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United States Government Accountability Office: 
GAO: 

Testimony: 

Before the Subcommittee on Technology, Information Policy, 
Intergovernmental Relations and Procurement Reform, Committee on 
Oversight and Government Reform, House of Representatives: 

For Release on Delivery: 
Expected at 1:30 p.m. EDT:
Thursday, April 7, 2011: 

Indian Issues: 

Observations on Some Unique Factors that May Affect Economic Activity 
on Tribal Lands: 

Statement of Anu K. Mittal, Director:
Natural Resources and Environment: 

GAO-11-543T: 

GAO Highlights: 

Highlights of GAO-11-543T, a statement before the Subcommittee on 
Technology, Information Policy, Intergovernmental Relations and 
Procurement Reform, Committee on Oversight and Government Reform, 
House of Representatives. 

Why GAO Did This Study: 

Indian tribes are among the most economically distressed groups in the 
United States. In 2008, the U.S. Census Bureau reported that the 
poverty rate among American Indian and Alaska Natives was almost twice 
as high as the population as a whole-—27 percent compared with 15 
percent. Residents of tribal lands often lack basic infrastructure, 
such as water and sewer systems, and sufficient technology 
infrastructure. Without such infrastructure, tribal communities often 
find it difficult to compete successfully in the economic mainstream.
This testimony statement summarizes GAO’s observations on (1) five 
broad categories of unique issues that may create uncertainty and 
therefore affect economic activity in Indian country and (2) tribes’ 
use of special gaming and small business contracting provisions. It is 
based on prior GAO reports. 

This testimony statement contains no new recommendations. 

What GAO Found: 

GAO’s previous work has identified five broad categories of unique 
issues that may create uncertainty for tribes or, in some cases, 
private companies wishing to pursue economic activities on Indian 
reservations. 

Accruing land in trust. Having a land base is essential for tribal 
economic development activities such as agriculture, energy 
development, and gaming. However, a February 2009 Supreme Court 
decision has raised uncertainty about the process for taking land in 
trust for tribes and their members. 

Tribal environmental standards. The Clean Water Act, Safe Drinking 
Water Act, and Clean Air Act authorize the Environmental Protection 
Agency to treat Indian tribes in the same manner as states. In some 
cases, however, states are concerned that tribes with this authority 
may impose standards that are more stringent than the state standards, 
which could result in a patchwork of standards within the state and 
potentially hinder economic activity. 

Indian tax provisions. Tribes face uncertainties regarding the types 
of activities that they can finance with tax-exempt bonds. Also, in 
2008, GAO reported that there were insufficient data to (1) identify 
the users of a tax provision that allows for accelerated depreciation 
of certain property used by businesses on Indian reservations and (2) 
assess whether the provision had increased economic development on 
Indian reservations. 

Obtaining rights-of-way. Securing rights-of-way across Indian land is 
important in providing Indian lands with the infrastructure needed to 
support economic activity. In 2006, GAO reported that obtaining rights-
of-way through Indian lands was a time-consuming and expensive process.
Legal status of tribes. The unique legal status of tribes has resulted 
in a complex set of rules that may affect economic activities. For 
example, Indian tribes have sovereign immunity, which can influence a 
business’s decision to contract with a tribe. Also, the limitations 
imposed by federal law on Indian tribes’ civil jurisdiction over non-
Indians on Indian reservations can create uncertainties over where 
lawsuits arising out of contracts with tribes can be brought. 

In contrast to these unique issues that may pose challenges to 
economic activity in Indian country, some Indian tribes have taken 
advantage of special provisions for gaming and small business 
contracting. The National Indian Gaming Commission reports that tribal 
gaming operations generated $26.5 billion in revenue for 2009. 
However, not all tribes have gaming operations and the majority of the 
revenue is generated by a fraction of the operations. Similarly, 
Alaska Native Corporations (ANC) have been granted special procurement 
advantages. In 2006, GAO reported that obligations to firms owned by 
ANCs that participated in the Small Business Administration’s 8(a) 
program increased from $265 million in fiscal year 2000 to $1.1 
billion in 2004. We have ongoing work looking at the use of these 
special procurement advantages. 

View [hyperlink, http://www.gao.gov/products/GAO-11-543T] or key 
components. For more information, contact Anu K. Mittal at (202) 512-
3841 or mittala@gao.gov. 

[End of section] 

Chairman Lankford, Ranking Member Connolly, and Members of the 
Subcommittee: 

I am pleased to be here today to participate in your hearing on the 
challenges of trying to increase economic activity in Indian Country. 
Indian tribes are among the most economically distressed groups in the 
United States. For example, in 2008, the U.S. Census Bureau reported 
that American Indians and Alaska Natives were almost twice as likely 
to live in poverty as the rest of the population--27 percent compared 
with 15 percent. Residents of tribal lands also often lack basic 
infrastructure, such as water and sewer systems, and sufficient 
technology infrastructure, such as telecommunications lines that are 
commonly found in other American communities. Without such 
infrastructure, tribal communities often find it difficult to compete 
successfully in the economic mainstream. 

Our testimony today will cover (1) five broad categories of unique 
issues that may create uncertainty and therefore affect economic 
activity in Indian Country--land issues, tribal environmental 
standards, Indian tax provisions, rights-of-way, and certain issues 
related to the legal status of tribes--and (2) tribes' use of special 
gaming and small business contracting provisions. This statement is 
based on previously published work issued from December 2001 through 
March 2011. See the list of related GAO products at the end of this 
statement and other products cited for detailed descriptions of the 
scope and methodology used to conduct our work. We conducted our work 
in accordance with generally accepted government auditing standards or 
GAO's Quality Assurance Framework, as appropriate to each engagement. 

Background: 

Tribal lands vary dramatically in size, demographics, and location. 
They range in size from the Navajo Nation, which consists of about 
24,000 square miles, to some tribal land areas in California 
comprising less than 1 square mile. Over 176,000 American Indians live 
on the Navajo reservation, while other tribal lands have fewer than 50 
Indian residents. Some Indian reservations have a mixture of Indian 
and non-Indian residents. In addition, most tribal lands are rural or 
remote, although some are near metropolitan areas. 

The federal government has consistently recognized Indian tribes as 
distinct, independent political communities with inherent powers of a 
limited sovereignty which has never been extinguished. To help manage 
tribal affairs, tribes have formed governments or subsidiaries of 
tribal governments including schools, housing, health, and other types 
of corporations. The United States has a trust responsibility to 
recognized Indian tribes and maintains a government-to-government 
relationship with those tribes. As of October 2010, there were 565 
federally recognized tribes--340 in the continental United States and 
225 in Alaska.[Footnote 1] 

According to tribal officials and government agencies, conditions on 
and around tribal lands--including the lack of technology 
infrastructure such as telecommunications lines--generally make 
successful economic development more difficult. In addition, a 1999 
Economic Development Administration (EDA) study that assessed the 
state of infrastructure in American Indian communities found that 
these communities also had other disadvantages that made successful 
business development more difficult.[Footnote 2] This study found that 
the high cost and small markets associated with investment in Indian 
communities continued to deter widespread private sector involvement. 

To help address the needs of Indian tribes, various federal agencies 
provide assistance, including economic development assistance. The 
Bureau of Indian Affairs (BIA) in the Department of the Interior is 
charged with the responsibility of implementing federal Indian policy 
and administering the federal trust responsibility for about 2 million 
American Indians and Alaska Natives. BIA assists tribes in various 
ways, including providing for social services, developing and 
maintaining infrastructure, and providing education services. BIA also 
attempts to help tribes develop economically by, for example, 
providing resources to administer tribal revolving loan programs and 
guaranteed loan programs to improve access to capital in tribal 
communities. In addition to the support provided by BIA, other 
agencies with significant programs for tribes include the Department 
of Health and Human Services, which provides funding for the Head 
Start Program and the Indian Health Service; the Department of Housing 
and Urban Development, which provides support for community 
development and housing-related projects; and the Department of 
Agriculture, which provides support for services pertaining to food 
distribution, nutrition programs, and rural economic development. 

Some Unique Issues that May Affect Economic Activity in Indian Country: 

Our prior work has highlighted five broad categories of unique issues 
that have the potential to create uncertainty for tribes or, in some 
cases, private companies wishing to pursue economic activities on 
Indian reservations. Some of the issues that we have identified during 
our past work include (1) accruing land in trust for tribes and 
individual tribal members, (2) tribal environmental standards, (3) 
Indian tax provisions, (4) obtaining rights-of-way, and (5) certain 
legal issues that arise from the unique legal status of tribes. In 
addition to these five issues there may be others, such as access to 
financing, which may also hinder economic activity on Indian 
reservations. The five broad categories should only be considered as 
illustrative of some of the unique circumstances that exist in Indian 
country, which tribes or other business entities will need to take 
into account when they consider undertaking economic activities on 
tribal lands. 

Land in Trust Issues May Create Uncertainty: 

Having a land base is essential for many tribal economic development 
activities such as agriculture, grazing, timber, energy development, 
and gaming. Since the early days of colonization, Indian lands have 
diminished significantly, in large part because of federal policy. By 
1886, Indian lands had been reduced to about 140 million acres, 
largely on reservations west of the Mississippi River. Federal policy 
encouraging assimilation in the late 1800s and early 1900s further 
reduced Indian lands by two-thirds, to about 49 million acres by 1934. 
In 1934, however, the enactment of the Indian Reorganization Act 
changed the government's Indian policy to encourage tribal self- 
governance.[Footnote 3] Section 5 of the act provided the Secretary of 
the Interior with discretionary authority to take land in trust on 
behalf of Indian tribes or their members. Trust status means that the 
federal government holds title to the land in trust for tribes or 
individual Indians. Once land is taken in trust it is no longer 
subject to state and local property taxes and zoning ordinances. 
[Footnote 4] In 1980, Interior established a regulatory process 
intended to provide a uniform approach for taking land in trust. 
[Footnote 5] Under the regulations, tribes or individual Indians who 
purchase or own property on which they pay property taxes can submit a 
written request to the Secretary of the Interior to have the land 
taken in trust; if approved, the ownership status of the property 
would be converted from taxable status to nontaxable Indian trust 
status. Some state and local governments support the federal 
government's taking additional land in trust for tribes or individual 
Indians, while others strongly oppose it because of concerns about the 
impacts on their tax base and jurisdictional control. Since 1934, the 
total acreage held in trust by the federal government for the benefit 
of tribes and their members has increased from about 49 million to 
about 54 million acres.[Footnote 6] 

We reported in July 2006 that BIA generally followed its regulations 
for processing land in trust applications from tribes and individual 
Indians to take land into trust, but had no deadlines for making 
decisions on these applications.[Footnote 7] BIA generally responded 
to our recommendations to improve the processing of such applications, 
but this issue continues to create uncertainty in Indian country, in 
part, because of a February 24, 2009, Supreme Court decision and 
ongoing litigation. The Supreme Court held that the Indian 
Reorganization Act only authorizes the Secretary of the Interior to 
take land into trust for a tribe or its members if that tribe was 
under federal jurisdiction when the law was enacted in 1934.[Footnote 
8] The court did not define what constituted being under federal 
jurisdiction but did find that a particular tribe, which was not 
federally recognized until 1983, was not under federal jurisdiction in 
1934. It is not clear how many tribes or pending land in trust 
applications will be affected by this decision, but the decision 
raises a question about the Secretary's authority to take land in 
trust for the 50 tribes that have been newly recognized since 1960 and 
their members.[Footnote 9] The Secretary's decisions to take land in 
trust for two of these tribes--the Match-e-be-nash-she-wish Band of 
Potawatomi Indians of Michigan and the Cowlitz Indian tribe of 
Washington--have been challenged in court.[Footnote 10] 

Having or securing the land does not lead to economic development if 
that land sits idle. In the past we have reported on concerns about 
idle Indian lands and BIA's process for leasing Indian lands,[Footnote 
11] but we have not done any recent work on these issues. 

Tribal Environmental Standards May Create Uncertainty: 

The Clean Water Act, Safe Drinking Water Act, and Clean Air Act 
authorize the Environmental Protection Agency (EPA) to treat Indian 
tribes in the same manner as it does states,[Footnote 12] referred to 
as TAS (treated as states),[Footnote 13] for the purposes of 
implementing these laws on tribal lands. On the one hand, tribes want 
to be treated as states and assume program responsibilities to protect 
their environmental resources because they are sovereign governments 
and have specific knowledge of their environmental needs. Tribes also 
generally believe that TAS status and program authority are important 
steps in addressing the potential impacts of economic development 
affecting their land. On the other hand, in some cases, states are 
concerned that tribes with program authority may impose standards that 
are more stringent than the state's, resulting in a patchwork of 
standards within the state and potentially hindering the state's 
economic development plans. 

In October 2005, we reported that since 1986, when Congress amended 
the first of the three environmental laws to allow TAS status for 
tribes, a number of disagreements between tribes, states, and 
municipalities had arisen, over land boundaries, environmental 
standards, and other issues.[Footnote 14] The disagreements had been 
addressed in various ways, including litigation, collaborative 
efforts, and changes to federal laws. For example, in City of 
Albuquerque v. Browner,[Footnote 15] the city challenged EPA's 
approval of the nearby Pueblo of Isleta tribe's water quality 
standards, which are more stringent than those of New Mexico. EPA's 
approval was upheld. In other disagreements, some tribes and states 
have addressed the issues more collaboratively. For example, the 
Navajo Nation and the Arizona Department of Environmental Quality 
entered into a cooperative agreement that, among other things, 
recognizes the jurisdiction of the Navajo Nation within its 
reservation and establishes a plan to share the cost of pilot 
projects. Regarding the use of federal legislation to address 
disagreements, a federal statute enacted in August 2005, requires 
Indian tribes in Oklahoma to enter into a cooperative agreement with 
the state before EPA can approve a tribe's TAS request.[Footnote 16] 
At the time of our October 2005 report, the Pawnee Nation was the only 
Oklahoma tribe that had been awarded TAS status to set its own water 
quality standards, and we have not conducted any more recent work on 
this issue. 

Uncertainties Regarding the Use of Selected Indian Tax Provisions: 

The tax code has also been used to promote economic activity in Indian 
country. We have reported on tax provisions regarding (1) the 
uncertainties that tribes faced regarding the types of activities that 
they could finance with tax-exempt bonds and (2) the impact of 
accelerated depreciation provisions. 

In September 2006, we reported on Indian tribal governments' use of 
tax-exempt bonds under section 7871(c) of the Internal Revenue Code. 
[Footnote 17] Section 7871(c), which was originally enacted in 1983, 
generally limits the use of tax-exempt bonds by Indian tribal 
governments to the financing of certain activities that constitute 
"essential government functions."[Footnote 18] In 1987, section 
7871(e) was added to the code to limit the essential governmental 
functions standard further to provide that an essential governmental 
function does not include any function which is not customarily 
performed by state and local governments with general taxing powers. 
To date the Internal Revenue Service has not issued regulations 
defining essential government function.[Footnote 19] The lack of a 
definition has created uncertainty among tribes regarding the types of 
activities that they can finance using tax-exempt bonds. In addition, 
this custom-based essential governmental function standard has proven 
to be a difficult administrative standard and has led to audit 
disputes, based on difficulties in determining customs, the evolving 
nature of the functions customarily performed by state and local 
governments, and increasing involvement of state and local governments 
in quasi-commercial activities. In trying to determine what the 
customary practices were of state and local governments that tribes 
should be held accountable to, we reported that state and local 
governments had provided financial support for a variety of 
facilities, including rental housing, road transportation, parking 
facilities, park and recreation facilities, golf facilities, 
convention centers, hotels, and gaming support facilities. 

Section 1402 of the American Recovery and Reinvestment Act of 2009 
added a $2 billion bond authorization for a new temporary category of 
tax-exempt bonds with lower borrowing costs for Indian tribal 
governments known as "Tribal Economic Development Bonds" under section 
7871(f) of the Internal Revenue Code to promote economic development 
on Indian lands.[Footnote 20] In general, this new authority provides 
tribal governments with greater flexibility to use tax-exempt bonds to 
finance economic development projects than is allowable under the 
existing essential governmental function standard of section 7871(c). 
The Internal Revenue Service allocated the $2 billion of bond issuance 
authority provided by section 1402 to 134 tribal governments in two 
rounds. Furthermore, the act required the Secretary of the Treasury to 
study the effect of section 1402 and report to Congress on the results 
of the study, including the Secretary's recommendation regarding the 
provision. According to the Treasury Department, the House Ways and 
Means Committee and the Senate Finance Committee indicated that, in 
particular, Treasury should study whether to repeal on a permanent 
basis the existing more restrictive essential governmental function 
standard for tax-exempt governmental bond financing by Indian tribal 
governments under section 7871(c).[Footnote 21] The act required that 
the study be completed no later than 1 year after enactment, which 
would have made the deadline February 17, 2010. The Treasury 
Department published a notice in the Federal Register in July 2010 
seeking comments from tribal governments regarding the tribal economic 
development bond to assist the department in developing 
recommendations for the required study, but, to our knowledge, the 
department has not yet issued the report to Congress. There is 
continuing uncertainty in this area because it is unknown what the 
Treasury Department may recommend regarding changes to section 7871(c) 
and ultimately what changes, if any, Congress may adopt. 

A second tax measure intended to promote economic activity in Indian 
country is the Indian reservation depreciation provision, enacted in 
1993. The provision acts as an incentive for investment on Indian 
reservations because it permits taxpayers to accelerate their 
depreciation for certain property used by businesses on Indian 
reservations.[Footnote 22] The provision's special depreciation 
deduction schedule permits eligible taxpayers to take a larger and 
earlier deduction for depreciation from their business incomes than 
they otherwise would be allowed, thereby reducing any tax liability. 
Reducing tax liability earlier is an incentive for economic 
development because having a lower tax payment today is worth more to 
the taxpayer than having a lower tax payment in the future. However, 
in June 2008, we reported that there were insufficient data to 
identify users of the provision and assess whether the provision had 
increased economic development on Indian reservations.[Footnote 23] 

Obtaining Rights-of-Way Across Indian Land Can Involve Uncertainty: 

Securing rights-of-way across Indian lands is an important component 
of providing Indian lands with the critical infrastructure needed to 
support economic activity. We have reported on the uncertainties that 
telecommunication service providers and a nonprofit rural electric 
cooperative have faced in trying to negotiate rights-of-way involving 
Indian lands. 

In January 2006, we reported that according to several 
telecommunications service providers and tribal officials, obtaining a 
right-of-way through Indian lands is a time-consuming and expensive 
process that can impede service providers' deployment of 
telecommunications infrastructure.[Footnote 24] The right-of-way 
process on Indian lands is more complex than the right-of-way process 
for non-Indian lands because BIA must approve the application for a 
right-of-way across Indian lands. BIA grants or approves actions 
affecting title on Indian lands, so all service providers installing 
telecommunications infrastructure on Indian lands must work with BIA 
or its contractor (a realty service provider) to obtain a right-of-way 
through Indian lands.[Footnote 25] To fulfill the requirements of 
federal regulations for rights-of-way over Indian lands and obtain BIA 
approval, service providers are required to take multiple steps and 
coordinate with several entities during the application process. These 
steps must be taken to obtain a right-of-way over individual Indian 
allotments as well as tribal lands. Several of the steps involve the 
landowner, which could be an individual landowner, multiple 
landowners, or the tribe, depending on the status of the land. 
Specifically, the right-of-way process requires (1) written consent by 
the landowner to survey the land; (2) an appraisal of the land needed 
for the right-of-way; (3) negotiations with the landowner to discuss 
settlement terms; (4) written approval by the landowner for the right-
of-way; and (5) BIA approval of the right-of-way application.[Footnote 
26] One telecommunication service provider told us that an individual 
Indian allotment of land can have over 200 owners, and federal 
regulations require the service provider to gain approval from a 
majority of them. The service provider stated that the time and cost 
of this process is compounded by the fact that a telecommunications 
service line often crosses multiple allotments. In addition, if the 
service provider cannot obtain consent for the right-of-way from the 
majority of landowners, the provider is forced to install lines that 
go around the allotment, which is also expensive. 

Rights-of-way can also be necessary to deliver energy to consumers. In 
September 2004, we reported that the Copper Valley Electric 
Association, a nonprofit rural electric cooperative, had been unable 
to reach agreements with several individual Alaska Natives for rights-
of-way across their land.[Footnote 27] In 1906, the Alaska Native 
Allotment Act authorized the Secretary of the Interior to allot 
individual Alaska Natives a homestead of up to 160 acres.[Footnote 28] 
We found 14 cases where conflict exists regarding Copper Valley's 
rights-of-way within Native allotments. Resolution to a number of 
these conflicts had been intermittently pursued since the mid-1990s, 
but at the time of our report, only a few cases had been resolved 
using existing remedies. Copper Valley had three remedies to resolve 
these conflicts: (1) negotiating rights-of-way with Native allottees 
in conjunction with BIA; (2) relocating its electric lines outside of 
the allotment; or (3) exercising the power of eminent domain, also 
known as condemnation, to acquire the land.[Footnote 29] We reported 
that Copper Valley had ceased trying to resolve these conflicts 
because it maintains that the existing remedies are too costly, 
impractical, and/or potentially damaging to relationships with the 
community. More importantly, Copper Valley officials told us that on 
principle they should not have to bear the cost of resolving conflicts 
that they believe the federal government had caused. 

Section 1813 of the Energy Policy Act of 2005 required the Secretaries 
of Energy and of the Interior to conduct a study of issues regarding 
energy rights-of-ways on tribal land and issue a report to Congress on 
the findings, including recommending appropriate standards and 
procedures for determining fair and appropriate compensation to Indian 
tribes for granting, expanding and renewing rights-of-way.[Footnote 
30] Issued in May 2007, the study focused on rights-of-way for 
electric transmission lines and natural gas and oil pipelines 
associated with interstate transit and local distribution. The study 
recommended that valuation of rights-of-way continue to be based on 
terms negotiated between the parties and that if negotiations failed 
to produce an agreement that has a significant regional or national 
effect on the supply, price, or reliability of energy resources, 
Congress should consider resolving such a situation through specific 
legislation rather than making broader changes that would affect 
tribal sovereignty or self-determination generally. 

Certain Issues Related to the Legal Status of Tribes May Complicate 
the Resolution of Disputes: 

The unique legal status of tribes has resulted in a complex set of 
rules that may affect economic development efforts. As we reported 
earlier this year, as a general principle, the federal government 
recognizes Indian tribes as "distinct, independent political 
communities" with inherent powers of self-government.[Footnote 31] 
Therefore, Indian tribes have sovereign immunity as well as plenary 
and exclusive power over their members and territory subject only to 
the limitations imposed by federal law. However, sovereign immunity 
may influence a private company's decision to contract with an Indian 
tribe and the limitations imposed by federal law on Indian tribes' 
civil jurisdiction over non-Indians on Indian reservations may create 
uncertainties regarding where lawsuits arising out of those contracts 
can be brought. 

Like the federal and state governments, Indian tribes are immune from 
lawsuits unless they have waived their sovereign immunity in a clear 
and unequivocal manner or a federal treaty or law has expressly 
abrogated or limited tribal sovereign immunity. For example, the 
Indian Tribal Economic Development and Contracts Encouragement Act of 
2000 requires the Secretary of the Interior to approve any agreement 
or contract with an Indian tribe that encumbers Indian lands for 7 or 
more years; however, it prohibits the Secretary from approving the 
agreement or contract unless it provides remedies for breaching the 
agreement or contract, references a tribal law or court ruling 
disclosing the tribe's right to assert sovereign immunity, or includes 
an express waiver of sovereign immunity. If the tribe does not waive 
its sovereign immunity in the agreement or contract, private companies 
might be hesitant to undertake the work because they will not be able 
to sue the tribe if any disputes arise. In addition to waiving 
sovereign immunity in agreements or contracts on a case-by-case basis, 
some tribes have formed separate entities to conduct business that are 
not immune from lawsuits. 

The Supreme Court has ruled that, as a general proposition, the 
inherent sovereign powers of an Indian tribe do not extend to the 
activities of non-tribal members.[Footnote 32] However, the Court has 
also recognized two exceptions to this general proposition: (1) tribes 
may regulate the activities of nonmembers who enter into consensual 
relationships with the tribe or its members through commercial 
dealing, contracts, leases, or other arrangements and (2) tribes may 
exercise civil authority over the conduct of non-Indians on fee lands 
within the reservation when that conduct threatens or has some direct 
effect on the political integrity, economic security, or the health or 
welfare of the tribe. In 2008, the Supreme Court ruled that a tribal 
court did not have jurisdiction to adjudicate a discrimination claim 
against a non-Indian bank brought by a company owned by tribal members 
because neither of the exceptions applied.[Footnote 33] The court's 
opinion focuses on the tribe's authority to regulate the bank's sale 
of fee land it owned within the reservation rather than addressing 
whether the tribal court had authority to hear the discriminatory 
lending claim under the consensual relationship exception. However, 
some private companies believe that this decision may not eliminate 
all of the uncertainty as to the nature and extent of tribal court 
jurisdiction that makes off-reservation businesses reluctant to trade 
on Indian reservations or with tribal members who live on 
reservations. For example, the brief filed by a railroad association 
asked the court to adopt a brightline rule that tribal courts may not 
exercise jurisdiction over claims against nonmembers absent clear and 
unequivocal consent to tribal court jurisdiction. The association 
argued that such a rule would ensure that litigation against nontribal 
members will be addressed by a forum that the nonmember has agreed 
affords acceptable law, procedure, and fundamental safeguards of 
process and fairness. 

Special Provisions for Gaming and Small Business Contracting: 

In contrast to the unique issues that can cause uncertainty or pose 
challenges to economic activity in Indian country, tribes can take 
advantage of special provisions for gaming and small business 
contracting. Indian gaming, a relatively new phenomenon, started in 
the late 1970s when a number of Indian tribes began to establish bingo 
operations as a supplemental means of funding tribal operations. In 
1987, the U. S. Supreme Court ruled that state regulation of tribal 
gaming would impermissibly infringe on tribal governments, thereby 
barring state regulation of tribal gaming in states which did not 
prohibit all forms of gaming.[Footnote 34] In response, the Indian 
Gaming Regulatory Act of 1988 was enacted, which established a 
regulatory framework to govern Indian gaming operations.[Footnote 35] 
In section 2(4) of the act, Congress found that a principle goal of 
federal Indian policy is to promote tribal economic development, 
tribal self-sufficiency, and strong tribal government. To that end, 
the act generally requires that the net revenues from tribal gaming 
operations be used to (1) fund tribal government operations or 
programs, (2) provide for the general welfare of the Indian tribe and 
its members, (3) promote tribal economic development, (4) donate to 
charitable organizations, or (5) help fund operations of local 
government agencies. A tribe may distribute its net revenues directly 
to tribal members, provided that the tribe has a revenue allocation 
plan approved by BIA and meets certain other conditions. 

According to the final report of the National Gambling Impact Study 
Commission,[Footnote 36] gambling revenues have proven to be a 
critical source of funding for many tribal governments, providing much 
needed improvements in the health, education, and welfare of Indians 
living on reservations across the United States. The National Indian 
Gaming Commission reports that for 2009: 

* 233 tribes operating 419 gaming operations generated $26.5 billion 
in revenue (233 tribes represents about 40 percent of the 565 
federally recognized tribes), 

* the top 21 operations (or about 5 percent of all the operations) 
generated 38.7 percent of all the revenues, and: 

* the top 71 operations (or about 17 percent of all the operations) 
generated 69.5 percent of all the revenues. 

In addition, in 1986, a law was enacted that allowed Alaska Native 
corporation (ANC)-owned businesses to participate in the Small 
Business Administration's (SBA) 8(a) program--one of the federal 
government's primary means for developing small businesses owned by 
socially and economically disadvantaged individuals. This program 
allows the government to award contracts to participating small 
businesses without competition below certain dollar thresholds. Since 
1986, special procurement advantages have been extended to ANC firms 
beyond those afforded to other 8(a) businesses, such as the ability to 
win sole-source contracts for any dollar amount. In April 2006, we 
reported on the use of special procurement advantages by ANCs, and 
found that 8(a) obligations to firms owned by ANCs increased from $265 
million in fiscal year 2000 to $1.1 billion in 2004.[Footnote 37] In 
fiscal year 2004, obligations to ANC firms represented 13 percent of 
total 8(a) dollars. Sole-source awards represented about 77 percent of 
8(a) ANC obligations for the six procuring agencies that accounted for 
the vast majority of total ANC obligations over the 5-year period. 

ANCs use the 8(a) program to generate revenue with the goal of 
providing benefits to their shareholders, but the ANCs we reviewed did 
not track the benefits provided to their shareholders specifically 
generated from 8(a) activity. Thus, an explicit link between the 
revenues generated from the 8(a) program and benefits provided to 
shareholders is not documented. Benefits vary among corporations, but 
include dividend payments, scholarships, internships, burial 
assistance, land gifting or leasing, shareholder hire, cultural 
programs, and support of the subsistence lifestyle. The special 
procurement advantages for ANCs also generally apply to tribes and 
Native Hawaiian organizations (NHO). To obtain more information on the 
benefits these entities receive from participation in the 8(a) 
program, SBA recently promulgated regulations that require each 8(a) 
program participant owned by an ANC, tribe, or NHO to submit 
information showing how the ANC, tribe, or NHO has provided benefits 
to tribal or Native communities or tribal or Native members due to its 
participation in the 8(a) program.[Footnote 38] The data submitted 
should include information relating to funding cultural programs, 
employment assistance, jobs, scholarships, internships, subsistence 
activities, and other services provided by the ANC, tribe, or NHO to 
the affected community. We have ongoing work looking at the use of 
these special procurement advantages by ANCs, tribes, and NHOs. 

Chairman Lankford, Ranking Member Connolly, and Members of the 
Subcommittee, this concludes my prepared statement. I would be pleased 
to answer any questions that you may have at this time. 

GAO Contacts and Acknowledgments: 

For further information about this testimony, please contact Anu K. 
Mittal at (202) 512-3841 or mittala@gao.gov. Contact points for our 
Offices of Congressional Relations and Public Affairs may be found on 
the last page of this statement. Jeffery D. Malcolm, Assistant 
Director; Jeanette Soares, and Joe Thompson also made key 
contributions to this statement. 

[End of section] 

Related GAO Products: 

Department of the Interior: Major Management Challenges. [hyperlink, 
http://www.gao.gov/products/GAO-11-424T]. Washington, D.C.: March 1, 
2011. 

Indian Country Criminal Justice: Departments of the Interior and 
Justice Should Strengthen Coordination to Support Tribal Courts. 
[hyperlink, http://www.gao.gov/products/GAO-11-252]. Washington, D.C.: 
February 14, 2011. 

Tax Expenditures: Available Data Are Insufficient to Determine the Use 
and Impact of Indian Reservation Depreciation. [hyperlink, 
http://www.gao.gov/products/GAO-08-731]. Washington, D.C.: June 26, 
2008. 

Federal Tax Policy: Information on Selected Capital Facilities Related 
to the Essential Governmental Function Test. [hyperlink, 
http://www.gao.gov/products/GAO-06-1082]. Washington, D.C.: September 
13, 2006. 

Indian Issues: BIA's Efforts to Impose Time Frames and Collect Better 
Data Should Improve the Processing of Land in Trust Applications. 
[hyperlink, http://www.gao.gov/products/GAO-06-781]. Washington, D.C.: 
July 28, 2006. 

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Special 8(a) Provisions Calls for Tailored Oversight. [hyperlink, 
http://www.gao.gov/products/GAO-06-399]. Washington, D.C.: April 27, 
2006. 

Indian Irrigation Projects: Numerous Issues Need to Be Addressed to 
Improve Project Management and Financial Sustainability. [hyperlink, 
http://www.gao.gov/products/GAO-06-314]. Washington, D.C.: February 
24, 2006. 

Telecommunications: Challenges to Assessing and Improving 
Telecommunications For Native Americans on Tribal Lands. [hyperlink, 
http://www.gao.gov/products/GAO-06-189]. Washington, D.C.: January 11, 
2006. 

Indian Tribes: EPA Should Reduce the Review Time for Tribal Requests 
to Manage Environmental Programs. [hyperlink, 
http://www.gao.gov/products/GAO-06-95]. Washington, D.C.: October 31, 
2005. 

Indian Economic Development: Relationship to EDA Grants and Self- 
determination Contracting Is Mixed. [hyperlink, 
http://www.gao.gov/products/GAO-04-847]. Washington, D.C.: September 
8, 2004. 

Alaska Native Allotments: Conflicts with Utility Rights-of-way Have 
Not Been Resolved through Existing Remedies. [hyperlink, 
http://www.gao.gov/products/GAO-04-923]. Washington, D.C.: September 
7, 2004. 

Welfare Reform: Tribal TANF Allows Flexibility to Tailor Programs, but 
Conditions on Reservations Make it Difficult to Move Recipients into 
Jobs. [hyperlink, http://www.gao.gov/products/GAO-02-768]. Washington, 
D.C.: July 5, 2002. 

Economic Development: Federal Assistance Programs for American Indians 
and Alaska Natives. [hyperlink, 
http://www.gao.gov/products/GAO-02-193]. Washington, D.C.: December 
21, 2001. 

[End of section] 

Footnotes: 

[1] 75 Fed. Reg. 60810 (Oct. 1, 2010); 75 Fed. Reg. 66124 (Oct. 27, 
2010). 

[2] Linda A. Riley, B. Nassersharif, and J. Mullen, Assessment of 
Technology Infrastructure in Native Communities, a study based on a 
survey of 48 Native communities, New Mexico State University, (Las 
Cruces, N.Mex.: 1999), EDA project no. 99-07-13799. 

[3] Act of June 18, 1934 (Indian Reorganization Act), ch. 576, 48 
Stat. 984-988 (1934), codified as amended at 25 U.S.C. §§ 461-479. 

[4] Department of the Interior regulations provide that zoning 
ordinances do not apply to land in trust except as permitted by the 
Secretary. 25 C.F.R. § 1.4. 

[5] 25 C.F.R. pt. 151. 

[6] The 5-million acre difference between these two figures represents 
the net change of Indian land in trust from 1934. In addition to 
Indian applicants seeking to have land converted to trust status, 
Indian applicants can also seek to have land already in trust status 
converted to fee status (which is subject to property tax) and tribes 
and individual Indians can also lose trust lands through a variety of 
means, including probate and foreclosure. These two processes result 
in land "coming into trust" (referred to as acquisitions) and land 
"going out of trust" (referred to as disposals). The regulations 
governing taking land out of trust are in 25 C.F.R. pt. 152. For 
example, for the calendar year ending December 31, 1997, BIA reported 
acquiring about 360,000 acres and disposing of about 260,000 acres, 
for a net increase in tribal and individual Indian trust acreage of 
about 100,000 acres. 

[7] GAO, Indian Issues: BIA's Efforts to Impose Time Frames and 
Collect Better Data Should Improve the Processing of Land in Trust 
Applications, [hyperlink, http://www.gao.gov/products/GAO-06-781] 
(Washington, D.C.: July 28, 2006). 

[8] Carcieri v. Salazar, 555 U.S. 379 (2009). 

[9] For additional information on BIA's administrative process for 
granting federal recognition and a list of newly recognized tribes see 
GAO, Indian Issues: Improvements Needed in Tribal Recognition Process, 
[hyperlink, http://www.gao.gov/products/GAO-02-49] (Washington, D.C.: 
Nov. 2, 2001). Also see enclosure II of GAO, Indian Issues: BLM's 
Program for Issuing Individual Allotments on Public Lands Is No Longer 
Viable, [hyperlink, http://www.gao.gov/products/GAO-07-23R] 
(Washington, D.C.: Oct. 20, 2006) and appendix II of GAO, Native 
American Graves Protection and Repatriation Act: After Almost 20 
Years, Key Federal Agencies Still Have Not Fully Complied with the 
Act, [hyperlink, http://www.gao.gov/products/GAO-10-768] (Washington, 
D.C.: July 28, 2010) for updated lists of new and restored tribes. The 
Shinnecock Indian Nation of New York, the newest federally recognized 
tribe, was recognized as of October 1, 2010. 75 Fed. Reg. 66124 (Oct. 
27, 2010). 

[10] Patchak v. Salazar, 646 F. Supp. 2d 72 (D.D.C. 2009), rev'd, 632 
F.3d 702 (D.C. Cir. 2011) (remanding to district court for further 
proceedings); Clark County v. Salazar, No. 11-00278 (D.C. Cir. filed 
Jan. 31, 2011). 

[11] GAO, Indian Programs: BIA's Management of the Wapato Irrigation 
Project, [hyperlink, http://www.gao.gov/products/GAO/RCED-97-124] 
(Washington, D.C.: May 28, 1997); GAO, Indian Programs: BIA Should 
Streamline Its Processes for Estimating Land Rental Values, 
[hyperlink, http://www.gao.gov/products/GAO/RCED-99-165] (Washington, 
D.C.: June 30, 1999). 

[12] Under these laws, EPA may authorize states to establish their own 
standards and carry out a state program in lieu of the federal 
program. State standards must meet or exceed federal requirements. 

[13] The acts generally use the term "treat as states." EPA and most 
Indian tribes prefer to use the term "treatment in the same manner as 
a state." 

[14] GAO, Indian Tribes: EPA Should Reduce the Review Time for Tribal 
Requests to Manage Environmental Programs, [hyperlink, 
http://www.gao.gov/products/GAO-06-95] (Washington, D.C.: Oct. 31, 
2005). 

[15] 97 F.3d 415 (10th Cir. 1996), cert. denied, 522 U.S. 965 (1997). 

[16] Pub. L. No. 109-59, § 10211, 119 Stat. 1144, 1937 (2005). 

[17] GAO, Federal Tax Policy: Information on Selected Capital 
Facilities Related to the Essential Governmental Function Test, 
[hyperlink, http://www.gao.gov/products/GAO-06-1082] (Washington, 
D.C.: Sept. 13, 2006). 

[18] Indian Tribal Government Tax Status Act, Pub. L. No. 97-473, § 
202, 96 Stat. 2605 (1983), codified as amended at 26 U.S.C. § 7871(c). 

[19] On August 9, 2006, the Internal Revenue Service published an 
advanced notice of proposed rulemaking regarding the definition of 
essential government function and solicited comments on a definition. 
71 Fed. Reg. 45474 (Aug. 9, 2006). 

[20] Pub. L. No. 111-5, § 1402, 123 Stat. 115, 351 (2009). 

[21] 75 Fed. Reg. 39730 (July 12, 2010). 

[22] 26 U.S.C. § 168(j). Indian reservation is defined as (1) Indian 
reservations; (2) public domain Indian allotments; (3) former Indian 
reservations in Oklahoma which are within the jurisdictional area of 
an Oklahoma Indian tribe as determined by the Secretary of the 
Interior and are recognized by the Secretary as eligible for trust 
land status under applicable regulations in effect on the day of the 
provision's enactment; (4) land held by incorporated Native groups, 
regional corporations, and village corporations; (5) all land within 
the limits of any Indian reservation under the jurisdiction of the 
United States Government; (6) all dependent Indian communities; (7) 
all Indian allotments, the Indian titles to which have not been 
extinguished; and (8) any lands not within the limits of an Indian 
reservation, part of a dependent Indian community, nor an allotment 
which is either held by the United States in trust or held by any 
Indian tribe or individual subject to a restriction by the United 
States against alienation. 

[23] GAO, Tax Expenditures: Available Data Are Insufficient to 
Determine the Use and Impact of Indian Reservation Depreciation, 
[hyperlink, http://www.gao.gov/products/GAO-08-731] (Washington, D.C.: 
June 26, 2008). 

[24] GAO, Telecommunications: Challenges to Assessing and Improving 
Telecommunications For Native Americans on Tribal Lands, [hyperlink, 
http://www.gao.gov/products/GAO-06-189] (Washington, D.C.: Jan. 11, 
2006). 

[25] The Indian Self-Determination and Education Assistance Act, as 
amended, directs Interior, at the request of a tribe, to contract with 
Indian tribes or tribal organizations to carry out the services and 
programs the federal government provides to Indians. Therefore, as 
authorized by the act, regional nonprofit corporations or tribal 
entities can assume management of the realty function from BIA to 
perform realty services for Indian lands. 25 U.S.C. § 450f. 

[26] 25 C.F.R. § 169.3. 

[27] GAO, Alaska Native Allotments: Conflicts with Utility Rights-of- 
way Have Not Been Resolved through Existing Remedies, [hyperlink, 
http://www.gao.gov/products/GAO-04-923] (Washington, D.C.: Sept. 7, 
2004). 

[28] Act of May 17, 1906 (Alaska Allotment Act), ch. 2469, 34 Stat. 
197 (1906), repealed by Alaska Native Claims Settlement Act, Pub. L. 
No. 92-203, § 18(a), 85 Stat. 688, 710 (1971). 

[29] Lands allotted in severalty to Indians may be condemned for any 
public purpose under the laws of the State or Territory where they are 
located in the same manner as land owned in fee may be condemned, and 
the money awarded as damages shall be paid to the allottee (25 U.S.C. 
§ 357). Under Alaska state law a public utility may exercise the power 
of eminent domain for public utility uses (Alaska Stat. § 42.05.631). 

[30] Pub. L. No. 109-58, § 1813, 119 Stat. 594, 1127 (2005). Tribal 
land is defined as any land or interests in land owned by any Indian 
tribe, title to which is held in trust by the United States, or is 
subject to a restriction against alienation under laws of the United 
States. 

[31] GAO, Indian Country Criminal Justice: Departments of the Interior 
and Justice Should Strengthen Coordination to Support Tribal Courts, 
[hyperlink, http://www.gao.gov/products/GAO-11-252] (Washington, D.C.: 
Feb. 14, 2011). 

[32] Montana v. United States, 450 U.S. 544 (1981). 

[33] Plains Commerce Bank v. Long Family Land and Cattle Company, 554 
U.S. 316 (2008). The non-Indian bank made operating loans to the 
company owned by tribal members and accepted the deed to the company's 
fee land inside the reservation but leased the land back to the 
company, with an option to purchase it at the end of the lease. The 
company did not exercise its option and the bank subsequently sold the 
property to non-Indians. The company then sued the bank in tribal 
court on a variety of claims, including claiming that the bank 
discriminated against the company because it had sold the company's 
land to non-tribal members on terms more favorable than those offered 
to the company. The tribal court awarded the company an option to 
purchase some of the land at issue, which effectively nullified the 
bank's previous sale of that land to non-Indians. 

[34] California v. Cabazon Band of Mission Indians, 480 U.S. 202 
(1987). 

[35] Pub. L. No. 100-497, 102 Stat. 2467 (1988), codified at 25 U.S.C. 
§§ 2701-2721. 

[36] The National Gambling Impact Study Commission, Final Report 
(Washington, D.C.: June 18, 1999). The National Gambling Impact Study 
Commission Act created the commission and required it to produce this 
report. Pub. L. No. 104-169, 110 Stat. 1482 (1996). 

[37] GAO, Contract Management: Increased Use of Alaska Native 
Corporations' Special 8(a) Provisions Calls for Tailored Oversight, 
[hyperlink, http://www.gao.gov/products/GAO-06-399] (Washington, D.C.: 
Apr. 27, 2006). 

[38] 76 Fed. Reg. 8222, 8264 (Feb. 11, 2011). Although the regulation, 
13 C.F.R. § 124.604, requires reporting by each participant in the 
8(a) program, the preamble to the regulation states that only parent 
corporations and not the individual subsidiary 8(a) participants will 
be required to submit this information. Generally, the new regulation 
became effective on March 14, 2011. However, SBA decided to delay the 
benefits reporting requirement to further study how the requirement 
could best be implemented without imposing an undue burden on ANCs, 
tribes, and NHOs. SBA has delayed the implementation for at least 6 
months and noted that further delay may be necessary if the 
refinements to the requirement take longer than 6 months. 76 Fed. Reg. 
8222, 8236 (Feb. 11, 2011). 

[End of section] 

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