03-28-89
                IMPLEMENTATION OF ENVIRONMENTAL
               STANDARDS AND REGULATIONS ON THE
                 ST. REGIS MOHAWK RESERVATION

                   MEMORANDUM OF AGREEMENT

I.   PARTIES

     This MEMORANDUM OF AGREEMENT ("Agreement"), dated march 28, 1989,
     between the St. Regis Mohawk Tribe, of Hogansburg, New York 
     ("Tribe"), by and through the Tribal Council, and the United 
     States Environmental Protection Agency ("EPA"), by and through the
     Regional Administrator of EPA Region II, concerns implementation 
     of the environmental standards and regulations of the Tribe 
     within the exterior boundaries of the St.  Regis Mohawk 
     Reservation ("Reservation") in New York State.

II.  PURPOSE AND INTENT

     A.  The Tribe and the EPA agree to work together toward the
         development of a comprehensive set of environmental regulations
         and measures to be implemented on the Reservation.  It is
         understood by both parties that this Agreement in no way waives
         or affects the existing authority of either of the parties
         involved, but rather promotes a spirit of cooperation between
         the parties.  Through this cooperative effort, the parties 
         desire to further Tribal self-government, and the special
         government-to-government relationship between the Tribal
         government and the federal government.  The development of this
         program is expected to result in a multi-media approach toward
         protecting the environmental quality of the Reservation
         environment.

     B.  In furtherance of these mutual goals and policies, this 
Agreement:

         *   establishes a framework for intergovernmental cooperation 
             and coordination between the Tribe and EPA;

         *   seeks to minimize duplicative efforts and, thereby, 
             conserve Tribal and EPA monetary and program resources; and

         *   facilitates the development of a separate agreement(s) 
             between the Tribe, EPA, New York State, and other 
             interested public and private entities regarding 
             protection of the Reservation.

         1.  Tribal Health and Welfare:  The parties desire to protect
             the health and welfare of the Reservation population and 
             the property, wildlife, and natural resources of the 
             Reservation.  Pollution from sources located both on and 
             off the Reservation may:  pose a threat to public health 
             and/or welfare; damage natural resources; pose a threat to
             livestock; impair beneficial uses of surface and ground
             waters; and adversely affect air quality.

         2.  Tribal Economic Development:  The parties desire to 
             protect the Tribe's interest in protecting the 
             environmental quality of the Reservation so that the 
             opportunity for attracting job producing businesses to the
             Reservation will be preserved.  In addition, the Tribe 
             desires to protect its reserved ownership right in the 
             quality of living and non-living resources which comprise
             the Reservation environment.

III. OBJECTIVES

     The following objectives have been established for the first two 
     years of work under this Agreement.  Unless modified by the 
     parties, the following objectives shall remain in force and effect
     beyond the initial two year term of this Agreement.

     A.  To develop and implement programs, as appropriate, to address
         Tribal environmental concerns in the following areas:  
         hazardous waste sites, solid waste, air quality, ground and 
         surface water quality management, underground storage tanks,
         pesticides, public water supplies, and sewage treatment.

     B.  To develop Tribal capability for participation in remediation
         efforts at sites under investigation pursuant to the 
         Comprehensive Environmental Response, Compensation, and 
         Liability Act/Superfund Amendments and Reauthorization Act
         (CERCLA/SARA), including the development of appropriate 
         remedial cleanup standards.  The parties are currently 
         negotiating one or more separate agreements under CERCLA/SARA 
         with regard to the Tribe's specific role under that statute.

     C.  To provide assistance in the development of appropriate Tribal
         regulatory programs under federal law, such as, but not 
         limited to: water quality management, public water supply, 
         and air quality management.

     D.  To assist the Tribe in further development of its support staff
         and governmental infrastructure to provide for enforcement of
         Tribal environmental ordinances and the resolution of such
         conflicts as may arise in the enforcement of such Tribal laws.

     E.  To take initial steps in carrying out actual program
         implementation activities under the programs developed and 
         adopted by the Tribe.

     F.  To develop future programming and funding plans.

IV. TERMS OF AGREEMENT

     A.  General Obligations

         In order to implement the purpose, intent, and obligations of 
         this Agreement set forth in Sections II and III above, the 
         parties agree to the following terms:

         1.  Coverage:  This Agreement covers programs and
             technical/financial assistance authorized by the Clean 
             Water Act (CWA), the Clean Air Act (CAA), the Resource
             Conservation and Recovery Act (RCRA), the Safe Drinking 
             Water Act (SDWA), the Federal Insecticide, Fungicide, and
             Rodenticide Act (FIFRA), the Toxic Substances Control Act
             (TSCA), and CERCLA/SARA.

         2.  Cooperation:  Each party shall cooperate to the greatest 
             extent possible with the other party in fulfilling the 
             purposes of this Agreement.  At the written request of 
             the Tribe and to the extent permitted by available 
             resources and applicable law, EPA will provide the Tribe 
             with technical and financial support to carry out the 
             activities identified in this Agreement.

         3.  Timely Notification:  Each party shall act in a timely 
             manner to provide the other with environmental 
             documentation for proposed actions (e.g., analyses, 
             assessments, or impact statements) of interest to the 
             other party.  When the proposed action of a party may 
             directly affect the programs or property of the other 
             party, the proponent of such action shall solicit input 
             from the affected party.  Furthermore, EPA shall provide 
             the Tribe with timely notice of proposed actions which may
             affect either the quality of the Reservation environment 
             or the fishery resources of the Tribe. 
 
         4.  Quality Assurance Review:  The Tribe understands that all
             applications for assistance awards involving environmental
             related measures for data generation must include a Quality
             Assurance Plan acceptable to the awarding official in
             accordance with applicable federal regulations.
             Nevertheless, the Tribe is free to explore innovative 
             methods of solving environmental problems which may be of
             benefit.  All results will be subject to evaluation and
             acceptance by both parties.

         5.  Compliance:  EPA retains responsibility for assuring that
             the actions of the parties hereunder comply with 
             applicable federal environmental law.

         6.  Funding:  During the term of this Agreement, EPA shall 
             assist the Tribe in applying for available program 
             development and implementation funds for which the Tribe 
             may be eligible.  EPA reserves the right to make the final
             determination whether funding shall be provided, and 
             under what conditions.

         7.  Annual Report:  At the end of one year, a report will be
         prepared by each of the parties' representatives on the Review
         Committee established in Section VI.B of this Agreement.
         Such evaluation shall include an evaluation of this Agreement,
         accomplishments during that year, and recommendations for use
         by the Tribe and EPA.

     B.  Review Committee

         In order to facilitate implementation of this Agreement, and
         further the relationship between the Tribe and EPA, and
         EPA-Tribal Review Committee is hereby established.  The Review
         Committee shall also promote communication and coordination
         between the parties.  The Review Committee shall initially
         consist of two (2) members designated by the Tribal Chiefs, and
         two (2) members designated by the EPA Region II Regional
         Administrator.  Additional members may be added as deemed
         necessary by the original committee.

         1.  Actions:  For the purpose of conducting business, a quorum
             of the Review Committee shall consist of four (4) members.
             The Review Committee shall take action by affirmative vote
             of three (3) members.  The Review Committee is advisory 
             in nature, and its actions are not binding on either 
             party to this Agreement.

         2.  Officers:  The Chairman of the Review Committee shall be
             designated by the Tribe and the Vice-Chairman shall be
             designated by EPA.  The Chairman and Vice-Chairman shall 
             each serve at the pleasure of the party whom he or she
             represents.

         3.  Ex-officio Members:  All members of the Tribal Council not
             members of the Review Committee; the Director of the 
             Eastern Area Office of the Bureau of Indian Affairs (BIA),
             or his or her designee; the Regional Administrator of EPA
             Region II, or his or her designee; a representative from 
             the Mohawk Council of Chiefs, or his or her designee; a
             representative from the Mohawk Nation Council of Chiefs, 
             or his or her designee; the Director of the Nashville Area
             Office of the Indian Health Service (IHS), or his or her
             designee; the Director of the Office of Indian Programs of
             the Department of Housing and Urban Development (HUD), or
             his or her designee; the Commissioner of the New York 
             State Department of Environmental Conservation, or his or
             her designee; and the Commissioner of the New York 
             State Department of Health, or his or her designee, shall
             be entitled to serve as ex-officio (non-voting) members 
             of the Review Committee.

         4.  Meetings:  The Chairman or any two members of the Review
             Committee may, upon reasonable notice, call a regular 
             meeting of the Committee to be conducted either in person
             or by telephone conference call.  Such meetings shall 
             initially be held quarterly, unless the parties agree 
             otherwise.  At all meetings the members of the Review 
             Committee may invite their respective staffs or attorneys
             to attend.

         5.  Dispute Resolution:  The Review Committee shall also be the
             forum for discussing any disputes which may arise between
             the parties regarding implementation of this Agreement 
             and the Committee may make non-binding recommendations to
             both parties of this agreement regarding the resolution 
             of such disputes.

     C.  Revisions/Amendments

         This Agreement may be amended at any time except as limited by
         applicable regulations or laws.  Amendments shall be made by
         supplemental Agreements executed in writing by the parties 
         hereto, as required in order to carry out any of the 
         provisions of this Agreement or for any other purpose in 
         furtherance of this Agreement.  This Agreement may be revised
         or amended to incorporate Agreements with the IHS, BIA, HUD, 
         and any Federal, Tribal, State, or County governments as 
         appropriate.

     D.  Written Communication

         Written communications pursuant to the provisions of this 
         Agreement shall be delivered or mailed as follows:

         1.  To the Tribe:  Chief Harold Tarbell, St. Regis Mohawk 
             Tribe, Hogansburg, New York 13655, with a copy to the 
             Director of the St. Regis Environmental Health Department.

         2.  To the EPA:  Regional Administrator, EPA Region II, 26 
             Federal Plaza, New York, New York 10278, with a copy to 
             the Indian Coordinator, EPA, Region II.

V.   TERMINATION

     This Agreement shall continue in effect until either terminated by
     joint agreement of the parties, or either party terminates its
     participation in this Agreement upon thirty (30) days written 
     notice to the other party.  Such termination, however, shall not 
     relieve any party of responsibilities otherwise prescribed by law
     or regulation.

VI.  EXECUTION

     This Agreement shall be effective when executed by all parties.

IN WITNESS WHEREOF the parties have executed this Agreement on the
dates attested to below.

For the St. Regis Mohawk Tribe

     BY:

         Head Chief Brenda LaFrance              (Date)
         Tribal Council

     BY:

         Chief Harold Tarbell                    (Date)
         Tribal Council

     BY:

         Chief L. David Jacobs                   (Date)
         Tribal Council

For the United States Environmental Protection Agency

     BY:

         William J. Muszynski, D.E.              (Date)
         Acting Regional Administrator
         EPA-Region II


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