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03. Salish Kootenai Tribal Attorney - Marion Yoder - Water QualityMAX BAUCUS MONTANA 'United ptates mate WASHINGTON, DC 20510-2602 June 3, 1994 The Honorable Douglas Rauthe Mayor City of Kalispell P.O. Box 1997 Kalispell, Montana 59903-1997 Dear Doug: JUIN I U i 4 WASHINGTON. DC 1202)224-2651 MONTANA TOLL FREE NUMBER 1-800-332-6106 Thank you for getting in touch with me about the Confederated Salish and Kootenai Tribes' application to be treated as a state.for purposes of implementing the Clean Water Act on the Flathead Reservation. I understand and have made note of your concerns. National environmental laws allow a tribe to implement laws, like the Clean Water Act, if the tribe can show that it has pre- existing jurisdiction to do so under the applicable principles of federal Indian law. I believe that it was not the intent of Congress to expand tribal jurisdiction over nonmembers in either the Clean Water Act or any other federal environmental law. I have contacted national and Montana EPA officials and understand that they agree and are reviewing the Tribes' application to decide whether the Tribes have the necessary pre- existing jurisdiction. As you know, this can be a complex issue, particularly on reservations like the Flathead, where the Indian reservation has been opened up to substantial non -tribal settlement. As the process moves forward, I will continue to urge EPA, the Tribes, the Joint Board of Control, the State, and others to work together. We need to develop an approach that protects the environment in a way that is sensitive to the interests of all reservation residents. Again, Doug, thank you for getting in touch with me about this important issue and you can be sure that I will keep your views firmly in mind. With best personal regards, I am MSB/dwf BILLINGS BOZEMAN (406) 657-6790 (406) 586-6104 Sincerely, BUTTE GREAT FALLS HELENA KALISPELL (406) 782-8700 (406) 761-1574 (406) 449-5480 1406) 756-1150 MISSOULA (406) 329-3123 o UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION VIII, MONTANA OFFICE FEDERAL BUILDING, 301 S. PARK, DRAWER 10096 HELENA, MONTANA 69626-0096 Ref: 8MO June 1, 1994 Douglas D. Rauthe Mayor The City of Kalispell P.O. Box 1997 Kalispell, Montana 59903-1997 Re: Confederated Salish and Kootenai Tribes: Treatment as a State Applications Dear Mayor Rauthe: Thank you for yor letter of May 2, 1994 expressing your opposition to to the application of the Confederated Salish and Kootenai Tribes' (CSKT) application for treatment as a State under the Clean Water Act. The 1987 amendments to the Clean Water Act (P.L. 100-4, February 4, 1987, hereinafter the "CWA") added Section 518 which would allow Indian tribes to become eligible for the administration of a number of programs under the Clean Water Act. These include the Water Quality Standards Program (under Section 303)'and the permitting program for the dredging or filling of waterbodies within the United States (under Section 404). If approved, the Tribes will have the opportunity to develop water quality standards; and the opportunity to submit to EPA a program for regulating dredging and filling activities on the Flathead Indian Reservation. Federal Rules and Regulations provide the opportunity for State Government to review a tribal application submitted under the provisions of CWA Section 518. A State, such as the State of Montana, may also file an objection if it perceives a conflciting jurisdictional issue. The regulations also allow local governments and the public to review and comment on a tribal application. We provide these comments to the affected State, in this case the State of Montana, which then reviews and integrates review comments into its response to EPA. A comment period was set in September 1993 for local governments to review and comment on the CSKT proposals. At that time substantial comments were received by this office and forwarded to the Attorney Generals Office for the State of Montana. While this process may be closed, we will forward your letter to the appropriate individuals in State Government. We note that the State of Montana already has filed an objection on the two applcations of the Confederated Salish and Kootenai Printed on Recycled Paper Tribes. The State's position will be taken into account in our review of the CSKT Applications. I trust that this -response is satisfactory for your purposes. If there are any questions pertaining to this matter, please contact Lee Roberts of my staff at (406) 449-5486 extension 236. Thank you. Sincerely, (�Z41 John F. Wardell Director Montana Office cc: Bill Yellowtail, 8A Nola Cooke, 8OEA Max Dodson, 8WM