONS.

     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 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 those cases  where  reservation  facilities 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 on Indian  reservations  as the Agency  would to noncompliance  by the
private sector elsewhere  in  the  country.   Where the Tribe has  a  substantial)
proprietary interest  in,   or  control  over,  the privately owned  or  managed
facility, EPA  will  respond  as  described  in  the  first  paragraph  above..

9.   THE AGENCY WILL INCORPORATE THESE INDIAN POLICY GOALS INTO ITS PLANNING !
AND MANAGEMENT ACTIVITIES, INCLUDING ITS BUDGET, OPERATING GUIDANCE, LEGISLA-
TIVE INITIATIVES,   MANAGEMENT ACCOUNTABILITY  SYSTEM AND  ONGOING  POLICY  ANp
REGULATION DEVELOPMENT PROCESSES.

     It is a  central purpose of  this effort  to  ensure that  the principles
of this Policy  are effectively  institutionalized  by incorporating  them into
the Agency's ongoing and long-term planning and management processes.   Agency
managers will include specific programmatic actions  designed  to resolve probj-
lems on Indian reservations in the Agency's existing fiscal  year and long-term
planning and management processes.
                                    William D. Ruckelshaus

-------
              UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                            WASHINGTON. D.C. 20460
                                    NOV   8 1984
                                                                     OFFICE OF

MEMORANDUM
SUBJECT:  Indian Policy Implementation Guidance
                           ~
FROM:     Alvin L. Aim
          Deputy Administrator

TO:       Assistant Administrators
          Regional Administrators
          General Counsel
                            INTRODUCTION
     The Administrator has  signed  the attached EPA  Indian  Policy.   This
document sets  forth  the  broad principles that  will  guide the  Agency in
its relations with American Indian Tribal Governments and in the adminis-
tration of EPA programs on Indian reservation lands.

     This Policy  concerns  more  than one  hundred  federally-recognized
Tribal Governments and  the environment  of  a  geographical  area  that is
larger than  the  combined  area  of the  States  of  Maryland,  New  Jersey,
Connecticut, Massachusetts, Vermont,  New Hampshire and Maine.   It  is an
important sector of  the  country, and constitutes the  remaining  lands of
America's first stewards  of the  environment,  the  American Indian Tribes.

     The Policy places a  strong  emphasis on incorporating Tribal  Govern-
ments into  the operation  and management  of  EPA's  delegable  programs.
This concept is based  on  the  President's Federal  Indian Policy published
on January  24,  1983  and the  analysis,   recommendations and  Agency  input
to the  EPA  Indian  Work  Group's  Discussion  Paper,   Administration of
Environmental Programs on American Indian Reservations  (July 1983).
                          TIMING AND SCOPE
     Because of the  importance  of the reservation environments,  we must
begin immediately to incorporate the  principles  of EPA's  Indian Policy
into the  conduct  of  our everyday  business.   Our  established  operating
procedures (including long-range budgetary and operational planning acti-
vities) have not consistently  focused on the proper  role of Tribal Govern-
ments or the  special legal  and political problems  of  program management
on Indian lands.   As a  result,  it will  require  a phased  and  sustained
effort over time  to  fully implement the principles of the  Policy and to
take the steps outlined in this Guidance.

-------
                                    -2-                                  '
                                                                         I
     Some Regions and Program  Offices have already made  individual  starts
along the  lines  of  the  Policy  and  Guidance.   I  believe  that  a  clear
Agency-wide policy will  enable all programs to  build on these  efforts  'so
that, within the limits of our legal  and  budgetary constraints,  the Agency
as a whole can make respectable progress in the next year.               j
                                                                         i
     As we begin the  first year  of operations under  the  Indian  Policy,  we
cannot expect to  solve  all  of the  problems  we will  face in administering
programs under the  unique legal  and  political circumstances presented  by
Indian reservations.  We  can, however, concentrate  on  specific  priority
problems and issues and proceed  to address these  systematically and care-
fully in the  first year.  With  this  general  emphasis,  I believe that  we
can make  respectable  progress and  establish   good  precedents  for  working
effectively with Tribes.  By  working within  a manageable scope and pace,
we can develop a  coordinated base which can be expanded, and, as appropriate,
accelerated in the second and  third years of  operations  under the Policy.

     In addition to routine application of the Policy and this  Guidance in
the conduct of our everyday business, the first year's implementation effort
will emphasize concentrated  work  on  a discrete  number  of  representative
problems through cooperative  programs or  pilot projects.  In the  Regions,
this effort  should  include  the  identification and  initiation  of work  on
priority Tribal projects. At  Headquarters, it  should  involve the resolution
of the legal,  policy  and procedural  problems  which hamper our  ability to
implement the kinds of projects identified by the Regions.              i

     The Indian Work  Group  (IWG),  which is chaired by the Director  of the
Office of Federal Activities  and  composed of representatives of key  regional
and headquarters  offices,  will  facilitate and  coordinate these  efforts.
The IWG  will   begin   immediately  to  help  identify  the   specific  projects
which may  be  ripe for  implementation and the problems needing  resolution
in the first year.

     Because we  are   starting  in  "mid-stream,"  the  implementation  effort
will necessarily  require  some contribution  of  personnel  time  and  funds.
While no one program will be affected in a major fashion,  almost  all  Agency
programs are  affected to  some degree.   I  do   not  expect  the  investment in
projects on  Indian  Lands  to cause  any  serious restriction in the States'
funding support  or  in their  ability to function  effectively.  To  preserve
the flexibility  of each  Region and each program,  we  have  not  set  a target
for allocation of  FY  85 funds.  I  am confident,  however, that Regions and
program offices can,  through  readjustment of existing  resources,  demonstrate
significant and  credible progress  in  the  implementation of EPA's Policy in
the next year.

-------
                                    -3-

                                   ACTION
     Subject to these constraints, Regions  and program managers  should now
initiate actions to  implement the  principles  of  the  Indian  Policy.   The
eight categories  set forth  below will  direct our  initial  implementation
activities.  Further guidance  will  be  provided by the  Assistant  Adminis-
trator for External  Affairs as experience indicates a need for such guidance.

     1.  THE  ASSISTANT  ADMINISTRATOR  FOR  EXTERNAL  AFFAIRS  WILL  SERVE  AS
LEAD AGENCY  CLEARINGHOUSE  AND  COORDINATOR  FOR  INDIAN  POLICY  MATTERS.

     This responsibility  will  include  coordinating  the  development  of
appropriate Agency guidelines pertaining to Indian issues, the
implementation of the   Indian  Policy  and  this Guidance.   In this  effort
the Assistant  Administrator  for  External  Affairs  will  rely  upon  the
assistance and support of the EPA Indian Work Group.

     2.  THE  INDIAN  WORK  GROUP (IWG)  WILL ASSIST AND SUPPORT THE ASSISTANT
ADMINISTRATOR FOR EXTERNAL AFFAIRS  IN DEVELOPING  AND RECOMMENDING DETAILED
GUIDANCE AS NEEDED  ON  INDIAN POLICY  AND IMPLEMENTATION MATTERS.  ASSISTANT
ADMINISTRATORS, REGIONAL  ADMINISTRATORS  AND   THE   GENERAL  COUNSEL  SHOULD
DESIGNATE APPROPRIATE REPRESENTATIVES  TO THE  INDIAN WORK GROUP AND PROVIDE
THEM WITH  ADEQUATE   TIME  AND  RESOURCES  NEEDED  TO  CARRY  OUT  THE  IWG'S
RESPONSIBILITIES UNDER  THE  DIRECTION  OF THE  ASSISTANT ADMINISTRATOR  FOR
EXTERNAL AFFAIRS.

     The Indian Work Group,  (IWG)  chaired  by  the  Director  of the Office of
Federal Activities,   will  be  an  important  entity  for consolidating  the
experience and advice  of  the key Assistant and Regional Administrators on
Indian Policy matters.  It  will  perform the  following functions:  identify
specific legal,  policy,  and  procedural  impediments  to working  directly
with Tribes  on  reservation  problems;  help  develop  appropriate  guidance
for overcoming such impediments; recommend opportunities for implementation
of appropriate  programs or  pilot projects;  and perform other  services  in
support of Agency managers in implementing the  Indian Policy.

     The initial task  of  the  IWG will  be  to  develop  recommendations  and
suggest priorities  for  specific  opportunities for  program implementation
in the first  year of operations under the Indian Policy and this Guidance.

     To accomplish this, the General  Counsel and each Regional and Assistant
Administrator must  be  actively represented  on the  IWG by  a  staff  member
authorized to  speak  for  his  or  her  office.   Further,  the  designated
representative(s) should  be  afforded  the  time  and  resources,  including
travel, needed  to  provide  significant staff  support to the  work  of the
IWG.

-------
                                     -4-
3.  ASSISTANT AND REGIONAL ADMINISTRATORS SHOULD UNDERTAKE ACTIVE OUTREACH AND
LIAISON WITH  TRIBES,  PROVIDING  ADEQUATE  INFORMATION TO  ALLOW THEM TO  WORK
WITH US IN AN INFORMED WAY.

     In the  first  thirteen years  6f  the  Agency's existence,  we  have  worked
hard to  establish  working  relationships  with  State  Governments,  providing
background information  and  sufficient interpretation and  explanations  to
enable them  to  work effectively  with us  in  the development  of  cooperative
State programs under our various statutes.  In a similar manner, EPA managers
should try  to  establish   direct,  face-to-face  contact  (p'referably  on  the
reservation) with Tribal  Government  officials.   This liaison is essential to
understanding Tribal needs, perspectives and priorities.  It will  also foster
Tribal understanding of  EPA's programs and procedures  needed  to  deal  effec-
tively with us.

4.  ASSISTANT AND  REGIONAL ADMINISTRATORS SHOULD ALLOCATE RESOURCES  TO MEET
TRIBAL NEEDS, WITHIN THE  CONSTRAINTS IMPOSED BY  COMPETING PRIORITIES  AND BY
OUR LEGAL AUTHORITY.

    As Tribes move to  assume  responsibilities similar to those borne  by EPA
or State  Governments,  an  appropriate  block   of  funds must  be set aside to
support reservation abatement, control and compliance activities.

     Because we want to begin to implement the  Indian  Policy  now,  we cannot
wait until FY 87 to formally budget for programs on Indian lands.  Accordingly,
for many  programs,  funds  for initial  Indian projects in  FY  85 and  FY 86
will need to come from  resources currently  planned for  support to  EPA-and
State-managed programs meeting  similar objectives.   As I stated  earlier, we
do not expect to  resolve  all  problems and  address all environmental  needs on
reservations immediately.   However,   we  can make   a significant  beginning
without unduly restricting our ability to fund ongoing programs.

     I am asking  each  Assistant Administrator and  Regional  Administrator to
take measures within his or her discretion and authority to provide sufficient
staff time and grant funds to allow the Agency to initiate projects on Indian
lands in  FY  85 and  FY 86 that  will  constitute  a  respectable step  towards
implementation of the  Indian Policy.

5.  ASSISTANT AND REGIONAL ADMINISTRATORS, WITH LEGAL SUPPORT PROVIDED BY THE
GENERAL COUNSEL, SHOULD  ASSIST TRIBAL GOVERNMENTS  IN PROGRAM  DEVELOPMENT AS
THEY HAVE DONE FOR THE STATES.

     The Agency has  provided extensive  staff work and assistance to State
Governments over  the  years   in  the  development  of  environmental  programs
and program  management capabilities.  This  assistance has  become  a  routine
aspect of  Federal/State  relations,   enabling  and  expediting  the  States'
assumption of-delegable programs under the various EPA statutes.  This "front
end" investment  has  promoted  cooperation  and   increased State  involvement
in the regulatory process.

-------
                                      -5-

     As the  Agency   begins  to  deal   with  Tribal  Governments  as partners  in
reservation environmental  programming,  we will  find  a  similar  need for  EPA
assistance.  Many  Regional  and  program  personnel   have  extensive  experience
in working  with  States  on  program  design  and  development; their  expertise
should be used to assist Tribal Governments where needed.
                                     /

6.  ASSISTANT ADMINISTRATORS,  REGIONAL ADMINISTRATORS AND THE GENERAL
COUNSEL SHOULD TAKE  ACTIVE STEPS  TO  ALLOW  TRIBES  TO  PROVIDE  INFORMED  INPUT
INTO EPA'S  DECISION-MAKING AND PROGRAM  MANAGEMENT ACTIVITIES  WHICH  AFFECT
RESERVATION ENVIRONMENTS.

     Where EPA   manages  Federal  programs  and/or  makes  decisions  relating
directly or  indirectly to  reservation  environments,  full   consideration  and
weight should be given  to  the public policies,  priorities  and concerns  of the
affected Indian Tribes  as  expressed  through their Tribal  Governments.   Agency
managers should make  a special  effort  to inform Tribes  of  EPA  decisions  and
activities which  can  affect their reservations  and  solicit their input  as  we
have done with State Governments.  Where necessary,  this should include provid-
ing the necessary  information, explanation  and/or  briefings  needed  to  foster
the informed  participation  of Tribal  Governments   in  the  Agency's  standard-
setting and policy-making activities.

7.  ASSISTANT  AND   REGIONAL  ADMINISTRATORS  SHOULD,  TO THE  MAXIMUM  FEASIBLE
EXTENT, INCORPORATE TRIBAL  CONCERNS, NEEDS  AND  PREFERENCES  INTO EPA'S  POLICY
DECISIONS AND PROGRAM MANAGEMENT ACTIVITIES AFFECTING RESERVATIONS.

     It has been EPA's  practice to  seek  out and accord  special  consideration
to local  interests  and concerns,  within  the  limits allowed  by  our statutory
mandate and  nationally  established  criteria and  standards.  Consistent  with
the Federal and  Agency policy to  recognize  Tribal   Governments  as the primary
voice for expressing public policy on reservations,   EPA managers should,  within
the limits of their  flexibility,  seek and utilize Tribal input and preferences
in those situations where  we  have  traditionally  utilized  State or local  input.

     We recognize that  conflicts  in  policy,  priority  or preference  may  arise
between States and  Tribes  as  it does between neighboring States.   As  in the
case of conflicts between neighboring States, EPA will  encourage early communi-
cation and cooperation between Tribal  and  State Governments to  avoid and resolve
such issues.  This is  not  intended to lend  Federal  support to any one party in
its dealings with the  other.   Rather, it recognizes that in  the field of environ-
mental regulation,  problems are often shared  and  the  principle of  comity between
equals often serves the interests of both.

     Several of the environmental statutes  include a  conflict resolution mechan-
ism which  enables EPA to use  its good offices to balance  and resolve the con-
flict.  These procedures can  be applied to  conflicts  between Tribal  and State
Governments that cannot  otherwise  be resolved.  EPA can play  a moderating role
by following the conflict resolution principles  set  by the statute, the Federal
trust responsibility and the  EPA Indian Policy.

-------
                                   -6-

8.  ASSISTANT ADMINISTRATORS, REGIONAL ADMINISTRATORS AND THE GENERAL COUNSEL
SHOULD WORK COOPERATIVELY  WITH  TRIBAL  GOVERNMENTS TO ACHIEVE COMPLIANCE WITH
ENVIRONMENTAL STATUTES  AND  REGULATIONS  ON  INDIAN  RESERVATIONS,  CONSISTENT
WITH THE PRINCIPLE OF INDIAN SELF-GOVERNMENT.

     The EPA Indian Policy recognizes Tribal Governments as the key
governments having  responsibility  for  matters  affecting  the  health  and
welfare of the Tribe.  Accordingly, where tribally owned or managed
facilities do  not  meet   Federally  established  standards,  the Agency  will
endeavor to work with the Tribal leadership to enable the Tribe to
achieve compliance.   Where  reservation  facilities  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  on  Indian  reservations as  we  do  to  noncompliance by  the
private sector off-reservation.

     Actions to  enable  and   ensure  compliance  by   Tribal  facilities  with
Federal statutes and regulations include providing consultation and
technical support  to  Tribal leaders  and  managers  concerning the  impacts
of noncompliance on Tribal health and the reservation environment
and steps  needed  to  achieve  such  compliance.   As  appropriate,  EPA  may
also develop compliance agreements with Tribal Governments and work
cooperatively with  other  Federal  agencies  to  assist  Tribes  in  meeting
Federal standards.

     Because of  the  unique   legal  and  political  status  of   Indian  Tribes
in the Federal System, direct EPA actions against Tribal facilities
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.   Regional  Administrators  proposing  to   initiate  such  action
should first obtain concurrence  from the Assistant Administrator for Enforce-
ment and Compliance Monitoring,  who will  act in consultation with the Assis-
tant Administrator for External  Affairs  and  the General  Counsel.  In emergency
situations, the Regional  Administrator may issue  emergency Temporary Restrain-
ing Orders,  provided that  the   appropriate  procedures   set  forth  in  Agency
delegations for such actions are followed.

-------
                                       -7-
9.  ASSISTANT  ADMINISTRATORS,  REGIONAL  ADMINISTRATORS AND  THE GENERAL  COUNSEL
SHOULD BEGIN TO  FACTOR INDIAN  POLICY GOALS  INTO  THEIR LONG-RANGE  PLANNING AND
PROGRAM MANAGEMENT ACTIVITIES,  INCLUDING BUDGET,  OPERATING  GUIDANCE,  MANAGEMENT
ACCOUNTABILITY SYSTEMS AND PERFORMANCE STANDARDS.

     In order  to  carry out  the principles  of  the  EPA  Indian Policy and  work
effectively with Tribal Governments  on a long-range basis,  it  will  be necessary
to institutionalize  the  Agency's  policy goals  in the  management  systems  that
regulate Agency behavior.  Where we have systematically incorporated State needs,
concerns and cooperative  roles into  our budget,  Operating  Guidance,  management
accountability systems and performance standards, we must now begin to factor the
Agency's Indian Policy goals into these same procedures and activities.

     Agency managers  should begin  to  consider Indian  reservations  and  Tribes
when conducting  routine   planning  and  management  activities  or  carrying  out
special policy analysis  activities.    In  addition, the IWG,  operating under the
direction of the Assistant Administrator for External Affairs and with
assistance from the  Assistant  Administrator  for Policy,  Planning and Evaluation,
will identify  and  recommend  specific steps  to be taken  to ensure that  Indian
Policy goals are  effectively incorporated and  institutionalized in  the Agency's
procedures and operations.

Attachment

-------