RE: Outreach to Tribes

[Jeff Tomhave <jtomhave@taswer.org>]

For today's agenda focus on how EPA should identify interested and potentially affected parties early in its decision-making process, the dialogue states that the Agency must communicate with all affected sectors of the public and that in turn, interested members of the public need to be able to notify EPA of their interests in particular issues. Easier said than done.

When it comes to Indian Tribal government's, the Agency's, indeed all federal agencies, typical response is to send by electronic mail (with a plethora of attachments) said announcement rather late in the decision-making process. The assumption by the federal agency is it has adequately notified this sector of the public. There is no comprehension on the feds part (with their T1 lines) that not only do most Tribe's lack state of the art hardware, most also lack high speed access. (More digital divide here.) Not to mention the Tribes that STILL lack electricity, phone service, running water, sewage. etc. - more than you'd suspect.

So even if a Tribe gets an announcement in time, with excessive download times and computer crashes resulting, there is no reason to believe that the Tribal staff will have either the time or the expertise to provide an informed response to said request. Usually, even if a Tribe does get a request in a timely manner, by the time it gets routed to the proper recipient, the deadline had passed. Why is this: because the federal agencies seem to all rely on some outdated database. Before I typed in this response I looked at both EPA's (at the American Indian Environmental Office) and BIA's tribal contacts lists, just in the cursory skim at both lists I found a number of outdated names, address, etc. This is the same reason why postal mail is an inadequate measure to assure all interested parties are informed of some pending federal action.  

It is also not enough to ask the regional Tribal coordinator's to invite Tribes to participate. That approach is only as good as the regional Tribal coordinator. Let's just say that some are better than others. Some have cultivated genuine relationships with the Tribes in their regions. Others do nothing more than remain in their offices.  

So how can the Agency enhance its identification efforts when it comes to Tribal communities. Don't rely on the inaccurate and outdated federal contact lists. The administrative turnover in Tribal governments is such that no federal database (usually outsourced to some private sector contractor with no experience with Indian Country, or maintained by summer interns) will ever reflect a real time component. Continue to use the existing affiliated universe of organizations out there, like the Alaska Native Science Commission. But realize that there is not now and will never be any universal Tribal organization. Develop relationships with them all. Not all Tribes will be represented in any given one. For instance, the Alaskan Federation of Natives represents the Alaskan Native Corporations, the InterTribal Council of Alaska represents the Native Village governments. They do not share the same concerns. The National Congress of American Indian lost a lot on member Tribes recently because many of the larger land based Treaty Tribes felt their interests would be better served through another organization. 

Since Tribes almost always begin their relations with the EPA through the grant programs, have the project officers (especially GAP PO's) disseminate the requests. They have the relationships with the Tribes, the regional Tribal coordinator manages the entire program, not the same function. As Tribes continue to develop their environmental component they will continue develop their ability to respond to policy making and their ability to lead policy making.