Status Report to the Court
                                  Number Eleven
                                      For the Period
                                           July 1, 2002 through September 30, 2002


























                                                          November 1, 2002



                           Eleventh Report to the Court
                              November 1, 2002


                                                                         TABLE OF CONTENTS

                              I.     INTRODUCTION ....................................................................................................... 3

                              II.    SECRETARY GALE NORTON'S OBSERVATIONS .............................................. 5

                              III.   DEPARTMENT OF THE INTERIOR ....................................................................... 7
                              A.    INFORMATION TECHNOLOGY ............................................................................................... 7
                              B.    CADASTRAL SURVEY ................................................................................................................. 19
                              C.    MINERALS MANAGEMENT SERVICE .................................................................................... 23
                              D.    WORKFORCE PLANNING .......................................................................................................... 25

                              IV.   OFFICE OF INDIAN TRUST TRANSITION ............................................................ 29
                              A.    TRUST BUSINESS PROCESS MODELING .............................................................................. 34
                              B.    INDIAN TRUST BUSINESS PLAN .............................................................................................. 37
                              C.    PROBATE ....................................................................................................................................... 39
                              D.    INDIAN TRUST SYSTEMS .......................................................................................................... 44
                              E.    TRUST DATA QUALITY ANALYSIS ......................................................................................... 47
                              F.    OFFICE OF HISTORICAL TRUST ACCOUNTING ................................................................ 50

                              V.    OFFICE OF THE SPECIAL TRUSTEE ..................................................................... 62
                              A.    CURRENT ACCOUNTING ACTIVITIES .................................................................................. 64
                              B.    RECORDS MANAGEMENT ........................................................................................................ 70
                              C.    TRAINING AND TRUST MANAGEMENT STAFFING ........................................................... 74
                              D.    RISK MANAGEMENT AND INTERNAL CONTROLS ........................................................... 77
                              E.    APPRAISAL .................................................................................................................................... 81

                              VI.   BUREAU OF INDIAN AFFAIRS .............................................................................. 85
                              A.    FRACTIONATION ........................................................................................................................ 85
                              B.    OFFICE OF TRUST POLICIES AND PROCEDURES .............................................................. 91



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                           Eleventh Report to the Court
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                           VII.     ACRONYMS ..................................................................................................... 96








































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                           Eleventh Report to the Court
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                                I.  INTRODUCTION
                           This 11 th
                                       Report to the Court (Report) represents the period from July 1,2002, through
                           September 30, 2002, updating the Court on Indian trust reform and trust management
                           activities. The Report is similar in structure to previous Reports.
                           Several significant events happened during this reporting period. An Acting Special
                           Trustee for American Indians was appointed to fill the vacancy in the Office of the
                           Special Trustee. The Acting Special Trustee is extremely well qualified to guide the
                           work of the Office of Special Trustee (OST). Her lead on reform of the management and
                           accounting of Indian trust funds has been one of the most successful trust reform
                           activities underway. She has also been working closely with the Office of Indian Trust
                           Transition (OITT) on several projects, which have shown great promise, including trust
                           data quality, probate reform and trust systems. This work continued with staff assigned
                           to OITT, and was monitored by the Acting Special Trustee. In addition, the Acting
                           Special Trustee was actively involved in the "As-Is" and "To-Be" business process
                           modeling, which is being used to create an effective trust business operating organization.
                           Another significant event during this reporting period was the agreement on a proposed
                           reorganization plan with the Tribal Task Force. The Tribal Task Force proposed adding
                           an office of Undersecretary for Indian Affairs to the Department of the Interior. The
                           purpose of the Undersecretary's office was to create a high level, single executive
                           authority within the Department of the Interior that would be accountable for oversight
                           and management of trust activities. The Tribal Task Force indicated its desire to have
                           most of the OST functions migrate to the new Undersecretary during a one or two year
                           transition period. These suggestions were accepted by DOI Task Force members and
                           drafting work on the appropriate legislation to accomplish this task was undertaken. At a
                           later meeting held in Alexandria, VA, the Tribal Task Force declined to support the
                           legislation, and advised DOI that the tribes would be submitting their own legislative
                           proposal. The proposal by the tribes contained language that was unacceptable to DOl.
                           During the consultation process, however, valuable information and ideas were
                           developed on many subjects. This information will be the basis for continuing
                           discussions with the tribes as DOI seeks to implement the organizational changes to
                           accomplish trust reform and management of trust business.
                           A major development also occurred in the Office of Historical Trust Accounting
                           (OHTA). OHTA completed a portion of the first phase of its accounting of Individual
                           Indian Money (IIM) accounts. A Historical Statement of Account for judgment fund
                           accounts for a group of account holders was completed during this reporting period.
                           Additional account statements should be completed during the next reporting period, and
                           a plan for the historical accounting of all funds is under development. Issuance of these
                           historical account statements is a major step toward meeting the Court ordered account
                           reconciliation for all account holders.


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                           Eleventh Report to the Court
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                           Significant progress to address trust management deficiencies was accomplished during
                           this reporting period. The acting training coordinator, under the direction of OITT, has
                           developed a relationship with the Cannon Financial Institute to create a trust training
                           program for all DOI managers. This course is intended to provide managers with specific
                           knowledge of the duties of a trustee in the performance of their fiduciary trust activities.
                           The Cannon Financial Institute is often used by commercial trust organizations to provide
                           similar training. The training coordinator position will be established in the Office of the
                           Special Trustee during the next reporting period and will be responsible for the
                           development and coordination of all trust training activities.
                           A vacancy announcement for the Director of the Trust Policy, Procedures and Regulatory
                           Affairs Office was prepared and will be advertised during the next reporting period. This
                           position will report to the Office of the Special Trustee. This person will be responsible
                           for assembling a staff of people to complete the arduous task of bringing all trust policies
                           and procedures into compliance.
                           A new section in this Report will give details about the development efforts of the Indian
                           Trust Business Plan (Plan). This planning effort has been directed by OITT since early in
                           calendar year 2002. It will be the first comprehensive operational plan for DOI trust
                           operations and replaces the limited, High Level Implementation Plan reported on
                           previously. The Mission Statement, Goals and Objectives of the Plan have been
                           approved by the managers of affected DOI agencies and by the Tribal Task Force Plan
                           Subcommittee. The Plan will be more fully developed during the next reporting period
                           and is considered to be a business plan that should guide DOI's trust management efforts
                           well into the future. The Goals and Objectives in the Plan are the foundation for the
                           development of an operational plan for future use by DOl. The Objectives of the Plan
                           will be accomplished through the implementation of the "To-Be' business process model
                           during the next two-to-three years. This planning effort is not to be confused with the
                           Court ordered plan due January 6, 2003, although some elements will be visible in both
                           plans.
                           There continue to be many challenges to trust reform and the development of a trust
                           operating business. However, there are hundreds of employees in DOI who are
                           committing their time and talent to improving the way trust operations are performed.
                           With the help of these people and support contractors from outside DOI, trust
                           management improvements continue to be evident throughout DOl.



                           Eleventh Report to the Court
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                               11.  SECRETARY GALE NORTON'S OBSERVATIONS
                           This Eleventh Report to the Court describes the Department of the Interior's
                           accomplishments, pending projects and obstacles related to trust reform and historical
                           accounting. The report captures the magnitude, the complexity and the technological
                           challenges that accompany these issues. It is the responsibility of the Department of the
                           Interior to manage thousands of employees and hundreds of contractors in all regions of
                           the country who, in turn, are responsible for millions of acres of land and accounting for
                           millions of dollars held in trust for individual Indians and tribes.
                           This Department is committed to improving services for individual Indian and tribal trust
                           beneficiaries. In the past 20 months, Interior received an independent evaluation of past
                           trust reform efforts, created an office to plan, organize and direct the historical
                           accounting, provided Congress with a comprehensive report on historical accounting,
                           consulted extensively with tribal officials and proposed trust reform budgets with
                           significant increases for trust management.
                           This quarter saw continuing progress toward reform. For the first time, we prepared
                           Historical Statements of Account for individual Indians reflecting the complete history of
                           certain judgment accounts. Numerous actions were taken to improve computer security.
                           Senior managers worked on the trust reform and historical accounting plans for delivery
                           to the court on January 6, 2003. Some key staff positions were filled, and new ones
                           created.
                           A significant development during the past quarter was the appointment of Donna Erwin
                           to be Acting Special Trustee for American Indians. Donna has 33 years of experience in
                           all facets of private and public trust management. She was the Director of the Office of
                           Trust Funds Management for seven years and Deputy Special Trustee for Systems and
                           Projects since 2001. During Ms. Erwin's management of OTFM, the office successfully
                           converted over 250,000 trust accounts to a well-established, commercial automated trust
                           system. She also established standardized requirements and documentation for trust
                           accounting transactions and quality assurance measures to mitigate risk. As Deputy
                           Special Trustee, she restructured three major reform projects - Probate Backlog, Indian
                           Trust Systems and Data Quality Analysis. She also established and directed the "As-Is"
                           business process modeling effort. A member of the Muscogee-Creek Nation of
                           Oklahoma, Ms. Erwin has 23 years of private sector banking and trust management
                           experience. Her management skills are already making a difference in holding managers
                           accountable for getting work done, and she is working to reorganize the Office of Special
                           Trustee to make it more effective.
                           The Department's senior management spent a large amount of time this quarter
                           consulting with tribes. Obtaining the views of Native Americans we serve is important in
                           making decisions that affect both tribal and individual Indian beneficiaries. Consultation
                           is, however, a long and slow process. We have discussed the options for reorganizing


                           Eleventh Report to the Court
                           November 1, 2002

                           DOI Indian trust functions during the past nine months. These discussions will be helpful
                           in making final decisions.
                           A problem a century in the making will not be solved quickly. Serious challenges
                           remain. For example, the unfortunate division of land ownership into tiny fractions
                           continues at an exponential pace. This report notes, for example, that the Rosebud Sioux
                           Reservation has in excess of 3500 fractional land interests valued at less than one dollar
                           each. Also found in this report are instances of additional challenges such as inadequate
                           resources, inadequate training, insufficient policy guidance and inaccessibility to the
                           Internet.
                           Reform first requires understanding. The lack of an integrated comprehensive business
                           model has hampered previous trust reform efforts. Understanding how current trust
                           services arc provided by thousands of employees in hundreds of locations is essential.
                           We have undertaken the meticulous, painstaking work of developing an "As-Is" trust
                           business model that describes what documents are prepared by whom, what decisions
                           must be made when, and what information is needed for each decision. This modeling is
                           being applied to each of the core trust processes: beneficiary services, probate, title,
                           appraisals, cadastral surveys, surface and subsurface asset management and accounting
                           management. Ultimately, the "As-Is" trust business model will provide important
                           information for the development of the "To-Be" trust services business model.
                           The overall impact of this ongoing litigation on the Department's Indian trust
                           management has been even more pronounced this quarter than in previous time periods.
                           It has entered into our relations with the legislative branch, as various members of
                           Congress issued statements commenting on the Court's recent rulings. This litigation
                           entered into the consultation process as well. I have heard reports that plaintiffs' counsel
                           inserted unrelated issues into that process, which proved divisive. Perhaps more
                           importantly, departmental employees have seen highly regarded, hard-working career
                           colleagues who have devoted their lives to public service vilified by plaintiffs' attomeys
                           in court filings, on the Internet and in the media. I believe that this vilification has caused
                           many of the Department's most experienced, conscientious employees to try to avoid
                           involvement in trust matters.
                           Is trust reform complete? No. Is historical accounting complete? No. Will mistakes be
                           made in the future? Yes. But the effort to accomplish trust reform and historical
                           accounting is headed in the right direction.
                           Interior's senior managers and many career employees are working hard to study,
                           investigate, and to find solutions to difficult issues. The complexity of a decentralized
                           bureaucracy deeply tied to Indian culture, with implications for politics within Indian
                           Country and Congress is staggering. There are few clear answers. Every employee,
                           every tribe and every decision maker has a slightly different view of the current problems
                           and future solutions. The following report presents our current understanding ora
                           constantly evolving process.



                           Eleventh Report to the Court
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                             III.  DEPARTMENT OF THE INTERIOR
                                    A. INFORMATION TECHNOLOGY
                           Introduction
                           The Bureau of Indian Affairs (BIA), the Office of the Special Trustee (OST) and, to a
                           lesser extent, other agencies of DOI rely upon Information Technology (IT) systems to
                           fulfill the trust duties to Native Americans pursuant to the American Indian Trust Fund
                           Management Reform Act of 1994 (P.L. No. 103-412), along with other applicable
                           statutes, regulations and Court orders. These IT systems store important information
                           (e.g., land ownership records, interests in monetary accounts, lease payment information,
                           records of cash disbursements) or provide various computing capabilities, including
                           functions critical to the proper administration of the trust.
                           This section incorporates the related efforts taken by DOI in IT Security (including BIA
                           Office of Information Resource Management Security) and Computer and Business
                           Systems Architecture.
                           On December 5, 2001, the effect of accumulated IT security weaknesses resulted in a
                           Temporary Restraining Order (TRO) that required DOI to "immediately disconnect from
                           the Internet all information technology systems that house or provide access to Individual
                           Indian Trust Data (IITD)" and to "immediately disconnect from the Internet all
                           computers within the custody and control of the Department of the Interior, its employees
                           and contractors that have access to IITD."
                           Subsequently, on December 17, 2001, the Court entered a "Consent Order Regarding
                           Information Technology Security" (Consent Order). Among other things, the Consent
                           Order provides the terms and conditions upon which DOI may seek the concurrence of
                           the Special Master to restore connections to the Intemet. A key component of the process
                           involves providing documentation to the Special Master that identifies which IT systems
                           house or provide access to IITD.
                           For the purposes of this report and consistent with the definition included in the Consent
                           Order, the term "information technology system" refers to "[a]ny equipment or
                           interconnected system or subsystem of equipment, that is used in the automatic
                           acquisition, storage, manipulation, management, movement, control, display, switching,
                           interchange, transmission, or reception of data or information, including computers,
                           ancillary equipment, software, firmware, and similar procedures, services (including
                           support services) and related sources."
                           For the purposes of this section of the report and consistent with the definition included
                           in the Consent Order, the term "IITD" refers to all "data stored in an information
                           technology system upon which the Government must rely to fulfill its trust duties to



                           Eleventh Report to the Court
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                           Native Americans pursuant to the Trust Fund Management Reform Act of 1994 (P.L. No.
                           103-412), other applicable statutes and orders of this Court reflecting, for example:
                              The existence of individual Indian trust assets (e.g., as derived from ownership data,
                               trust patents, plot descriptions, surveys jacket files, statement of accounts);
                              The collection of income from individual Indian trust assets (e.g., as derived from
                                deposit tickets, journal vouchers, schedule of collections);
                              Use or management of individual Indian trust assets (e.g., as derived from leases,
                                sales, rights-of-way, investment reports, production reports, sales contracts); or
                              The disbursement of individual Indian trust assets (e.g., as derived from transaction
                                ledgers, check registers, transaction registers, or lists of canceled or undelivered
                                checks)."
                           IITD resides on IT systems located within several DOI Bureaus and Offices. These
                           systems exist on a variety of communications networks and hardware and software
                           platforms and are of varying states of functionality.
                           For DOI overall, relatively few IT systems contained IITD. Results from a broad systems
                           certification process conducted in January - February 2002 indicated that approximately
                           ninety-four percent (94%) of DOI's IT systems did not house IITD. In some Bureaus or
                           Offices, a few systems were identified that contained IITD, and efforts were made to
                           isolate or reconfigure those systems to ensure that security considerations were
                           addressed. Generally, proposals to reconnect to the Intemet or resume operations (where
                           systems were turned off as a result of the TRO) have been presented to and received the
                           concurrence (final or preliminary) of the Special Master.
                           The remaining six percent (6%) of the IT systems identified as having IITD are, in large
                           part, not connected to the Internet. These systems include a majority of the systems
                           supporting BIA, OST (which is operating within BIA's network), Office of Hearings and
                           Appeals (OHA), and the Office of the Solicitor (SOL).
                           Accomplishments and Completions
                           During the reporting period (July 1,2002 through September 30, 2002), DOI continued to
                           work closely with the Special Master on matters related to IT systems security. DOI has
                           cooperated in the investigations conducted by the Special Master's experts, and DOI has
                           taken action to improve computer system security when potential weaknesses have been
                           identified. The DOI Chief Information Officer (CIO) has issued guidelines for preparing
                           evaluations, assessments, and plans in accordance with OMB Circular A-130 (A-130),
                           Appendix III requirements and National Institute of Standards and Technology (NIST)
                           guidance. The relative security and integrity of DOI's computer systems is gradually
                           improving. Some of the more noteworthy matters relating to IT systems security include:



                           Eleventh Report to the Court
                           November 1, 2002

                           DOI IT Security
                           DOI's IT security program is based on tenets of public law such as the Computer
                           Security Act of 1987 and Government Information Security Reform Act (GISRA),
                           Executive Branch directives such as A-130 and PDD - 63, and guidelines developed by
                           NIST. These general principles were augmented by DOI-specific requirements and were
                           used to develop a recently enacted DOI IT Security Policy, an IT Security Plan, and an IT
                           Security Handbook. Achieving compliance with all aspects of the security program
                           continues to be a challenge. In addition to policies and procedures, DOI has identified
                           the following major areas for strategic focus:
                           Management Support and Performance Measures:
                           *   On August 26, 2002, the Deputy Secretary issued a memorandum, "Information
                                Technology Investment Management," to facilitate compliance with the IT Security
                                Program and effective management of IT investments.
                              A new performance measurement tool for assessing IT security programs at the
                                bureau level based on the NIST Special Publication 800-26, "The Security Self-
                               Assessment Guide for Information Technology Systems," was developed. This new
                                IT security program-level assessment guide incorporates the critical elements of the
                                NIST SP 800-26 and includes questions to identify management and DOI-specific
                                performance measures.
                              DOI developed a draft Strategic Plan to Reach A-130, Appendix III compliance based
                                on NIST methodology. This plan details a structured, consistent approach to achieve
                                A-130, Appendix III Certification and Accreditation.
                              DOI's CIO Security Officer has issued guidelines for preparing asset valuations, risk
                                assessments, system security plans, and contingency plans in accordance with A-130,
                                Appendix III requirements and NIST guidance. These IT security policies and
                                guidelines include additional guidance in the form of technical memoranda.
                              DOI's Expert Assistance - Security Contractor, Science Applications International
                                Corporation (SAIC), is engaged in supporting both Deparhnent and Bureau security
                                requirements. The contract provides the Department, Bureaus and Offices with
                                security consulting, security assessment and engineering, security validation, security
                                analysis, and security program support.
                              DOI identified requirements to develop a web portal for managing security efforts,
                                posting policies and other security resource documents, as well as running automated
                                monitoring, remediation tracking, and scanning tools. DOI will scan for System
                                Administration, Networking and Security (SANS) Institute Top 20 most critical
                                Internet security vulnerabilities. This portal will assist DOI in managing the A-130,
                                Appendix III accreditation process.
                              On July 29, 2002, and on August 1, 2002, two security incidents were reported to the
                                Associate Deputy Secretary, and subsequently to the Special Master, for unauthorized
                                connection of DOI computer equipment to the Internet at OST and BIA respectively.
                                Both incidents were reported through DOI's incident handling process and are under
                                investigation by the Inspector General. Personnel actions are pending.



                           Eleventh Report to the Court
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                         IT Security Initiatives:
                            On July 16, 2002, DOI CIO approved and distributed the guidelines, "Hardening of
                             Information Technology Systems," which includes specific technical solutions for
                             "hardening" the IT infrastructure. Focusing on hardware, software and procedures,
                             this hardening effort begins with strengthening the outer network perimeter and then
                             works inward to servers and then to the desktops.
                            DOI IT security personnel are building the information security portion of the Interior
                             Enterprise Architecture (IEA) and have completed the Technical Reference Model
                             (TRM) phase. The TRM defines thirteen principles that provide guidance for the
                             design and selection of security technology components. The TRM within the
                             Information Security domain of the lEA will be defined on an ongoing basis and
                             includes components and standards developed during the IT infrastructure hardening
                             effort noted above. During September 23-24, 2002, members of the IT Security
                             Domain Working Group Team met to review the current version of the IT security
                             TRM and examine standards for emerging technologies such as wireless
                             communication and instant messaging.
                            WorldCom completed the technical design of DOI's secure trust network (TrustNet).
                             This design includes an enhanced security capability at the connection point between
                             the network and the Intemet (the Intemet point of presence or DMZ). WorldCom is
                             finalizing a contractual document to initiate the testing and delivery of TrustNet to
                             BIA once the base FY 2003 budget is approved and DOI can obtain reprogrammed
                             funds to pay for this effort.
                            On August 8, 2002, DOI briefed the Special Master on the ZANTAZ, Inc. proposal,
                             and on September 20, 2002, DOI provided additional information as requested by the
                             Special Master. Following the Special Master's concurrence with DOI's proposal,
                             DOI awarded a contract to ZANTAZ on September 27, 2002, to outsource automatic
                             cmail capture, archival and retrieval. This action will, when implemented, enable DOI
                             to capture email related, among other things, to Trust Management and Individual
                             Indian Money Accounts.
                         IT Security and Capital Asset Planning:
                            The budget justifications (Exhibit 300's) for IT systems were reviewed from an IT
                             security perspective for the first time this quarter in connection with the FY 2004
                             budget.  The review focused on IT security components relevant to the stage of the
                             system lifecycle (planning, design, development, testing, implementation, steady
                             state, or expiration). This year, for the first time, DOI's new capital planning
                             executive review boards met to assess major investments for IT systems.  All aspects
                             of system functionality and requirements analysis along with IT security were
                             reviewed to assure proper controls and funding were being addressed.
                         Training and Awareness:
                            In August 2002, DOI's CIO's Security Office developed and distributed an Interior
                             IT Security Awareness Brochure. In some cases, customized IT Security Awareness

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                           Eleventh Report to the Court
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                               Brochures were developed for specific bureaus. To date, over 32,000 brochures have
                               been printed and are being distributed.
                              DOI CIO continued its General End User IT Security Training Program highlighting
                               key security procedures and requirements outlined in the revised DM 375, Chapter
                                19. At least 53,586 employees (about 68%) have completed this training during this
                               reporting period. The training is accessed from the employees' web browser and
                               completed on-line. DOI employees who are currently disconnected from the Intemet
                               accessed the training via internal networks.
                              Specialized training in IT security is being encouraged for IT professionals. To date,
                                over twenty DOI IT security personnel received Certified Information Security
                                System Professional (CISSP) training and certification.
                           System Inventory and Prioritization:
                              The IT Security Team members, under the auspices of the IT Management Council,
                                are inventorying and prioritizing DOI IT systems. An acknowledged systems
                                inventory is the starting point for determining where to apply resources for managing
                                and securing information and IT systems.
                              Thc Interior Asset Valuation Guide was reviewed and expanded into an Interior IT
                                asset definition process. The draft IT asset definition process will be used at DOI to
                                measure information sensitivity and asset value to determine criticality of IT systems.
                                Based on a numerical value assigned during the draft IT asset definition process, DOI
                               plans to rank IT systems to facilitate objective resource allocations and work priority.
                           Bureau of Indian Affairs - Securi_, Efforts
                              On July 15, 2002, the Office of the Assistant Secretary- Indian Affairs (AS-IA) CIO
                                developed a report titled "Optimizing the Indian Affairs Information Technology
                                Infrastructure" to mitigate risks, reduce costs, and improve efficiency.
                              In August 2002, AS-IA CIO presented a corrective action approach to DOI and the
                                DOI Bureau CIOs. The presentation centered on an Enterprise Information
                                Management approach to managing and operating IT within BIA.
                              The AS-IA CIO met with each BIA Regional Director to identify specific IT
                                requirements and toured the Reston, VA BIA primary data center, the Albuquerque,
                                NM backup data center, the Denver, CO NBC data center, and the Denver, CO BLM
                                test lab.
                              On August 29, 2002, the Secretary re-assigned management responsibility for the
                                BIA Office of Information Resources Management (OIRM) to the AS-IA CIO. This
                                change in IT management is the first step in establishing the necessary management
                                control over IT planning and operations within BIA.
                              On September 10, 2002, the AS-IA awarded a contract to IBM to automate the
                                inventory process of all network-attached devices. The automated inventory will
                                enable BIA to validate the Security Technical Implementation Guide (STIG)
                                hardening and baseline for Windows 2000 upgrade requirements.


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                           Eleventh Report to the Court
                         November 1, 2002

                            On September 10, 2002, the AS-IA awarded a task order on DOI's Expert Assistance
                             - Security Contract with SAIC to conduct NIST 800-26 Review and Mitigation. In
                             the sites covered under the four phases of this stage, SAIC will implement STIGs and
                             provide guidance for network devices; run Nessus (security scanning software)
                             evaluations on all servers, and train BIA staff to run the Nessus tool continuously in
                             the future; complete NIST 800-26 Evaluations for A-130 compliance; develop a
                             work-off plan addressing how to fix vulnerabilities discovered in above NIST 800-26
                             review and vulnerabilities identified in the Findings and Recommendations database;
                             and work with BIA staff to correct deficiencies and vulnerabilities.
                            On September 11, 2002, the AS-IA awarded a contract to SeNet International to
                             provide security analysis, security planning, and security operations support.
                            On September 23, 2002, the AS-IA developed a document outlining the security
                             requirements for reconnecting to the Intemet. Secure E-Mail and Web Proxies and
                             system hardening efforts are planned to provide sufficient security for establishing the
                             reconnection of BIA to the Intemet.
                            On September 26, 2002, the AS-IA partnered with DOI to establish an enterprise
                             license for Microsoft products. This initiative will establish Windows 2000 as the
                             baseline secure workstation operating system.
                            On September 30, 2002, the AS-IA awarded a contract to BearingPoint, Inc.,
                             formerly KPMG Consulting, Inc., to conduct a systems boundary assessment. This
                             assessment will identify the paths and connection points on which data can flow in
                             and out of a system.
                         Office of the Special Trustee - Security Improvements
                         During the previous reporting period, OST added a task order to DOI's Expert Assistance
                         - Security Contract with SAIC to conduct NIST 800-26 Review and Mitigation. This
                         effort was completed by September 30, 2002. A synopsis of the security work performed
                         is provided below.
                            Assessed OST security program and network configuration to develop the Security
                             Remediation Work-off Plan
                            Purchased IT security hardware and software
                            Reviewed and updated OST procedures
                            Completed firewall installation
                            Performed security hardening efforts
                            Upgraded all workstations to a secure operating system (Windows 2000) and ran
                             Windows 2000 secure hardening tools
                            Completed Security Remediation Work-offPlan
                            Performed security scanning to identify and remediate vulnerabilities
                            Completed an independent security assessment and validation of security work
                             completed in preparation for proposing Internet reconnection.



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                           Eleventh Report to the Court
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                           Office of Hearings and Appeals - Security Improvements
                           OHA's firewall security improvements have been completed. OHA procured new IT
                           security hardware and software and utilized the SAIC contract to secure the
                           configuration, perform network scanning and validate the performance of the new
                           configuration.
                           UTILIZING THE AUDIT "FINDINGS AND RECOMMENDATIONS"
                           DATABASE
                           Extensive weaknesses in the security measures associated with the IT systems housing or
                           providing access to IITD have been identified by various audits and studies. These
                           weaknesses and associated recommendations have been compiled into a "Findings and
                           Recommendations" Database. DOI has enhanced the functionality of the Findings and
                           Recommendations database to provide additional support to Bureau CIOs and security
                           contractors performing security reviews:
                              Completed development of a user interface to allow for data entry of new security
                                weaknesses from a variety of sources (audit reports, studies, DOI Management
                                Control Reviews, Special Master site visits, and automated scanning tools)
                              Completed interface access to developed reports (e.g.; by Bureau, thematic groups,
                                finding status), charts and graphs.
                              Completed catalog characterizing weaknesses within the database as Operational,
                                Management or Technical and grouping those weaknesses into N1ST SP 800-26
                                thematic categories.
                           DOI is evaluating the possible use of two other tools for managing security programs:
                           An electronic data entry form to capture responses for the NIST SP 800-26, "Security
                           Self-Assessment Guide for Information Technology Systems" (implemented), and an
                           online service that provides current remediation actions for known security
                           vulnerabilities. DOI is also considering the use of internal scanning to test Department
                           and Bureau networks against the SANS Institute list of the Top 20 most critical Internet
                           security vulnerabilities and an automated tool to track systems reaching and maintaining
                           A- 130, Appendix III compliance.
                           These tools could enable Bureau Security Officers to evaluate current security
                           weaknesses, search through the "Findings and Recommendations" Database for
                           weaknesses that have been previously identified, note if they are outstanding or recurring,
                           and utilize the online service to find up-to-date instructions on correcting technical
                           security weaknesses.
                           PURSUING CONCURRENCE TO OPERATE SYSTEMS OR RECONNECT TO
                           THE INTERNET
                           During this quarter, DOI worked with the Special Master and his experts as they tested
                           DOI systems, identified security vulnerabilities, and validated security vulnerability

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                           Eleventh Report to the Court
                           November 1, 2002

                           remediation work completed by the Bureaus and DOI's security experts. Some delay
                           occurred due to the need to procure and configure new equipment for security detection,
                           monitoring, and/or enforcement. The percentage of systems reconnected to the Internet
                           or resuming operations remained at approximately ninety-four percent (94%).
                                    The following systems received concurrence from the Special Master during this
                           quarter:
                                             Minerals Management Service (MMS) Denver - Concurrence to
                                             Reconnect
                                             BIA Division of Energy and Mineral Resources (DEMR) - Concurrence
                                             to Operate
                                             BIA Anadarko (7 sites) - Concurrence to Operate
                                              OST Interior Department's Electronic Acquisition system (IDEAS) -
                                              Concurrence to Connect to the Intemet
                                    The following proposals are under review by the Special Master:
                                              BIA "Dark" Systems (Land Title Mapper (LTM), Key File Document
                                              Imaging System (KeyFile), Native Allotment Data Collection and Access
                                              Project (NADCAP))
                                              BIA Administrative PCs
                                             MMS State and Tribal Royalty Audit Committee (STRAC) sites
                                             MMS Hemdon
                                    The following proposals are under review by the Associate Deputy Secretary:
                                              Bureau of Reclamation (BOR) trust Systems (awaiting a rewrite from
                                              BOR)
                                              Fish and Wildlife Service trust Systems
                                              SOL request for temporary reconnection for testing
                                              OHA request for temporary reconnection for testing
                           PURSUING COMPLIANCE WITH OMB CIRCULAR A-130_ APPENDIX III
                           During this quarter, DOI identified a Departmental certification and accreditation process
                           based upon the new NIST SP 800-37. The major goal of DOI's IT security program is to
                           achieve certification and accreditation for IT systems in compliance with A-130,
                           Appendix III. Efforts this quarter include:
                           ,,   Work on a draft Strategic Plan to Reach A-130, Appendix III Compliance
                              Adopt a standard, NIST 800-37 based approach to reach A-130, Appendix III
                                Certification and Accreditation for high risk systems, which includes fiduciary trust
                                systems
                              Identify security contracts and funding for OHA, OSM and MMS to perform Initial
                                Assessments (first phase of A-130, Appendix III Accreditation).




                                                                                  14



                           Eleventh Report to the Court
                           November 1, 2002

                           COMPUTER AND BUSINESS SYSTEMS ARCHITECTURE
                           As discussed in the last quarterly report, progress on DOI's Architecture Program and the
                           Trust Architecture Program will be addressed in this section.
                           Departmental Enterprise Architecture Pro,ram
                              DOI's Chief Architect provides quarterly briefings to OMB on the Plan and Schedule
                                for the Interior Enterprise Architecture (IEA) program. To date, OMB has
                                satisfactorily accepted DOI's IEA approach, progress and products.
                              Two Department-level trust architects were selected and hired. These architects will
                                focus on trust architecture across all trust bureaus, with significant focus on the
                                development and implementation of the BIA trust architectural program.
                              In September 2002 DOI negotiated and signed an agency-wide three year enterprise
                                desktop  and service  license  agreement  with  the  Microsoft  Corporation.    This
                                agreement will enable DOI to address security weaknesses associated with older
                                versions of the Windows operating system.
                              In September 2002 DOI completed and signed a contract with ZANTAZ for
                                implementation of real-time e-mail capture.
                           Trust Architecture Program
                              On July 11-12, 2002, the Trust Architecture Working Group recommended
                                establishing a trust governance structure, including an architecture advisory board,
                                change control board, executive steering committee, and project teams for specific
                               trust components.
                              The Trust Architecture Working Group completed a Trust Architecture Work Plan on
                                August 6, 2002. This plan describes work to be undertaken and products to be
                               produced by the Trust Architecture Working Group (or successor group).
                              On August 20, 2002, DOI, BIA, OST, and OITT presented their draft architecture
                               plans to the Associate Deputy Secretary for the purpose of developing a common
                                trust architecture. The trust architecture will be nested within the Interior Enterprise
                                Architecture, which will in turn comply with the Federal Architecture.
                              In September 2002 DOI awarded a one-year contract for two commercial
                                architectural professionals to support the Trust Architecture Program.
                           TRUST INFORMATION TECHNOLOGY BUDGET
                              Throughout July and August 2002 DOI prepared a unified BIA, OST and OITT FY
                                2004 budget request. The FY 2004 Budget request is pending within OMB.
                              BIA identified approximately $15 million in prior year funding that was reapplied to
                                Indian Affairs IT initiatives.
                              BIA established OMB A-11 Exhibit 300s for Enterprise Information Management,
                                TrustNet, LRIS and IRMS.



                                                                                 15



                           Eleventh Report to the Court
                           November 1, 2002

                           DELAYS/OBSTACLES
                           Many challenges must be addressed regarding the security and integrity of IT systems.
                           The shortcomings and failures of the overall system are well documented. A host of prior
                           reports from government institutions, private contractors, and, most recently, the Special
                           Master, SRA and NIST have pointed out in great detail the security weaknesses (e.g.,
                           lack of firewalls, intrusion detection, active log monitoring, etc.) of the systems housing
                           IITD. These documents have been provided to the Court before and during this reporting
                           period.
                           There are obstacles or impediments to achieving acceptable IT systems improvements.
                           For example:
                                    Acceptable standards for IT systems security need to be articulated and the
                                    standards need to be realistic. As indicated in this section of the 11 th
                                                                                                                             report to
                                    the court, DOI has made progress in the development of standards for hardening
                                    IT system security and achieving compliance with A-130, Appendix III. A
                                    standard process for assessing the security levels of our critical systems (Initial
                                    Assessment) has been developed. In the short term, for systems containing IITD,
                                    expectations need to be clarified regarding acceptable security measures that will
                                    permit DOI to undertake its critical work. In thc long term, the negotiated
                                    systems security standard must balance the relative risks of providing access to
                                    the system against the need to conduct trust business processes.
                                    Past views within DOI (and the Federal government, in general) have not led
                                    to the development of a robust IT systems security infrastructure. Current
                                    security measures were designed to support traditional government programs,
                                    where openness with the public was accepted. Substantial efforts will be required
                                    to establish a solid, stable, dynamic and secure infrastructure designed to meet a
                                    new, robust set of requirements for trust reform and trust assets management.
                                    DOI, in conjunction with the Special Master, has been reviewing the relative
                                    security of trust-related IT systems and making improvements where needed.
                                    Employee fears about personal involvement in the CobeU litigation are
                                    undermining creativity and decision making.  As previously noted to the
                                    Court, the NIST CSEAT team reported that, "The current litigation is having a
                                    negative impact on employee performance. The employees who were
                                    interviewed by CSEAT appear to be trying to do the best job they can, but many
                                    stated that they are afraid to do anything for fear of being named in the lawsuit. A
                                    lack of action appears to go unnoticed, whereas well-intentioned actions appear to
                                    be penalized. This has resulted in behaviors that are unproductive and sometimes
                                    counter productive." These concerns continued during this reporting period.




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                           Eleventh Report to the Court
                           November 1, 2002

                                    Generally, the quantity and quality of information system technical
                                    leadership and support staff are insufficient. DOI and AS-IA are seeking to
                                    add technical leadership and support staff. DOI has selected Hord Tipton as the
                                    Chief Information Officer for the Department. AS-IA has hired Brian Bums
                                    (formerly Deputy CIO, Department of Health & Human Services) as its new CIO.
                                    DOI is seeking other qualified individuals to assist in improving the operations of
                                    DOI's trust-related IT systems. The lack of sufficient staffing will likely
                                    adversely impact the pace and quality of improvement efforts.
                                    The government (e.g. DOI, OMB, Congress, etc.) needs to evaluate current
                                    funding requirements. Making material improvements in the current status of
                                    IT system security will likely require additional funding. DOI sought and
                                    received approval from Congress to reprogram approximately $12 million in
                                    funds to improve IT security. BIA also identified a significant amount of prior-
                                    year funding, which was made available for IT improvements. DOI is working
                                    with Congress to address its funding requirements for FY 2003. IT initiatives are
                                    being delayed due to the funding limitations caused by Congress's Continuing
                                    Resolution. Once a FY 2003 budget is passed, DOI plans to work with OMB and
                                    Congress to obtain reprogrammed funds to support other IT security initiatives.
                                    In addition, DOI is working with OMB regarding funding requests for FY 2004.
                                    Trust-related systems are not integrated within DO1. The variety of systems
                                    identified within DOI are operated on various communications networks, on
                                    different hardware/software platforms and with different database configurations
                                    and varied security approaches. DOI has undertaken a general evaluation of these
                                    systems and is taking the initial steps to develop a Department-wide trust systems
                                    architecture.
                                    Inadequate resources and training to implement a comprehensive security
                                    program for trust-related systems. In some cases, needed policies and
                                    procedures have not been developed or adopted by the Department, Bureaus and
                                    Offices. In others, the policies and procedures have been adopted, but
                                    insufficiently implemented. DOI is evaluating its commitment to improve IT
                                    security measures and plans to prioritize needed improvements in providing staff
                                    direction, training, and funding requests.
                                    Computer systems specifications need to be reconciled against the multiple
                                    requirements contained in applicable statutes, regulations, Court orders,
                                    treaties, investigations, and Congressional budget directives.
                                    OMB has directed DOI to adopt an "enterprise architecture" plan.  Funding
                                    for trust system security improvements may be subordinate to receiving OMB's
                                    approval of the architecture plan. Therefore, the schedule to implement trust-
                                    related initiatives is subject to OMB concurrence, which may impact schedules
                                    and resource availability.

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                           Eleventh Report to the Court
                           November 1, 2002


                                    The reliability, quality and structure of the relevant application systems and
                                    the data contained are not fully known at this time. Accomplishment of
                                    business process standardization to the greatest extent possible is important. The
                                    degree to which trust-related IT systems can be consolidated or integrated will
                                    influence the design of security measures and the overall effectiveness of these
                                    security measures.
                           In the short term, DOI's employees and its associated security experts arc taking steps to
                           address these issues as a part of the efforts being undertaken to improve the security of
                           individual Indian trust systems. In the longer term, DOI will be addressing these issues
                           in more detail as a part of its efforts to achieve compliance with A-130.
                           Assurance Statement
                           I concur with the content of the information contained in the Information Technology
                           section of the 11 th
                                                  Report to the Court. The information provided in this section is
                           accurate to the best of my knowledge.
                           Date:  November 1, 2002
                           Name: Signature on File
                                     James Cason
                                     Associate Deputy Secretary




















                                                                                  18



                           Eleventh Report to the Court
                           November 1, 2002

                                     B.  CADASTRAL SURVEY
                           Introduction
                           A cadastral survey is a land survey of sufficient scale to show the extent and
                           measurement of property boundaries. A cadastral survey as performed by the Bureau of
                           Land Management (BLM) is used to accurately identify land boundaries and to maintain
                           the related survey records for all public and tribal lands. These surveys require detailed
                           investigations of the history of land use and occupancy, legal document research, and
                           correlating on-the-ground, physical surveys with legal documents. A cadastral survey
                           plat shows and records property boundaries, subdivisional lines, official acreage,
                           building, and related details. The requirement for the BLM to direct and control the
                           survey of Indian lands is codified in 25 U.S.C.  176.
                           Most Indian lands have been surveyed. Many of these surveys are more than 100 years
                           old and the original sticks and stones which marked the property corners are increasingly
                           difficult to recover. Many of the individual allotments were surveyed by Bureau of
                           Indian Affairs (BIA) Indian Service surveyors, but few records of these surveys were
                           located. A request for assistance in locating these missing records has been sent to the
                           Office of Historical Trust Accounting (OHTA) for archival research of these records.
                           This request will be copied to the BIA.
                           The BLM and BIA conducted general inventories of cadastral survey needs on Indian
                           lands in 2001. These inventories identified $60 million in unmet, short-term needs for
                           these surveys, and another $51 million in projected needs. These identified needs
                           focused interest on the performance of these surveys and related topics, such as the
                           survey measurement-based Cadastral Geographic Information System (CGIS) like the
                           "Yakama Model." This model fully integrates land and survey records into a functional
                           geographic information system.
                           Accomplishments and Completions
                           Training Course, "Land Tenure in Indian Country:" The purpose of this course is to
                           improve efficiencies in addressing survey and land tenure issues through better
                           understanding of the appropriate use of surveys and surveyor services. The pilot for this
                           course was held September 16-19, 2002, at the Tamastslikt Cultural Institute, Umatilla
                           Indian Reservation, Pendleton, Oregon. This new training course was based on a similar
                           course developed by BLM and U.S. Forest Service (USFS) for realty specialists,
                           cadastral surveyors, appraisers and other land tenure specialists to help in broadening the
                           understanding of cross-cutting issues facing these specialists and agencies. The cross-
                           section of BIA, Tribal, Solicitor's Office, Office of Trust Risk Management (OTRM),
                           and BLM employees attending gave the course high marks in providing an awareness of
                           alternatives to surveys and other problem solving techniques. As a result of this course, it
                           is expected that the demand for surveys from BLM will decrease, and real estate
                           transactions will be expedited through more efficient processing by these trained land

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                           Eleventh Report to the Court
                           November 1, 2002

                           managers. This course will next be offered during 2003 at a yet-to-be determined time
                           and location. It is critical to the success of this educational effort to have tribal members
                           attend, and funding has been assured for tribal attendees.
                           Inventory of Survey Needs/Automated Cadastral Survey Request and Database:
                           The BIA/BLM general inventory of 2001 lacked specific parcel information and the
                           information necessary to prioritize the identified work or allow for programmatic
                           execution of the surveys. An automated request system and database are being developed
                           to refine the inventory and gather the necessary prioritization information. The first
                           delivery for the system, the automated request module, has undergone testing and use in
                           the Northwest Region in conjunction with the preliminary inventory in Oregon and
                           Washington States. This preliminary inventory captured in-depth information regarding
                           survey needs for the next two to five years from approximately one-half of the agencies
                           in those states. An analysis of that data will be performed to compare results with the
                           2001 general inventory. The entire inventory for those states will be completed by
                           January 2003.
                           The inventory of survey needs on a nationwide basis was stalled because the necessary
                           survey drivers or priorities, which will help determine which surveys are of the highest
                           need, have not been agreed upon. Efforts to reach consensus on priority criteria during
                           the next reporting period will continue. It is unlikely the nationwide inventory will be
                           completed by May 2003, as previously anticipated. Some BIA regional offices have
                           developed inventories that will become part of the national inventory.
                           Cadastrai Indian Project Manager Position: The Indian Project Manager position has
                           been advertised and a selection is anticipated during the next quarter. This position will
                           oversee the ongoing and future survey needs for Indian trust and Tribal lands. This
                           position will also coordinate between key Tribal, BIA and BLM groups and develop a
                           long-term strategic plan to meet critical survey needs.
                           Office of Historical Trust Accounting (OHTA) Pilot: The OHTA Cadastral Survey
                           Pilot on acreage errors and location errors has been completed. Current technology
                           allows greater precision for surveys. As a result of comparing original surveys to
                           resurveys of 37 selected allotments, it was determined that gross acreages in the legal
                           descriptions of those allotments varied from 0.7% (0.56 acres) to 20.7% (9.54 acres). In
                           some instances, this could impact the income value of the land if actual acreage is a
                           factor in determining value. If the land records have been updated to reflect the resurvey
                           information, the acreage differences between original surveys and resurveys should be of
                           no consequence. Further study is necessary to determine the correlation, if any, between
                           the reliability of the coordinate values of the Public Land Survey System comers and
                           resultant erroneous acreage value of allotments. On-the-ground resurveys of three other
                           allotments, however, indicated the allotments' actual attributes of size, shape, and
                           location were consistent with their assumed attributes. However, it is extremely difficult
                           to quantify the resulting inaccuracy in an IIM account until what is known about a tract
                           through the realty (title) records is integrated with what is known about a tract through

                                                                                 2O



                           Eleventh Report to the Court
                           November 1, 2002

                           modem survey and remote sensing technology, such as those represented by the Yakama
                           Model. These same conditions currently exist in the private sector.
                           Reports on the findings of this study will be sent to OHTA.
                           Current Status
                           Update on Issues: Report to the Court Number Ten, August 1, 2002
                           Expansion of Cadastral GIS Model, "Yakama Model:" The Cadastral Geographic
                           Information System Model (CGIS) weds ground-truthed location information for
                           cadastral surveys with current land status and resource data to create a usable spatial
                           representation of ownership, use, and resource information. This model was developed
                           by BLM's Cadastral Survey Program and the Yakama Tribe in a unique partnership. The
                           BLM supplied the expertise of a land surveyor and the Tribe supplied a specialist to
                           develop the system. The project combines the cadastral (land) information from the state,
                           county, BIA, and Tribe into a parcel (allotment) level database. This CGIS Model is a
                           fully functional, parcel-based system, which brings many economic benefits to the
                           Yakama Tribe. Seed funding from BLM has been supplied for a needs evaluation on the
                           Umatilla Indian Reservation, and an agreement was made between the Umatilla Tribe
                           and BLM to improve the accuracy of the CGIS. The Ute Mountain Ute, Southern Ute,
                           and Coeur d'Alene Tribes are establishing systems which fully integrate land and survey
                           records. South Dakota State University and the BLM are in discussion to expand this
                           model on the Tribal lands in North and South Dakota through a grant with the National
                           Science Foundation's Geospatial Academic Inter-Tribal Initiative for Digital
                           Government.
                           Workforce Issues: The plans for replacing BLM's depleted workforce of land surveyors
                           have been presented to BLM management. BLM has made this a high priority and a
                           model for other occupational series. This is necessary since approximately 50% of the
                           current land surveyors are eligible for retirement by 2008. BLM has implemented a
                           policy for "Recruitment and Relocation Bonuses and Retention Allowances" to help
                           alleviate this issue. Other alternatives, including contracting from the private sector, will
                           be explored as well.
                           Department of the Interior Indian Trust Lands Boundary Standards (Standards):
                           After an intemal review, the drat_ Standards are being revised. These Standards will
                           increase efficiencies in land transactions and help resolve boundary issues by establishing
                           processes, procedures and requirements for cadastral services. These Standards are
                           scheduled for departmental review in December 2002. After compilation of internal
                           comments and revisions, a public review period will run until September 2003.
                           Pilot Study of Risk Assessment for Cadastral/Services: The Office of Trust Risk
                           Management (OTRM) pilot study of trust cadastral services performed in a BLM State
                           Office has been delayed pending development of OTRM's criteria for assessing risk. The

                                                                                 21



                           Eleventh Report to the Court
                           November 1, 2002

                           pilot study will focus on risks associated with funding, process and priority setting. BLM
                           has provided subject matter experts to help the OTRM contractor develop the work
                           process flow charts, management control review questions, risk management plan
                           database and OTRM program review requirements. Further development of these
                           requirements is necessary before the pilot study can be initiated. It is anticipated that
                           additional meetings will be held during the next reporting period to resolve these issues.
                           Delays/Obstacles
                           The nationwide BLM/BIA inventory of survey needs has been delayed. Guidance to
                           regional offices for requesting surveys should be based on prioritization of need. This
                           will ensure that highest priority surveys, those with the greatest need, can be done first.
                           As a result, it is highly unlikely this inventory will be completed by May 2003 for the
                           FY 2005 budgetary strategies.  This will also impact the FY 2003 and FY 2004
                           identification of high priority survey projects: Without agreement on a prioritization
                           system, surveys will continue to be done based on ad hoc requests from Regional BIA
                           offices. Meetings between BLM and BIA will continue during the next reporting period
                           in an effort to reach consensus on a prioritization system for ordering surveys. This issue
                           is expected to be resolved before calendar year 2003.
                           Assurance Statement
                           I concur with the content of the information contained in the Cadastral Survey section of
                           the 11 m
                                     Report to the Court. The information provided in this section is accurate to the
                           best of my knowledge.
                           Date:  November 1, 2002
                           Name: Signature on File
                                    Donald A. Buhler
                                    Chief Cadastral Surveyor
                                    Bureau of Land Management













                                                                                 22



                           Eleventh Report to the Court
                           November 1, 2002

                                    C. MINERALS MANAGEMENT SERVICE
                           Introduction
                           The Minerals Management Service (MMS), Minerals Revenue Management (MRM) is
                           responsible for collecting, accounting for, and distributing mineral revenues from both
                           Federal and Indian mineral leases and for evaluating industry compliance with laws,
                           regulations, and lease terms. The MRM conducts its business processes, maintains
                           reported information, and distributes revenues at the lease level. The Bureau of Indian
                           Affairs (BIA) uses its ownership records to allocate revenues to individual Indians. The
                           MMS does not maintain information on individual Indian mineral beneficiaries.

                           Accomplishments and Completions
                           The MRM completed implementation of the major elements of the reengineered system
                           on November 1, 2001, and continues to phase in the less time-critical modules. During
                           the system shutdown, MMS was unable to process mineral revenue reports related to
                           Indian or Federal leases. After the systems were reactivated in March 2002, MMS placed
                           its priority on processing individual Indian mineral lease revenue reports so that it could
                           produce distribution files to BIA. MRM's Indian mineral revenue backlogs arising from
                           the system shutdown have now been eliminated and MRM is processing current revenues
                           on a routine cycle.
                           Current Status
                           In the previous report, MMS estimated that the final module - Exception Processing -
                           would be completed by September 30, 2002. The estimated completion date for that
                           module has been extended until March 31,2003 due to the continued recovery efforts
                           associated with the system shutdown of December 2001.
                           Three additional recommendations were added to this activity as a result of the Electronic
                           Data Systems (EDS) Report on Trust Reform. These recommendations will help provide
                           appropriate documentation of procedures and agreements. But none represent problems
                           that are adversely affecting the fulfillment of DOI's Indian Trust responsibilities.
                                1.       Establish Ongoing Application Change Control Procedures. To document
                                         how software enhancements and modifications are approved and implemented
                                         in the steady state environment - (March 3 l, 2002).
                                2.       Resolve Information Exchange Issues between MMS and all (DOD Systems.
                                         These procedures will document information exchange procedures and
                                         contain executed service level agreements among MMS, BLM, OTFM, and
                                         BIA - (Date to be determined).



                                                                                 23



                           Eleventh Report to the Court
                         November 1, 2002

                             3.      Establish Procedures Regarding Royalties Disbursement. This will document
                                     royalty disbursement procedures and contain executed service level
                                     agreements between MMS and BIA - (Date to be determined).
                         Delays/Obstacles
                         Because of the recovery efforts associated with the system shutdown, the implementation
                         of the Exception Processing Module will be delayed from September 30, 2002, as
                         reported in the previous quarterly report, to March 31, 2003.
                         Assurance Statement
                         I concur with the content of the information contained in this project manager report, set
                         forth above. The information in those sections is accurate to the best of my knowledge.
                         Date:  November 1, 2002
                         Name: Signature on File
                                 Phil Sykora
                                 Manager, Financial Management
                                 Mineral Revenue Management
                                 Minerals Management Service.




















                                                                          24



                           Eleventh Report to the Court
                           November 1, 2002

                                    D. WORKFORCE PLANNING
                           Introduction
                           Workforce planning (WFP) is a comprehensive process that provides managers with a
                           framework for making staffing decisions based on an organization's mission, strategic
                           plan, budgetary resources, and the associated skills needed to accomplish mission tasks
                           now and in the future. Indian trust management WFP is underway in the DOI and
                           involves a comprehensive process of assessing current workload, current program
                           efficiencies and gaps, future work and skill gaps together with options for addressing
                           future workforce needs. This planning process is a large undertaking that requires
                           significant top-down leadership and focus on field-level personnel who actually know
                           about the work being performed. Trust organizations are being asked to combine budget,
                           program performance, and workforce priorities into a cohesive strategy that is useful for
                           human resources planning as well as for budget justifications.
                           Accomplishments and Completions
                              The 12 BIA Deputy Regional Directors attended the DOI One-Day Overview
                                Course on Workforce Planning. The course provided the Deputy Regional
                                Directors an outline of the DOI WFP model and discussion of the latest tools and
                                methods for workforce planning. In formal evaluations of the training session,
                                participants commented favorably on the strengths of the concept definitions and
                                examples, contributions of class members and the workbook. At this training event,
                                the regional leaders addressed the membership, time and place for the follow-on DOI
                                Three-Day Workforce Planning Workshop for management staff and human
                                resources (HR) practitioners throughout the regions. These workshops will continue
                                to be delivered throughout FY 2003.
                              The management team of the Southwest Region BIA (Albuquerque) attended the
                                DOI Three-Day Workforce Planning workshop. During the workshop, the
                                participants expressed that they had learned how to apply the DOI model for
                                workforce planning and how to use workforce planning tools. In evaluating the
                                effectiveness of this training session, it was noted that the team left the session with
                                the basic components to include in a first workforce plan.
                              The Indian Trust Human Resources Advisor completed a field visit to the
                                Southern Plains Region staff in Anadarko, OK. The purpose of this visit was to
                                observe and assess trust management operations as managed in the Bureau of Indian
                                Affairs and to advise on the agency's WFP efforts. Regional staff members and the
                                Anadarko Agency Superintendent provided briefings related to their analysis and
                                planning for current trust management workload, staff and vacancies. The efforts are
                                well-organized and support the effective allocation of resources. Lack of Internet
                                access continues to be a significant barrier to recruitment.


                                                                                 25



                           Eleventh Report to the Court
                           November 1, 2002

                              The Indian Trust HR Advisor participated in and provided a workforce
                               planning briefing and related policy and process material at a week-long
                               business process reengineering session. The primary goal of the week was to
                               generate ideal "To-Be" probate processes. The on-going comprehensive study of
                               both "As-Is" and "To-Be" trust management processes will focus and define the
                               scope of workforce analysis involved in the trust workforce planning process. The
                               trust management workforce planning process is driven by Departmental policy and
                                guidance on WFP. This process is designed to influence the important cross-cutting
                                structure of the plans for roll up into bureau and department-level plans. The Indian
                               Trust HR Advisor is arranging further workforce planning training for the trust
                               process sponsors, and will participate in future reengineering meetings.
                              A standardized individual development plan (IDP) format and process was
                                developed and distributed. IDPs are designed to generate improved integration of
                               performance management and development of trust management employees to
                                improve performance.
                           Current Status
                              DOI Offices/Bureaus plan to develop workforce plans by September 30, 2003,
                                for FY 2004-2008 and update annually. To assist trust managers in developing
                                their workforce plans, the WFP training is now available. Appropriate trust
                               management staffs are being trained or scheduled to attend training sessions
                                throughout FY 2003. Potential reorganization efforts and the business process
                               reengineering under the DOI Indian Trust Business Plan could affect the WFP skills
                                analysis and planning decisions. As the business process reengineering progresses,
                               new job requirements will be established that will require different training and skill
                                levels. It will also alter the timelines for completing reengineering and other WFP
                                actions. The Indian Trust HR Advisor will stay informed on the status of business
                               process reengineering and thereby assist in the coordination of WFP activities.
                              Offices/Bureaus are continuing development of FY 2003 staffing plans.
                                Offices/Bureaus provide information on current staff and vacancies to the HR
                                Advisor. The staffing data includes retirement forecasts and attrition. The vacancy
                                data includes costs and impediments associated with recruitment. Both of these data
                                sets are designed to provide a picture of the current workforce for program planning
                                purposes. We anticipate that staffing planning will provide valuable information for
                                trust management workforce planning after the trust management business model is
                                complete.
                              Offices/Bureaus are developing an Individual Development Plan (1DP) for each
                                employee with trust process responsibility. As trust management employees are
                                identified, standardized IDPs will be developed. The IDPs will associate future and
                                mandatory training and development with assigned duties and tasks. Therefore, the
                                business process reengineering effort may alter the final content of IDPs, delaying the

                                                                                 26



                           Eleventh Report to the Court
                           November 1, 2002

                               December 31, 2002, timeline for their completion. The Indian Trust HR Advisor will
                               stay informed on the status of business process reengineering and thereby assist in the
                               coordination of IDP development.
                              Workload analysis and workforee planning software options are being
                               considered. The Indian Trust HR Advisor, Office of Personnel Policy staff, and trust
                               managers are researching software tools and contractors' ability to accomplish
                               automated comprehensive workload analysis and assist in developing long-term
                               workforce plans. The goal is to identify a provider and a viable methodology for use
                               during business process reengineering, as appropriate, and after processes are
                               reengineered to collect and assess required competencies, staffing and training in the
                               WFP process.
                           Delays/Obstacles
                              Bureau and Office managers need a clear definition of Indian trust activities for
                               budgetary purposes and organization development. The definition would assist in
                               identifying trust management work in the WFP process. WFP will follow the
                                direction given by the Solicitor's office and senior DOI management in this regard.
                              The continuing restriction on the use of the Internet in many trust organizations
                                affects electronic collection of staffing data across all DOI Bureau lines. Lack of
                                Intemet access also continues to complicate Internet recruiting.
                              Reorganization decisions need to be made to prepare and focus on workload analysis
                                and WFP.


















                                                                                 27



                           Eleventh Report to the Court
                           November 1, 2002


                           Assurance Statement
                           I concur with the content of the information contained in the 1 lth Report to the Court in
                           reference to Workforce Planning. The information provided in this section is accurate to
                           the best of my knowledge.
                           Date:  October 31, 2002
                           Name: Signature on File
                                    Kathryn A. Bown
                                    Indian Trust HR Advisor
                           Acknowledgement Statement:
                           I have reviewed the report submitted by manager, Kathryn A. Bown, and to the best of
                           my knowledge believe the findings submitted in the report to reflect a fair representation
                           of items covered in this manager's report.
                           Date:  October 25, 2002
                           Name: Signature on File
                                    P. Lynn Scarlett
                                    Assistant Secretary-Policy, Management and Budget




















                                                                                 28



                          Eleventh Report to the Court
                          November 1, 2002

                             IV.  OFFICE OF INDIAN TRUST TRANSITION
                          Introduction
                          The Office of Indian Trust Transition (OITT) was organized in November 2001 to
                           implement the transition of trust-related functions within the Department of the Interior
                           (DOI) to a separate trust organization housed within DOl. The goal of DOI management
                           was to create a trust structure within DOI that had independence of judgment at the field
                           level and that would be responsive to high-level leadership in DOI. In addition, OITT
                           has been charged with assisting in the development of an Indian Trust Business Plan for
                           the future operations of DOI's trust activities, and oversight of several trust improvement
                          projects.
                           During this reporting period, the Director of OITT continued to attend and report at
                           Tribal Task Force (Task Force) consultation sessions chaired by Tribal leadership and
                           DOI senior officials. Reports have been provided to the Task Force on the work of the
                           Office of Historical Trust Accounting, the Indian Trust Business Plan development and
                           the "As-Is" and "To-Be" business process-reengineering project being done with the
                           support of Electronic Data Systems (EDS).
                           11 th Report to the Court
                      This Report marks the fourth report to the Court prepared under the supervision of OITT.
                           The manner in which the Report is developed and presented is similar to the previous
                           three Reports. Each of the managers responsible for trust projects or related trust activity
                           within DOI was asked to submit his or her report of activity during the past three months.
                           Once the written drafts were received, they were reviewed for completeness and
                           understanding. Interviews were then held with each of the managers to ensure accuracy
                           of statements made and verify to the best of their ability that the reports were
                           representative of the work performed during the time period reported.
                           The Indian Trust Business Plan, under the direction of OITT, has been the subject of
                           much discussion at the Task Force meetings, and senior managers within DOI involved in
                           the delivery of trust services have had weekly meetings for several months to confirm
                           that the Goals and Objectives would, if executed, accomplish DOI's trust responsibilities.
                           It is important to note also that the court has ordered DOI to present its plans for
                           historical accounting and trust operations by January 6, 2003. Although the planning
                           effort described in this Report precedes the Court order for a "Plan," it is expected that
                           some elements will be the same in both plans.
                           Reor_,anization
                           DOI officials continued meeting with the Task Force during this reporting period. Three
                           meetings were held in various locations to accommodate tribal requests. The Task Force
                           recommended that a new position of Undersecretary for Indian Affairs be created in order

                                                                                 29



                           Eleventh Report to the Court
                           November 1, 2002

                           to provide within DOI a high-level executive who would have direct line authority over
                           all agencies that are engaged in delivering trust services or managing trust operations.
                           DOI agreed with this request and, as reported in the last Report to the Court, this
                           information was provided to Congress at a hearing in June 2002.
                           Indian Trust Business Plan (Plan)
                           As further described in this Report, a major trust business planning initiative has been
                           underway for several months. Work on the Plan continues. The Task Force, the Special
                           Trustee for American Indians and other mt-related managers within DOI approved the
                           Goals and Objectives of the Plan. The tasks for completing each Objective are being
                           developed and will be incorporated into the final Plan. Each task will be defined by the
                           "As-Is" business process review now underway or will be a new "To-Be" task as
                           determined by the reengineering of an "As-Is" task. Performance standards and metrics
                           that determine successful achievement will be developed for each task. Employees
                           assigned the responsibility for completing the task will receive appropriate training and
                           supervisory support. Many of these tasks will, of necessity, not be defined until the "To-
                           Be" business processes have been determined, and the policy, procedures and regulations,
                           as required, have been written and implemented. A separate plan that addresses the
                           requirements set forth in the Court Orders of September 17, 2002, will also be developed
                           during the next reporting period.
                           OITT Initiatives This Reporting Period
                           One of the major concerns of the Tribal Task Force has been whether DOI has the
                           appropriate manpower and money to meet the requirements of DOI's trust duties. OITT
                           has worked closely with DOI's workforce planning coordinator assigned to the trust
                           project to be certain that field personnel are aware of workforce planning tools available
                           through DOI and are knowledgeable of how to use these tools. In many instances, people
                           have been hired for one job, yet are doing another. In some areas, certain functions are
                           understaffed, whereas in other areas there might appear to be too many people assigned
                           for the same function. It is important to look at the entire trust management universe
                           rather than region by region to ensure that staff is available as required to meet the
                           workload. The "As-Is" study is guiding the effort to locate these imbalances and also is
                           helping to determine where efficiencies might be gained through restructuring or
                           reengineering of the business processes. Simply having the workforce planning tools and
                           being able to use these tools effectively should help in the proper allocation of workload
                           among the various regional and agency offices. These tools are being developed and will
                           be used during the next several years as the "To-Be" business processes are implemented.
                           Traininu
                           A training coordinator's position has been identified and is being filled. Training of new
                           personnel as well as existing personnel is important to effective trust reform and on-going
                           trust business management. Such training must include individuals from the highest to

                                                                                 30



                           Eleventh Report to the Court
                           November 1, 2002

                           the lowest grade level of the organization. Efforts are underway to consolidate training
                           for trust workers within the Department. As previously reported, training in the past has
                           been on an ad-hoc basis, often at great cost and time away from the job. Performance of
                           this activity is intended to consolidate the trust training efforts within DOl. The training
                           will include job-specific training as well as certifying and credentialing of trust managers.
                           During this reporting period, the acting training coordinator was asked to proceed with
                           development of a trust manager's training program for DOI managers. It is anticipated
                           that such training will be conducted by a certified trust training organization such as the
                           Cannon Financial Institute, American Bankers Association or similar institution.
                           Although implementation of the trust business plan proposes that trust officers are to be
                           placed at agency level offices with trained trust personnel, it is important that agency
                           superintendents understand the role of these trust officers and are made aware of their
                           responsibilities. The curriculum is being developed and training is expected to begin in
                           calendar year 2003.
                           Office of Policies and Procedures
                           In order to manage trust activities effectively, it is critical that there be written policies
                           and procedures at all levels of the trust organization. As the "To-Be" business model is
                           developed for the performance of trust business processes, new procedures, handbooks,
                           desk manuals and other directives will help ensure a high level of performance.
                           The position for Director of Trust Policies, Procedures and Regulatory Affairs was
                           approved to be advertised and should be filled during the next reporting period. A
                           Director for this office is critical to fulfill the requirements of the 1994 Trust Reform Act.
                           Further staffing of the office will occur once a director of the office is in position.
                           Fractionation
                           Meaningful trust reform will continue to be a major challenge to DOI until the underlying
                           problems, one of which is fractionation of land ownership, are resolved. For various
                           reasons, ownership of Indian trust land has passed from the original allottee through
                           several generations of that allottee's descendents. Undivided ownership interests in
                           original allotments may number in the thousands for relatively small tracts of land.
                           Work on resolving fractionation of Indian lands continued during this reporting period.
                           OITT hosted a large group of regional, agency, central office, tribal and individual
                           representatives to discuss the issue and develop options for managing or eliminating the
                           problem. As a result of fractionation, DOI is required to manage thousands of accounts
                           that contain as little as one cent and many thousands more that contain less than one
                           dollar. The money expended on managing these accounts takes away resources needed to
                           manage more productive properties, and results in less income being generated from the
                           fractionated interests. No private trustee would engage in such a practice as most private
                           trusts are fee-generating businesses and there is not sufficient income from small-dollar

                                                                                 31



                           Eleventh Report to the Court
                           November 1, 2002

                           accounts to pay a fee. The Indian Land Consolidation Act Amendments of 2000 (ILCA)
                           are a step in the right direction. The impact of this Act has been reported previously. It
                           is important that DOI continue to pursue land consolidation as a remedy on a nationwide
                           basis.
                           One outgrowth of the group meeting on fractionation was the development of three
                           distinct projects. The first was the advancement of an unclaimed property act. DOI, not
                           unlike states and other federal agencies, has account owners with unknown addresses.
                           Many of these people have been on the DOI "whereabouts unknown" list for years.
                           Attempts to locate missing individuals have been exhaustive with little success. Yet
                           accounts are still maintained, some with very little money and some with substantial
                           sums in their accounts. The cost of maintaining these accounts is significant. In addition,
                           the underlying asset such as land, timber or oil and gas, continues to generate income to
                           these accounts. Many of these accounts result from the fractionated ownership of the
                           land. In the pilot work performed at the Great Lakes Agency to implement ILCA, many
                           owners of fractionated interests were not aware of their ownership until they received a
                           notice or word from a relative that BIA was offering to purchase their land. These same
                           people may have accounts but have not responded to requests for information and have
                           become "whereabouts unknown" account holders. Most states have adopted the Uniform
                           Unclaimed Property Act. A similar proposal might be helpful to resolve the whereabouts
                           unknown accounts. This idea will continue to be studied for the next congressional
                           session beginning in 2003.
                           The second proposal was the concept of a "self-managed trust." In a self-managed trust,
                           the land would remain in trust or restricted status with the federal government, but the
                           landowner would exercise full control over the property except for the right to sell. The
                           sale of the property would continue to require Secretarial approval. Many Indian owners
                           prefer to manage their own assets but have no choice as long as their land remains in trust
                           with the United States Government. Currently, if they were to take their land out of trust
                           in order to manage it themselves, the income would be taxed and the property interests
                           would be subject to state and local taxation. Such "self-managed" trust land may have
                           great appeal to many Indian owners and will continue to be discussed as a possible
                           legislative initiative.
                           The third proposal that came from the working group was the concept of partitioning. In
                           the private sector, surface fractionation is kept to a minimum, in part, through the use of
                           partitioning whereby any owner of an interest in land can partition out the other owners
                           either by dividing the land in kind or requiring the property to be sold at auction. The
                           working group agreed to continue to pursue the partitioning idea as well.
                           Purchase of fractionated interests of land will continue to be a priority of DOI using the
                           appropriations and authority available under the Indian Land Consolidation Act. The
                           pilot project of the Great Lakes Agency provides DOI with one opportunity to determine
                           how best to implement a national program. DOI will continue to study the lessons from


                                                                                 32



                           Eleventh Report to the Court
                           November 1, 2002

                           the pilot project and develop a policy for continuing work to eliminate as much
                           fractionation as possible.
                           As-Is/To-Be Business Process Modeling
                           The "As-Is" part of the business process study being done by DOI with the help of
                           Electronic Data Systems (EDS) is scheduled to be completed by the end of calendar year
                           2002. All regions will have had an opportunity to complete an assessment of how trust
                           business processes are done currently and will later have the opportunity to express ideas
                           on how these processes can be improved. A special business process review for self-
                           govemance tribes is expected to be scheduled during the next reporting period, at which
                           time the tribal trust business "As-Is" processes will be examined.
                           During the next reporting period, EDS is expected to have a first draft of its
                           benchmarking study. This study will compare the trust business "As-Is" processes of
                           DOI with those of the private sector. This should be very helpful as the "To-Be"
                           business model is put together.
                           OITT will continue to work with the other managers of DOI to develop an appropriate
                           trust management organization and to transition existing trust functions into the
                           organization. Planners and managers of the Indian Trust Business Plan expect to ensure
                           that the organization and managers responsible for trust reform and trust management
                           will have the proper guidance for going forward.
                           Assurance statement
                           I concur with the content of the information contained in this section of the 11 th
                                                                                                                              Report to
                           the Court. The information provided in this section is accurate to the best of my
                           knowledge.
                           Date:  October 29, 2002
                           Name: Signature on File
                                    Ross O. Swimmer
                                    Director, Office of Indian Trust Transition










                                                                                 33



                           Eleventh Report to the Court
                           November 1, 2002

                                    A. TRUST BUSINESS PROCESS MODELING
                           Introduction
                           A three-stage approach is being developed to standardize trust business processes. This
                           approach will: (i) identify existing business processes ("As-Is'); (ii) determine which of
                           those processes should remain or be reengineered, thereby establishing a draft business
                           model "To-Be;" and (iii) develop the universal support functions cross-cutting the
                           baseline business model. The Department of the Interior (DOI) expects that this
                           approach, in conjunction with the Indian Trust Business Plan (Plan), will achieve trust
                           reform and meet the needs of the trust beneficiaries. See attached flow chart.
                           The first step in developing standard trust business processes is to identify and document
                           existing trust business processes and how users, beneficiaries, and systems interact with
                           existing processes.
                           The core "As-Is' trust business processes are:
                              Beneficiary Services
                              Probate
                              Title
                              Appraisal
                              Cadastral Survey
                              Surface Asset Management
                              Subsurface Asset Management
                              Accounting Management (IIM, Tribal and Investments)
                           Accomplishments and Completions
                           The Trust Business Process Modeling Team (Team) continued to hold workshop
                           discussions to document the trust business processes at ten sites which include all twelve
                           Regions. These discussions included DOI and tribal staffthat perform trust functions.
                           Six site visits were held during this reporting period, bringing the total to eight. This
                           leaves two more scheduled site visits. The site visit locations and dates were:
                                    Alaska Region                                              July 15-19, 2002
                                    Northwestern Region                                      July 22-26, 2002
                                    Eastern Oklahoma & Southern Plains Region        August 12-16, 2002
                                    Rocky Mountain Region                                  August 19-23, 2002
                                    Navajo Region                                              September 9-13, 2002
                                    Southwestern Region                                      September 16-20, 2002
                           In the workshop discussions, the "As-Is" baseline for each core trust business process is
                           closely analyzed by the appropriate trust personnel. All variances from the "As-Is"


                                                                                 34



                           Eleventh Report to the Court
                           November 1, 2002

                           baseline are discussed and documented, and any resulting enhancements are added to the
                           baseline.
                           Following all site visits, the Team consolidates their work and creates a compact disk
                           (CD), which contains the variances and enhancements to the baseline for that region for
                           distribution to the participants of the workshop. The CD is mailed back to the Regional
                           Director for confirmation that all variances were captured and documented correctly.
                           During the July Tribal Task Force meeting in Portland, Oregon, an update was given and
                           questions were answered at the general meeting of the Tribal Task Force. The Tribal
                           Task Force also participated in the EDS project's Oversight Committee made up of tribal
                           representatives and DOI staff. The Oversight Committee is responsible for monitoring
                           the progress of the business process modeling project and giving advice on issues related
                           to the project. Five oversight meetings were held during this reporting period. During
                           these meetings, updates were given and questions and comments were received regarding
                           the status of the project.
                           Business process sponsors are individuals who are required to gain a thorough
                           understanding and knowledge of each business process. These business process sponsors
                           were recruited from various offices and agencies within DOI. In addition to gaining a
                           thorough knowledge of each business process, they must be capable of overseeing the
                           implementation of a "To-Be" trust business model. During the last reporting period,
                           eight process sponsors were detailed to the Office of Indian Trust Transition (OITT) to
                           begin documenting the "As-Is" trust business processes. During this reporting period,
                           eight permanent process sponsor positions were created and advertised within the Office
                           of the Special Trustee. Six individuals have been selected for permanent positions. The
                           other process sponsors are expected to be selected during the next reporting period.
                           On September 3-6, 2002, OITT held a meeting in Albuquerque to start addressing the
                           "To-Be" reengineering of the probate process. This meeting was attended by
                           approximately fifty individuals from DOI and Tribal representatives who are subject
                           matter experts in delivering probate services to beneficiaries. Subject matter experts are
                           the employees assigned to perform the probate work day-to-day. The purpose of the
                           meeting was to get individuals started on the "To-Be" reengineering process and to
                           determine the timelines, budget and resources required for the reengineering and
                           universal support functions for the trust business processes.
                           Current Status
                           OITT is currently scheduling the remaining two site visits to complete the currently
                           scheduled "As-Is" studies, as well as determining the need for any further visits to other
                           Bureaus or Agencies. The Office of Trust Funds Management, Minerals Management
                           Service, and BIA centralized offices will be scheduled for visits during the next reporting
                           period. Plans are being formalized to hold a session for the self-governance tribes


                                                                                 35



                           Eleventh Report to the Court
                           November 1, 2002

                           (compacting/contracting tribes) to gather best practices as well as document any
                           variances. These meetings are expected to be completed during the next reporting period.
                           The lack of a methodical approach to establishing a business model has been a detriment
                           to past reform efforts. The "To-Be" reengineering of the eight core trust processes will
                           be the next step after the completion of the "As-Is" task. The "To-Be" project will be a
                           multiyear task to ensure that the trust processes will be reengineered to provide consistent
                           management of trust functions. The reengineering will require that all processes move in
                           tandem to ensure the creation of a new trust business model that is integrated and fulfills
                           the Department's fiduciary obligations.
                           The reengineering of the business processes will be a multi-year effort. This effort will
                           require implementation of consistent, efficient business processes across all agencies,
                           offices and bureaus in DOI that perform trust or trust support activities. It will also
                           require, among other things, comprehensive policies, procedures, handbooks, new and
                           amended regulations, personnel, training and systems development and implementation.
                           Delays/Obstacles
                           The major obstacle that affects this project is the lack of Internet access. This impedes
                           the ability to communicate quickly and efficiently with trust staff throughout the country.
                           This has increased both the time and cost of this project.
                           Another obstacle is the sheer complexity of documenting hundreds of business process
                           activities and scheduling time with employees to limit their work interruption as much as
                           possible.
                           The "To-Be" model will also be very challenging to put into place because of the
                           business culture that exists today. Change is not readily welcomed, and in this instance
                           of trust reform, change may be required of several thousand people and the way in which
                           they do business.
                           Assurance Statement
                           I concur with the content of the information contained in the Trust Business Process
                           Modeling section of the 11 th
                                                               Report to the Court. The information provided in this
                           section is accurate to the best of my knowledge.
                           Date:  November 1, 2002
                           Name: Signature on File
                                    Jeff Lords
                                    Trust Reform Officer



                                                                                 36











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                                                                                                                                                                                              36a



                           Eleventh Report to the Court
                           November 1, 2002

                                    B.  INDIAN TRUST BUSINESS PLAN
                           Introduction
                           A Departmental Indian Trust planning team under the guidance of the Office of Indian
                           Trust Transition (OITT) has been developing the framework for a comprehensive Indian
                           Trust Business Plan (Plan). The Plan team consists of representatives from the Bureau of
                           Land Management, Minerals Management Service, Bureau of Indian Affairs, Office of
                           the Special Trustee for American Indians (OST) and Office of Indian Trust Transition
                           (OITT). Each member of the team was responsible for getting input from their respective
                           agency managers and staff. The Plan currently contains Goals and Objectives that outline
                           the high-level goals that the Department of the Interior (DOI) must achieve in performing
                           its trust responsibilities. The Plan, when completed, will articulate DOI's strategy for
                           managing and reforming its trust responsibilities and guide DOI's implementation of this
                           strategy.
                           Plan
                           The Plan begins with six major Goals. These are: 1) Beneficiary Services, 2) Ownership
                           Information, 3) Land and Natural Resource Assets, 4) Trust Fund Assets, 5) Indian Self-
                           Governance and Self-Determination, and 6) Administrative Services. The Goals and
                           Objectives of the Plan are based on statutes, regulations, and the guiding principles
                           contained in the Department Manual. The Director of OITT met and reviewed with the
                           Tribal Task Force, OST, BIA and other affected DOI agencies to gain input and
                           agreement on the Goals and Objectives. The Tribal Task Force Planning Subcommittee
                           agreed that the Goals and Objectives were consistent with its views of trust. All other
                           participants in the planning process have concurred, as well, in the Goals and Objectives.
                           The Plan will describe DOI's strategy for managing and reforming its trust
                           responsibilities, will act as a roadmap to guide implementation of trust business processes
                           and will be regularly evaluated to ensure its responsiveness to the on-going needs of
                           Interior's trust operations. The Plan may be updated and revised as required by the
                           development ofreengineered business processes and organizational requirements. As the
                           Plan is executed, it should include steps to monitor performance of employees in meeting
                           the Plan Goals. Performance measurements are also expected to include continuing
                           feedback from beneficiaries. This information will be used to refine business processes
                           and to refine the Plan, when appropriate. Therefore, the Indian Trust Business Plan will
                           be a dynamic plan that can and will be adapted to changing environments and to
                           changing needs and strategies.
                           In order to obtain input and feedback from individual Indian account holders, the Plan
                           team initiated the development of a survey to be sent to a sample of individual account
                           holders. The survey, which is tentatively scheduled for release during the first quarter of
                           calendar year 2003, will ensure that viewpoints from the Indian community are
                           considered regarding the Goals and Objectives. Input from tribal representatives and

                                                                                 37



                           Eleventh Report to the Court
                           November 1, 2002

                           individual Indian account holders throughout the process will provide an important
                           feedback mechanism to ensure that the Plan addresses the needs and concerns of the
                           beneficiaries.
                           During the next reporting period, various agencies within DOI will identify officials
                           responsible for each objective by working with a team consisting of business process
                           sponsors as described in the Section on "Trust Business Process Modeling" of this
                           Report, agency lead persons and managers. These officials, together with their teams,
                           will be directed to develop a set of specific tasks that outline a comprehensive step-by-
                           step methodology for achieving each objective. The responsible officials will also
                           coordinate with OITT to define related performance measures and create schedules for
                           completing the tasks. The specific tasks, related measures and schedules are subject to
                           review and approval by the Plan team.
                           An integral part of the Plan is the development of standardized trust business processes.
                           DOI is reviewing current business processes to determine those that need to be
                           reengineered and/or integrated with other processes. The results, when integrated into the
                           Plan, will help achieve meaningful trust reform and improve the overall management of
                           the trust program. Building on the work of its consultant, Electronic Data Systems, an
                           "As-Is" business process model is being developed. The work is expected to be
                           completed during the last quarter of this calendar year.
                           The next step is to construct a "To-Be" model, which will begin to be developed in
                           calendar years 2003-2004. This model will take into consideration private trust business
                           practices as well as the earlier EDS Roadmap recommendations and lessons learned
                           during the "As-Is" studies.
                           Assurance Statement
                           I concur with the content of the information contained in Indian Trust Business Plan
                           section of the 11 th
                                                  Report to the Court. The information provided in this section is
                           accurate to the best of my knowledge.
                           Date:  October 29, 2002
                           Name: Signature on File
                                    Ross O. Swimmer
                                    Director, Office of Indian Trust Transition







                                                                                 38



                           Eleventh Report to the Court
                           November 1, 2002

                                    C. PROBATE
                           Introduction
                           Probate is one of the three trust improvement projects consolidated in the Office of Indian
                           Trust Transition (OITT) on November 21,2001. Conducting and completing the probate
                           of individual Indian trust assets requires the cooperative efforts of the Bureau of Indian
                           Affairs (BIA), the Office of Hearings and Appeals (OHA) and the Office of Trust Funds
                           Management (OTFM). In addition to bringing the probate caseload current so that the
                           overall management of trust assets is based on correct ownership information, the focus
                           of the probate project is on creating a prompt, efficient, beneficiary-oriented and seamless
                           process.
                           Accomplishments and Completions
                           Probate Handbook. In this reporting period, DOI engaged the services of a contractor to
                           revise and expand the existing draft probate handbook to detail the responsibilities and
                           procedures in all phases of the probate process. The contractor is uniquely qualified to
                           describe the probate process because it has already conducted risk management analyses
                           of the probate process. A complete draft of the revised Probate Handbook "As-Is" is due
                           for distribution, review and comment by the end of December 2002. During the first
                           calendar quarter of 2003, the Handbook is scheduled to be put into final form and
                           proposed revisions resulting from the reengineering process are scheduled to be
                           delivered. The proposed revisions will be in the form of replacement pages that may be
                           disseminated based on an event occurring, e.g., a change in policy.
                           Certified Death Certificates. The Department has a need for prompt and accurate
                           verification of death for Indian trust property owners in order to conduct a probate of
                           their trust assets. Given previous methods and resources, it is sometimes not possible for
                           a local agency to obtain a certified death certificate. Partial reports from BIA agencies
                           identified more than 1600 backlogged probate cases being prepared that cannot be
                           submitted because they lack certified death certificates. On September 30, 2002, the
                           Department engaged and began using the services of VitalChek Network, Inc., a
                           company that specializes in obtaining certified vital records for third parties and that has
                           contractual relations with all states except Louisiana, to obtain death certificates.
                           Case Preparation. Case preparation is the gathering of information and documents to
                           enable the submission of a probate package to a deciding official. Through agency-level
                           Site Assessments, agencies that have the highest numbers of probate cases involving
                           interests in trust land were identified in each region. Based on those assessments, the
                           contractor was directed to focus its efforts on case preparation in the gathering of
                           documents to enable thc submission of a probate package to a hearing official, beginning
                           with the agencies that have the highest caseloads.



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                           Eleventh Report to the Court
                           November 1, 2002

                           Probate Process Reen_ineering. Building on the experience and information developed
                           and documented by the trust business process modeling commenced by OITT in April of
                           this year, reengineering of the probate trust process business model began in September.
                           A trust business process "To-Be" modeling workshop was held September 3-6, 2002, in
                           Albuquerque, NM, to develop a prompt, efficient, beneficiary-oriented and seamless
                           process. A contractor facilitated the workshop using mobile workstations and
                           collaboration software to foster an open dialog and record the workshop proceedings.
                           Participants included subject matter experts from all phases and levels of the probate
                           process, including Tribal probate service providers, and from the universal support
                           functions, including risk management, records management, policies and procedures,
                           workforce planning, training, automated systems, and technical assistance, together with
                           representatives from the Tribal Task Force.
                           There was active participation in the workshop. More than one thousand comments were
                           entered into the collaboration software, which is considered to be quite high considering
                           the amount of time spent in breakout groups. Nevertheless, the contractor reported that
                           most of the process improvement comments were incremental and mirrored comments
                           already collected in the field workshops facilitated by another contractor that are being
                           conducted to document regional variances from the "As-Is" trust business process
                           baseline. These comments may validate the information gathered at the field workshop
                           meetings but do not provide the solid basis for reengineering the probate process that was
                           hoped for.
                           Consistent with the contractor's recommendations, the focus of this effort to revise the
                           probate process will be narrowed and made more explicit to obtain a greater number of
                           specific visions of an overall revised probate process, which will be reviewed and
                           evaluated by a small group of subject matter experts to develop a "straw man" of the "To-
                           Be" trust business model. This "straw man," and perhaps one or two altematives, will be
                           presented to the larger group for development into an initial "To-Be" trust business
                           model. It is anticipated that the "To-Be" trust business model will be completed in the
                           first calendar quarter of 2003. The time required to apply the universal support functions
                           which are Risk Assessment, Automated Systems Requirements, Records, Internal
                           Controls/Fiduciary Security, Policies and Procedures, Workforce Planning, Training, and
                           System User Technical Assistance Center Requirements to the "To-Be" trust business
                           model will also be determined.
                           Regional meetings are expected to be held in the future to discuss the initial "To-Be"
                           trust business model and solicit comments in order to refine the model.
                           Probate Proiect Manager. A new manager to oversee the probate project was appointed
                           effective July 14, 2002.





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                           Eleventh Report to the Court
                           November 1, 2002

                           Current Status
                           Case Location and Status (CLS) Database. In response to the need for accurate
                           information about probate caseloads, an interim tracking system not requiring internet
                           access is being developed to collect accurate on-site case counts and information across
                           all probate processes so that appropriate resources can be provided to meet localized
                           backlogs. In June, work was nearing completion on incorporating robust security
                           measures and correcting the operating flaws that were disclosed by the CLS Beta test
                           conducted at the end of May.
                           After further revision, the CLS database, which was developed by a contractor, was then
                           subjected to rigorous functional testing and volume testing from July 15, 2002, to July
                           31, 2002. The August 1, 2002, test results noted that numerous additional defects were
                           disclosed and fixed, but at least 10 known major defects remained at the end of the
                           testing. A determination was made that it would require less time and effort and provide
                           a quicker, more responsive program to rebuild the database program rather than to
                           troubleshoot the existing design. The preliminary training of contractors conducted in
                           May concerning what data to gather is not affected by the redesign.
                           After rebuilding the program, additional input from representatives of each phase of the
                           probate process was obtained through a meeting in Albuquerque on August 22, 2002.
                           Numerous suggestions were made, and the balance of the reporting period has been
                           devoted to incorporating those suggestions and preparing the program for final approval
                           and deployment, which is expected to take place during the next reporting period.
                           Social Security Administration's (SSA) e-Vitals Proiect. The SSA e-Vitals project
                           sponsored by the National Association for Public Health Statistics and Information
                           Systems (NAPHSIS) is now in its pilot phase. Based on discussions with NAPHSIS, it
                           appears that this project is designed only to give a "match or no-match" response to data
                           supplied by SSA in an attempt to confirm a death. Consideration is being given to
                           whether DOI could benefit from the project if certain probate regulations were changed.
                           In many states, NAPHSIS is also sponsoring an effort to provide reports of death
                           electronically to state vital records offices. Contacts were made with the President and
                           Executive Director of NAPHSIS and discussions were begun to clarify the Department's
                           needs and to explore whether the Department might also be notified when the death of a
                           Native American or Alaska Native is reported. A representative of OST plans to attend
                           the next regional meeting of NAPHSIS to continue these discussions.
                           Number of Cases Processed and Decided - July through September 2002. During this
                           reporting period, BIA and OHA deciding officials received 728 cases and issued
                           decisions in 941 cases. The Office of Trust Funds Management (OTFM) distributed and
                           closed 992 estate accounts representing 961 estates. The Trust Funds Accounting System
                           (TFAS), as of the end of September 2002, contains 25,404 open estate accounts. Of
                           these, 13,481 are classified as official deaths, where OTFM has confirmed the death but

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                           Eleventh Report to the Court
                           November 1, 2002

                           the case has not been recorded as sent to probate. Another 7,617 of these accounts are
                           classified as unofficial deaths, where OTFM has received some indication of death which
                           has not yet been confirmed. The remainder of these accounts are in the probate process
                           or have been decided but the assets have not yet been distributed. These numbers are the
                           best information available and are subject to verification. An accurate statement of the
                           probate workload cannot be made until a reconciliation is made with the CLS Database
                           noted above. There could be significant changes in the figures based on the on-site hand
                           count verification entered into the CLS database.
                           Case Preparation - Probate File Processing (involving land interests). The contractor's
                           pilot project to complete tasks related to the preparation of probate cases involving
                           interests in trust land continued in the BIA's Western Region. A total of forty-one (41)
                           backlogged land cases were approved by the BIA during the quarter. Another thirty-two
                           (32) backlogged land cases are pending BIA approval.
                           Case Preparation - Probate Summary File Processing (money only). Contractor efforts to
                           complete case preparation - summary distribution tasks, i.e., no land ownership,
                           continued in the BIA's Western, Great Plains, Midwest, Northwest, and Rocky Mountain
                           Regions. A total of fifty-four (54) backlogged Summary Distribution cases were
                           approved by the BIA during the quarter. Another forty-three (43) backlogged Summary
                           Distribution cases are pending BIA approval.
                           Case Preparation - Priorities.  In addition to focusing on the agencies with the highest
                           caseloads, the top 501 open estate accounts, based on the amount of money in the
                           account, were identified. These accounts represent only 3.4% of the estate accounts, but
                           total $31 million or 65% of the funds. The BIA and OHA are giving priority to probating
                           these estates. OHA reported this quarter that it identified 152 of these cases as having
                           been on its inventory of cases. As of August 9, 2002, 116 of these had been decided,
                           leaving a balance of 36 cases pending in OHA. Some of those cases decided may be
                           administratively appealed and reappear on OHA's docket.
                           Posting and Recording. Posting and Recording Tasks continued during the quarter at the
                           BIA regional and agency locations including the Great Plains Region Land Titles and
                           Records Office (LTRO) in Aberdeen, the Northwest Region LTRO in Portland, the
                           Pacific Region LTRO in Sacramento, and the Southern Plains Region LTRO in
                           Anadarko. No cases were completed by the contractor because, as noted below, the
                           contractor did not have access to the Land Records Information System (LRIS) and the
                           Cognicase (TAAMS) current title module. Posting and recording activities included ID
                           Verification, microfiche research, Standard Operating Procedures (SOP) development,
                           modification order drafting, the posting of land tracts to records maintained manually,
                           and the conducting of agency-level Site Assessments.
                           Complete processing of Probate actions and title recordation were prevented by the
                           unavailability of both the Land Records Information System (LRIS) and the Cognicase
                           current title module since December 2001. The systems became available recently and,

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                           Eleventh Report to the Court
                           November 1, 2002

                           as staff has become re-certified for access to the systems, accumulated backlogs have
                           been addressed. For example, the Rocky Mountain Region LTRO reported that it had no
                           probate decisions pending recording as of December 1, 2001. By June 30, 2002, the
                           Rocky Mountain Region LTRO had a backlog of 585 probate decisions awaiting
                           recordation. As of September 30, 2002, its backlog of probate decisions awaiting
                           recordation was reduced to 164.  Meanwhile, the number of requests for probate
                           inventories (BIAINVs) pending at the Rocky Mountain Region LTRO has increased to
                           1194.  Probate inventories are needed to complete the preparation of a probate case.
                           Requests for inventories were allowed to accumulate while resources were devoted to
                           recording probate decisions because current data is essential to an accurate inventory and
                           probate decisions frequently affect the contents of future probate inventories.
                           Babbitt v. Youpee. Youpee tasks at the LTRO level were limited to ID Verification
                           activities and the electronic entry of all Great Plains Youpee escheat cases by reservation
                           and agency. Agency level ID verification was completed for the Standing Rock,
                           Winnebago, Fort Berthold, Cheyenne River, Lower Brule, Crow Creek, Fort Totten,
                           Leech Lake and Fond du Lac reservations. Databases were initiated to track Youpee ID
                           verifications i n the Midwest Region.
                           Delays/Obstacles
                           The lack of access to the internet, legacy BIA systems, and electronic mail systems
                           necessitated by the December 5,2001, court order and subsequent "Disconnect Order"
                           issued by the Assistant Secretary-Indian Affairs, continued to significantly affect the
                           ability to process and complete probate backlogs across all probate processes. As the
                           automated Probate Tracking System (PTS) is an Intemet-based system and therefore not
                           currently available, critical documents and processes such as the OHA-7 forms, the
                           assignment of probate docket numbers, case counting and reporting are now being done
                           manually.
                           Assurance Statement
                           I concur with the content of the information contained in this section of the 11 th
                                                                                                                              Report to
                           the Court. The information provided in this section is accurate to the best of my
                           knowledge.
                           Date:  November 1,2002
                           Name: Signature on File
                                    Marinus Heymering Jr.
                                    Supervisory Trust Reform Specialist





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                           Eleventh Report to the Court
                           November 1, 2002

                                    D. INDIAN TRUST SYSTEMS
                           Introduction
                           System design is no longer centered on one all-encompassing asset management system.
                           What is required is a series of software applications focusing on each aspect of the trust
                           business. These software applications do not need to come from a single company; in
                           fact, it is preferable to get the applications from companies which specialize in the field
                           which the software is to be used. The goal of Indian Trust Systems is to integrate the
                           separate applications into compressive software architecture which share necessary
                           information across all applications to accomplish trust reform. Reform is focused on
                           defining trust business processes to meet beneficiary needs and fiduciary requirements.
                           This design focuses on developing fundamental trust business processes and then
                           developing system requirements and architecture for these business processes. These
                           requirements and architectures will determine whether existing systems and technology
                           should be used, integrated, or replaced.
                           Accomplishments and Completions
                           Trust Systems is examining each of the functional process modules required to execute
                           the trust business. The aim is to incorporate these processes into an integrated Trust
                           Systems framework architecture which will fully comply with all requirements and
                           standards enumerated in the Department of the Interior (DOI) draft Enterprise
                           Architecture (EA) released May 15, 2002.
                           In researching software systems which can be integrated, input from companies using
                           trust-related commercial software applications is being sought. As requirements for each
                           of the functional process modules becomes known, an evaluation of the software
                           available from commercial companies will be made in order to determine applications
                           that are congruent with the trust reform requirements. This will minimize the need for
                           costly custom built applications. To replace TAAMS, a Request for Information (RFI)
                           was published in "Federal Business Opportunities," (FEDBIZOPS) in July 2002 to solicit
                           information on commercial software applications that could possibly meet the functional
                           business requirements of the Indian trust business processes. Copies of the RFI were
                           provided to trust-related companies that usually do not solicit business with the
                           government and may not be users of the FEDBIZOPS. Seventeen responses were
                           received to the RFI. Examination and review of the RFI responses have been prioritized
                           based on the trust business process reengineering schedule, with probate and title
                           functions being evaluated first. Additionally, title systems were reviewed outside the RFI
                           process, i.e., Stewart Title, First American Title and three county title systems.
                           The Cognicase Current Land Title module was restored to operational status in August
                           2002. A nine-month Interim Authorization To Operate was approved. Updates to the
                           System Security Plan, Security Legal Requirements Analysis, Risk Management Plan,
                           and Security Plan of Action were initiated.

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                           Eleventh Report to the Court
                           November 1, 2002


                           Title subject matter experts from the Bureau of Indian Affairs (BIA) met with Trust
                           Systems and Projects staff and Information Services Corporation (ISC) personnel at the
                           ISC facility in Regina, Saskatchewan, Canada from September 23, 2002, through
                           September 25, 2002, to review the ISC-developed Land Titles Automated Network
                           Delivery (LAND) system. The LAND system provides quick, reliable, and secure land
                           titles services over the Internet to Provincial Government offices, business and industry,
                           and individual landholders in Saskatchewan province. The system was identified as a
                           potential Trust title system through the RFI process.  The Saskatchewan government has
                           taken a centralized approach to the maintenance of land title and relies heavily upon the
                           Intemet to ensure success of that centralization. Additionally, through legislation, the
                           Saskatchewan government was able to resolve many of the issues related to recording life
                           estates and using metes and bounds to describe property. Several processes within its
                           system could be adopted to improve current procedures used to maintain the BIA Indian
                           land title system. The filing system, which incorporates indexed record containers and
                           computer bar-coding, appears much more efficient than any methods used in county court
                           houses or BIA Land Title Record Offices. In addition, use of scanned documents and
                           geographic information mapping was exceptional. The fundamental approach the
                           Saskatchewan government employs in the maintenance of land title, the Torrens title
                           system, is very different from the "registration" or "recording of evidence" methods that
                           have been employed by the United States and therefore is not directly applicable to the
                           BIA land title system requirements.
                           An additional tracking system that could possibly support the Probate process was also
                           identified from the RFI responses. This product will be examined during the next
                           reporting period.
                           Current Status
                           Development of a "As-To" business model based on review and documentation of
                           current business processes continues. The identification of the Critical Data Elements
                           (CDE) continues. CDEs are defined as those trust data elements which are needed to
                           provide: (1) timely and accurate payments to beneficiaries; (2) timely and accurate
                           transactions listings and asset inventories to beneficiaries; and (3) effective management
                           of the assets. Examples of CDEs are name, account number, and tract number. A draft
                           concept of operations for the Data Quality initiative for collecting, validating, and
                           maintaining the CDE is being reviewed. Data cleanup will be prioritized by agency in
                           accordance with the amount of recurring IIM income. A contractor will review the hard-
                           copy land title documentation and correct the automated data files to reflect the
                           information contained on the hard-copy documentation. After a quality check verifies the
                           accuracy of the automated file update, the validated data will be transferred to a
                           controlled repository for safe guarding and protection from corruption. Updates to
                           validated information will follow a similar quality control review change process.



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                           Eleventh Report to the Court
                           November 1, 2002

                           The computer hardware and software to build a data warehouse to store validated CDE
                           have been ordered. Data warehousing allows for the collection of data elements extracted
                           from dissimilar data sources and placed in a common repository. The collection of CDE
                           is vital to the process of producing accurate and timely trust real property asset statements
                           to the beneficiaries.
                           Development of a database to capture the probate case workload at BIA agencies and
                           regional offices and OHA offices is proceeding. The database will capture the case
                           number, location and current status of each outstanding probate.
                           Delays/Obstacles
                           Research into new information system solutions and components was hampered by lack
                           of Intemet connectivity.
                           Assurance Statement
                           I concur with the content of the information contained in The Indian Trust System section
                           of the 1 lth Report to the Court. The information provided in this section is accurate to
                           the best of my knowledge.
                           Date:  October 29, 2002
                           Name: Signature on File
                                    William L. Becker
                                    Supervisory IT Specialist


















                                                                                 46



                            Eleventh Report to the Court
                            November 1, 2002

                                     E.  TRUST DATA QUALITY ANALYSIS
                            Introduction
                           The success of trust reform depends foremost on the accuracy of data upon which trust
                           land is maintained, trust land ownership is determined, trust income is distributed and
                           trust accounts managed. This trust reform task is to standardize trust data elements and
                           implement quality controls, which will ensure trust data is accurate, current and secure.
                           Accomplishments and Completions
                           The Trust Systems and Projects (TS&P) office provided the Acting Deputy
                           Commissioner of Indian Affairs (DCIA) a draft list of Critical Data Elements (CDEs) for
                           review and comment. CDEs are defined as those trust data elements which are needed to
                           provide: (1) timely and accurate payments to beneficiaries; (2) timely and accurate
                           transaction listings and asset inventories to beneficiaries; and (3) effective management
                           of the assets. Examples of CDE's are name, account number, and tract number. The
                           draft list of CDEs, provided to the DCIA, was identified by a contractor after its
                           extensive review of available Bureau of Indian Affairs (BIA), Office of Trust Funds
                           Management (OTFM) and Minerals Management Service (MMS) documentation,
                           meetings with Department of the Interior (DOI) leadership and interviews with personnel
                           from selected BIA Regions.
                           After the BIA comments regarding CDE inclusion or exclusion are reviewed and
                           considered, the CDE list will be provided to those DOI bureaus and offices with trust
                           asset management responsibilities for their review and comment. Once all comments
                           have been considered, the CDE list will be finalized and the TS&P office will begin
                           implementation of the Data Quality and Integrity (DQ&I) Model Agency Project.
                           DQ&I Model Agency Project
                           The DQ&I Model Agency Project will identify, verify for accuracy, correct, if necessary,
                           and safeguard CDEs, in order to ensure the accurate status and reporting of trust real
                           property assets to the trust beneficiaries. Upon their verification of accuracy and/or
                           correction, CDEs will be stored, in a standard data format, in a secure electronic data
                           repository environment where stringent quality controls would be implemented to ensure
                           accuracy to CDE updates.
                           The Concho, Anadarko, and Eastern Navajo Agencies were selected as DQ&I Model
                           Agency Project sites. These BIA agencies were selected because they are three of the top
                           four agencies, for having the highest recurring amounts of trust income being deposited
                           into Individual Indian Monies (IIM) accounts. The amount of revenue from these three
                           agencies is approximately 23% of the $119 million deposited annually into all IIM
                           accounts.


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                           Eleventh Report to the Court
                           November 1, 2002

                           The top ten BIA Agencies have approximately 59% of the total recurring trust income
                           deposited into IIM accounts. Upon full implementation at Concho, Anadarko, and
                           Eastern lqavajo Agencies, the DQ&I Model Agency Project is scheduled to be
                           implemented at the remaining top ten agencies, prior to conducting a nation-wide
                           deployment.
                           A site visit to the Eastern Navajo Agency is scheduled to be conducted October 8-9,
                           2002. Site visits to the Concho and Anadarko Agencies are scheduled to be conducted
                           October 22-25, 2002.
                           Data Warehousing
                           Data warehousing allows for the collection of data elements extracted from dissimilar
                           data sources. In the context of the DQ&I Model Agency Project, a data warehouse is
                           scheduled to be developed and used to extract periodically CDEs originating from the
                           systems used by the various DOI bureaus and offices (primarily the BIA, OTFM, and
                           MMS). Once extracted, common relationships among CDEs will be identified and CDE
                           queries and CDE ad hoc reporting may be conducted. These capabilities are vital to the
                           process of verifying for accuracy and/or correcting CDEs, so that accurate and timely
                           trust transaction and asset statements can be provided to the beneficiaries.
                           Contractor Efforts
                           Pre-deployment data cleanup tasks consist of researching and correcting critical key
                           fields, reducing BIA backlogs, acquiring documents and encoding directly into the
                           Cognicase current land title product and/or the Land Records Information System (LRIS).
                           Data cleanup activity has been impeded by the Federal Court Temporary Restraining
                           Order (TRO), which went into effect on December 5, 2001, and the subsequent Consent
                           Order of December 17, 2001. However, access to the majority of the legacy systems has
                           been restored. The contractor's encoding for the Alaska Region was not available due to
                           a telecommunication problem resulting from the contractor's move to a new facility. The
                           contractor's data cleanup efforts and accomplishments were in the following areas:
                                o  Title Examination (Chain Sheet Preparation);
                                o   Chain Sheet Review;
                                o   Reviewing and Acquiring Legal Land Documents;
                                o   Preparing Documents for Encoding into the LRIS;
                                o  Multiple Owner Identification (MOLD) Tasks
                                o  Document (land title/encumbrance to land title) Processing Tasks;
                                o  Non-Enrolled Identification Number Tasks;
                                o   Current Document Type Modifier Tasks;
                                o   Document Chaining Tasks at the Flathead Agency;
                                o  Realty/Title Land Tract Match Tasks;
                                o  Tract M990 Title Ownership Chaining Task at the Fort Peck Agency;

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                           Eleventh Report to the Court
                           November 1, 2002

                                o  REM/Land Ownership ID/TFAS Account Comparison Match Task;
                                o  Document Recording and Microfilm Task at the Eastern Region;
                                o   As assigned by BIA, Drafting and Encoding Administrative Probate Modification
                                    Tasks;
                                o   LRIS Death Notifications Encoding Task at the Southwest Region.
                           The contractor has also assisted the BIA in processing the backlog caused from the
                           systems shutdown, resulting from the Federal Court Orders.
                           Data Cleanup Delays/Obstacles
                           During the 1 lth reporting period, the following impacted the contractor's data cleanup
                           efforts:
                                o   Systems and/or network unavailability;
                                o   Unavailability of BIA personnel to review and approve task cases, prepared by
                                     the contractor;
                                o  Unavailability of BIA agency personnel to perform Enrollment Identification
                                     verifications;
                                o  Navajo Enrollment Office access limited to one day per week;
                                o  Being limited to ten LRIS automated reports per day at the Rocky Mountain
                                     Regional Office due to time required to recover from the automated systems
                                     shutdown;
                                o   Remaining without access to the Cognicase current land title product for the
                                     Alaska Region, due to a telecommunication problem resulting from the
                                     contractor's move to a new facility.
                           Assurance Statement
                           I concur with the content of the information contained in the Trust Data Quality Analysis
                           section of the 1 lth Report to the Court. The information provided in this section is
                           accurate to the best of my knowledge.
                           Date:  October 30, 2002
                           Name: Signature on File
                                     John E. White
                                     Supervisory Trust Reform Specialist







                                                                                  49



                           Eleventh Report to the Court
                         November 1, 2002

                                 F.  OFFICE OF HISTORICAL TRUST ACCOUNTING
                         Introduction
                         On July 10,2001, the Office of Historical Trust Accounting (OHTA) was established by
                         Secretarial Order No. 3231 (Order). The purpose of OHTA is to plan, organize, direct
                         and execute the historical accounting of Individual Indian Money (IIM) accounts.
                         On June 27, 2002, Secretary Norton amended Secretarial Order No. 3231 by issuing
                         Amendment No. 1. The Amendment extended the expiration date of the Order from July
                         1, 2002, to July 1,2004.  The Secretary further modified the Order by directing OHTA
                         to plan, organize, direct and execute the historical accounting of IIM accounts and Tribal
                         Trust accounts (emphasis added). On July 31, 2002, Secretary Norton issued
                         Amendment No. 2 which revised Sec. 3 of the Secretarial Order No. 3231 by adding "and
                         Tribal Trust accounts."
                         Accomplishments and Completions
                         Report to Congress on the Historical Accounting of Individual Indian Money
                         Accounts
                         As stated in Status Report to the Court Number Ten, OHTA issued its Report to Congress
                         on the Historical Accounting of Individual Indian Money Accounts (Report) on July 2,
                         2002. OHTA provided copies of the Report to Members of the U. S. House of
                         Representatives and U.S. Senate Interior Appropriations Subcommittees. These include
                         (1) Subcommittee on Interior and Related Agencies, Committee on Appropriations,
                         House of Representatives and (2) Subcommittee on Interior and Related Agencies,
                         Committee on Appropriations, U.S. Senate respectively.
                         OHTA also provided copies of the Report to Members of the House of Representatives
                         and Senate oversight committees for DOI. These include (1) the Chairman and Ranking
                         Member of the Committee on Resources, U.S. House of Representatives, (2) Co-
                         Chairmen, Congressional Native American Caucus, U. S. House of Representatives, and
                         (3) the Chairman and Ranking Member, Committee on Indian Affairs, U.S. Senate. The
                         Department of Justice (Justice) provided a copy of the Report to the Court.
                         On July 9, 2002, OHTA's Executive Director and Deputy Director provided a briefing
                         for Staff of the Senate Interior Appropriations Subcommittee. On August 1, 2002,
                         another briefing was provided to a Staff member of the House Appropriations Committee
                         by OHTA's Executive Director and Deputy Director.
                         During this reporting period, OHTA provided additional briefings to personnel of the
                         Office of Management and Budget and to senior DOI personnel regarding various aspects
                         of the Report.


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                           Eleventh Report to the Court
                           November 1, 2002

                           As stated in the Status Report to the Court Number Ten, Interior prepared the Report
                           pursuant to Congressional direction contained in DOI's appropriation for FY 2002. The
                           Report provides an estimate for the total cost of the historical accounting at about $2.4
                           billion over an assumed 1 O-year period. To accomplish this accounting, OHTA proposed
                           to divide the historical accounting into three distinct phases of work based on the
                           attributes of the Individual Indian Money (IIM) account. However, OHTA notes some
                           obstacles to the proposed historical accounting plan. These obstacles are described on
                           pages 12 and 13 of the Report.
                           Further details about OHTA's approach, methods and additional information for the
                           proposed historical accounting can be found in various sections of the Report. The
                           complete Report is available on the Intemet at ,z_,w.doi.eov/ohta or by request to OHTA
                           at (202) 327-5300.
                           Judgment and Per Capita IIM Accounts
                           As reported in the Status Report to the Court Number Ten, OHTA hired Chavarria,
                           Dunne & Lamey LLC (CD&L) to reconcile a number of judgment and per capita IIM
                           accounts. The work requested was a continuation of procedures CD&L performed earlier
                           in connection with its pilot project of ten groups of judgment accounts for the Office of
                           the Special Trustee's Office of Trust Risk Management (OTRM).
                           CD&L continues to perform accounting procedures on the judgment and per capita IIM
                           accounts scheduled for completion with interim deliverables through mid-fiscal year
                           2003.
                           Judgment IIM Accounts
                           The following table is a summary of deliverables completed by CD&L and cumulative
                           results to date for judgment IIM accounts.















                                                                                 51



                           Eleventh Report to the Court
                           November 1, 2002

                           Table 1. Judgment IIM Accounts Reconciled Through December 31, 2000
                             Ii ! _'_ I'-c:--_-_ ._'i ,::::::::             .... _ ) Ir[ Illilg--_ tl_J I mi_--                _,ttl'_l_iii............... t_,J.._'r _ ---------------



                                    1           I October 31, 2001      See Note 1        See Note 1      See Note I      See Note 1
                                         I
                                     Below             Below         Below          Below
                            2            June 7,2002-            7,903        $   22,764,799         7,903       $22,764,799
                                          Update of
                                          October 31,2001
                                          June 7, 2002-         3,706       $    6,937,813         3,706       $ 6,937,813
                                          Additional
                                          Judgments
                             3            July 31, 2002               662       $    7,990,801      In Progress   In Progress
                             4            August 30, 2002         1,055        $       552,681      In Progress    In Progress
                             5            October 2, 2002           909       $    2,698,099      In Progress   In Progress
                                          Cumulative            14_235       $   40_944_193        1L609      $29_702_612
                                      Note 1: CD&L's first report dated October 31, 2001, reconciled
                                      accounts through September 30, 2000, as specified in its contract with
                                      OTRM. The second report dated June 7, 2002, updated these results
                                      through December 31, 2000. The update was due to a change in the
                                      cut-off date from September to December 31, 2000.
                           Historical Statements of Account for an initial sample of 560 reconciled judgment IIM
                           accounts were prepared for mailing to account holders (included in the June 7, 2002,
                           CD&L Report Number 2). The information provided to these IIM account holders
                           includes (1) a Historical Statement of Account covering the period from the initial
                           deposit of the Tribal judgment distribution into the IIM account and interest through
                           December 31,2000, (2) a letter describing the historical accounting work performed,
                           including a general description of the account history, (3) a brochure containing
                           instructional material with answers to anticipated questions, and (4) a description of an
                           appeal process to the Interior Board of Indian Appeals. These 560 accounts are the first
                           in a series of mailings scheduled throughout the performance of the historical accounting
                           work in order to communicate results to the IIM account holders in a timely manner.





                                                                                 52



                           Eleventh Report to the Court
                           November 1, 2002

                           Quality Assurance
                           As reported in the Status Reports to the Court Numbers Nine and Ten, Grant Thornton
                           LLP (Grant Thornton) has been engaged to perform a quality control check of CD&L's
                           work on judgment IIM accounts. As reported above, reports issued to date by Grant
                           Thornton represent quality control checks on 11,609 judgment IIM accounts.
                           OHTA expects Grant Thornton to complete quality control reports on reconciled IIM
                           accounts covering 1,717 judgment IIM accounts (1,055 + 662) by late November 2002,
                           and 909 accounts by mid-December 2002.
                           Grant Thornton also conducted a quality control check for the mailing described above of
                           the initial 560 judgment IIM accounts and is currently drafting its report on this activity.
                           Per Capita IIM Accounts
                           Similar to judgment accounts, per capita accounts have limited activity because their
                           primary purpose is to receive per capita payments. These accounts are also a focus of the
                           historical accounting work by CD&L. The following table is a summary of work
                           completed by CD&L and cumulative results to date for per capita IIM accounts.
                           Table 2.  Per Capita Transactions Reviewed
                          _q },l,;_ _{ _'_ _                  m_m_m_lll{m_   _     ._r_r_'m_nl_ _ Jm _-------,-_,,_-


                            1            October 31, 2001       23,226       $ 51,645,526    In Progress          In Progress
                           2           June 7, 2002               -            $     -            Not Applicable    Not Applicable
                           3           July 31, 2002            14,096       $   5,476,310    In Progress          In Progress
                           4           August 31, 2002        16,306       $   8,407,932    In Progress          In Progress
                           5           October 2, 2002        35,151       $  12,982,059    In Progress          In Progress
                                        Cumulative             88,779       $ 78,511,827     0                       0
                           Disbursement Testing Of Judgment IIM Accounts with Disbursements
                           CD&L noted that some judgment IIM accounts for which it performed historical
                           accounting procedures reflect disbursements from the account. These accounts with
                           disbursements were excluded from the 7,903 reconciled accounts for further work.


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                           Eleventh Report to the Court
                           November 1, 2002

                           A stratified random sample of 150 disbursements from approximately 8,500
                           disbursements was designed by the OHTA contractor, National Opinion Research Center
                           of the University of Chicago (NORC), to develop reconciliation procedures for specific
                           judgment IIM accounts. Copies of the checks for the selected sample were then
                           requested from the Department of the Treasury (Treasury). Treasury was able to provide
                           copies of 122 of the 150 disbursements. Alternative documentation will be examined for
                           the 28 disbursements not verified by copies of the checks. CD&L completed this work
                           on August 31, 2002.
                           OHTA's Office Move
                           Effective September 14, 2002, OHTA moved its offices to 1801 Pennsylvania Avenue,
                           NW, Suite 400, Washington, DC 20006. The new telephone number is (202) 327-5300.
                           Consultants
                           During this reporting period, OHTA hired an additional consultant, Government &
                           Business Solutions Inc. (G&B), to advise on information technology (IT) systems,
                           security and trust architecture issues, as well as to perform independent verification and
                           validation of IT systems. G&B also performs similar services for other DOI components.
                           OHTA is also actively engaged in acquiring the services of a contractor with experience
                           in document handling, imaging and scanning services for OHTA.
                           Current Status of Oneoin_ Proiects
                           As reported in the Status Report to the Court Number Ten, OHTA is conducting various
                           projects to assist it in completing the historical accounting. The following summarizes
                           current projects.
                           BIA Eastern Region
                           The Eastern Region has 37 IIM land-based accounts, an ideal size to learn about the
                           difficulties that will be encountered when accounting for larger numbers of accounts.
                           Once this project is completed, it will substantially complete the historical accounting for
                           one of the 12 BIA Regions.
                           Deloitte & Touche LLP (D&T), a public accounting firm engaged by OHTA, is now
                           conducting a historical accounting for the 37 IIM land-based accounts in the Eastern
                           Region. D&T's work focuses on land-based accounts on direction from OHTA.
                           Using the IRMS and TFAS files, D&T has identified 1,700 transactions for 37 IIM
                           accounts. D&T also received a file from the Office of Special Trustee's Office of Trust
                           Funds Management (OTFM) containing balances for all of the Eastern Region IIM


                                                                                 54



                           Eleventh Report to the Court
                           November 1, 2002

                           accounts. D&T is performing additional analysis of the IRMS and TFAS data to
                           determine the source of funds for all Eastern Region IIM land-based IIM accounts.
                           Most of the Eastern Region's 2,900 accounts are related to judgment awards, and this
                           historical accounting work will be performed by CD&L. CD&L has completed historical
                           accounting work on 1,055 Eastern Region judgment IIM accounts, which are included in
                           the August 30, 2002, deliverable in Table 1 above. An additional 682 accounts have
                           disbursements and are scheduled to be addressed during the next quarter.
                           New Accounts in Trust Fund Accounting System (TFAS)
                           Since TFAS was installed, new accounts have been established. These new accounts
                           have been opened as a result of probate inheritance, new leases of allotted lands,
                           judgment or per capita distributions, or for other reasons. The limited history associated
                           with these new accounts affords a cost-effective means for OHTA to test and learn how
                           to use electronic IIM account information in TFAS in relation to supporting paper records
                           and documents in performing an accounting. Further, OHTA's examination of these IIM
                           accounts will serve as a test to identify and resolve procedural and policy assumptions
                           related to reconciling the automated IIM records. OHTA hired the public accounting
                           firm of Ernst & Young LLP (E&Y) to perform the accounting work for this project.
                           E&Y prepared a work plan to perform the accounting for the new TFAS accounts
                           initially in the Southwest Region. The Southwest Region was selected since land records
                           are in the Albuquerque Land Records Title Office and financial records are in the Office
                           of Trust Records facilities, also in Albuquerque. This plan was reviewed and approved
                           by Grant Thornton.
                           E&Y has also gathered land ownership information for a subset of these IIM account
                           holders. Because of the Department-wide shutdown of computer systems (including the
                           Land Records Information System - LRIS), this information was collected from hard-
                           copy records at the Albuquerque Land Title Records Office of the BIA. Additional
                           ownership records will be obtained from LRIS.
                           E&Y has begun the analysis of the transaction histories for these accounts, including the
                           review of selected supporting financial documents from OTFM. E&Y expects to
                           complete this project during the next reporting quarter.
                           The accounting for the new TFAS accounts in the Southwest Region was originally
                           scheduled for completion this quarter. However, delays in obtaining LRIS data on leases
                           due to the December 5, 2001, Temporary Restraining Order (TRO) and the December 17,
                           2001, Consent Order were experienced.





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                           Eleventh Report to the Court
                           November 1, 2002

                           Land Title Project
                           The goal of the Land Title Project has been to evaluate the completeness of the BIA's
                           Land Records Information System (LRIS) underlying the IIM accounts. There are two
                           facets to this project: (1) completeness of the physical land records (i.e., whether all
                           Indian Trust tracts/allotments are in LRIS) and (2) completeness of the ownership data
                           (i.e., whether all individual owners are recorded in LRIS). The first facet of this project
                           has been completed and interim reports of findings have been provided to each Land Title
                           Records Office and an overall report finalized for OHTA.
                           The second facet of this project, the completeness and accuracy of the ownership records,
                           had been put on hold, as noted in the Status Report to the Court Number Ten, due to the
                           inability to gain access to LRIS, a result of the December 5,2001, TRO and the
                           December 17, 2001, Consent Order.
                           NORC is expected to resume this part of the project, since access to LRIS was restored
                           during mid-2002. A new schedule calling for a rapid completion of this facet is expected
                           by October 31, 2002, with completion during the next reporting period
                           Outreach
                           On September 17, 2002, OHTA's Deputy Director attended the Bureau of Indian Affairs
                           (BIA) Managers and Line Officers meeting in Phoenix, Arizona. This meeting, attended
                           by Assistant Secretary-Indian Affairs, Acting Deputy Commissioner for Indian Affairs,
                           BIA Regional Directors, BIA Area Superintendents, and other BIA office heads
                           (approximately 200 attendees), was held in conjunction with the National Summit on
                           Emerging Tribal Economies. The OHTA Deputy Director presented an overview of
                           OHTA and its mission, the plan for the historical accounting of IIM accounts as
                           contained in the Report and information on how OHTA plans to coordinate work with
                           BIA. Discussion and questions followed.
                           In order to ensure an accurate and consistent plan for the historical accounting to IIM
                           account holders for the selected projects, OHTA's management and staff personnel held
                           three offsite meetings with representatives from BIA field personnel and OHTA's
                           contractors - accounting firms, statisticians, historians, cost contractor, and project and
                           system integrator.
                                   The first offsite meeting was held August 22-23, 2002, in Denver, Colorado, to
                                    select the initial BIA Agencies in which to conduct an historical accounting of
                                    land-based IIM accounts.
                                  The second offsite meeting was held September 18-19, 2002, in Dallas, Texas,
                                    with a focus on planning the work in the Alaska Region, which was chosen as the
                                    site of the first historical accounting for land-based IIM accounts.


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                           Eleventh Report to the Court
                           November 1, 2002

                                   The third offsite meeting was held September 25-26, 2002, in Dulles, Virginia, to
                                    focus on the Alaska Region kick-offpresentation and meeting agendas. The kick-
                                    off meetings will be held in Juneau, Alaska, on October 3, and Anchorage,
                                    Alaska, on October 7 and 8, 2002.
                           BIA Presentation on September 10, 2002
                           OHTA's BIA Liaison arranged and moderated a briefing provided by BIA staff members
                           entitled "Working in Indian Country." OHTA sponsored this presentation. Topics
                           included overviews of tribal self-governance, compacting, contracting, sovereignty,
                           judgment and per capita distributions, probate process for realty trust assets and IIM
                           account distribution, Indian policies, and protocol issues. BIA speakers were Chief-
                           Tribal Government Services, Acting Chief-Division of Real Estate Services, and Director
                           of Self Governance.
                           A morning session was held for DOI and Treasury staff and OHTA contractors. A
                           separate presentation was held for Justice personnel in the afternoon. A total of 50
                           attended these two sessions.
                           Collection of Missing Information from Outside Sources
                           The District Court held that DOI was in breach of a duty to have written policies and
                           procedures to identify and collect from third parties missing information necessary for an
                           accounting of IIM funds. This project was originally assigned to the Office of the Special
                           Trustee for American Indians and was reassigned to OHTA earlier this year. OHTA has
                           identified broad categories of relevant third parties, e.g., oil and gas producers, foresters
                           and governmental entities, likely to have IIM documents in their possession. As part of
                           its efforts regarding the research and examination of third-party records, OHTA plans to
                           develop, by the end of the next reporting quarter, a policies and procedures plan for
                           collection of such records.
                           As a result of a Federal Register notice, three energy companies contacted OHTA and
                           indicated that they may have records pertaining to allotted lands. On August 6 and 7,
                           2002, OHTA staff conducted an on-site overview of records at one of these companies
                           and concluded a small percentage of the records may be useful as "fill-the-gap" data.
                           The company has agreed to retain custody of the records until further notice.
                           Another possible records source is the American Heritage Center at the University of
                           Wyoming. The Center houses the Anaconda Geological Documents Collection, and,
                           according to its brochure, this collection is "the largest and most significant body of
                           economic geologic data in the world." In September 2002, OHTA secured a membership
                           to the Center and is planning to inspect records maintained by the Center following its
                           submission of the Court-ordered historical accounting plan.



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                           Eleventh Report to the Court
                           November 1, 2002

                           OHTA has also contracted with Historical Research Associates (HRA) to research the
                           historical involvement of the U.S. Forest Service on allotted lands. Although anecdotal
                           evidence suggests the Forest Service had little, if any, involvement on allotted lands,
                           OHTA intends to present HRA's findings to the Forest Service for further discussions
                           regarding potentially relevant records. A final report from HRA is anticipated in October
                           2002.
                           In September 2002, DOI submitted an additional information collection request to the
                           Office of Management and Budget for inclusion in the Federal Register. This request
                           will allow OHTA to continue to seek Indian trust-related information from third parties.
                           In June 2002, Gustavson Associates (Gustavson) completed a pilot study to search and
                           identify oil and gas records on allotted lands and submitted a report with its findings.
                           The study successfully demonstrated a methodology for collecting records from third
                           parties, particularly oil and gas companies, but noted that specific solutions for records
                           collection will depend on unique problems and conditions. Gustavson briefed DOI and
                           Justice staff on its findings on July 23, 2002.
                           In discussions with representatives of the oil and gas industry, Gustavson concluded there
                           is no standard policy for records retention in the petroleum industry. The cost of
                           maintaining large volumes of records, frequent buying and selling of oil and gas
                           resources, and ongoing industry consolidation were cited as primary reasons for the lack
                           of an industry-wide standard. Gustavson recommended that OHTA work with the
                           Council of Petroleum Accounting Societies (COPAS) to survey its membership about
                           records retention practices. COPAS is an industry trade group and many of its members
                           are chief financial officers, controllers and chief accountants for petroleum companies.
                           On October 23, 2002, OHTA plans to make a presentation to the COPAS fall conference
                           asking for assistance in identifying potential sources of relevant records within the oil and
                           gas industry.
                           Palm Springs BIA Field Office, Large Dollar Transactions and Reconciling
                           Beneficiary Names
                           No new activity for these projects was conducted during the July through September
                           2002 reporting period. This work is expected to resume during the next reporting period.
                           New Projects
                           IIM Land-Based Accounts in Alaska
                           OHTA has initiated a project to examine the process of document collection, processing
                           (imaging and coding), accounting, and reporting procedures for about 18,000 native
                           allotments in Alaska, of which approximately 700 are receiving land-based revenues.
                           The lessons learned will help future OHTA projects in other geographical areas.


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                           Eleventh Report to the Court
                           November 1, 2002

                           OHTA selected this region because of the high value and manageability of the IIM
                           accounts, and the willingness of the BIA Alaska Region personnel to help OHTA in
                           carrying out this initial project. To kick off the project, OHTA scheduled a series of
                           meetings with BIA personnel at BIA regional offices in Juneau and Anchorage, Alaska,
                           during October 3 through October 9, 2002.
                           Topics of discussion will include types and quality of records, processing land sale
                           transactions, allotment process, Alaska Native Claims Settlement Act, the historical
                           accounting work that OHTA will conduct, and introduction of OHTA staff and
                           contactors. Additional meetings are scheduled with personnel of BLM, SOL, and other
                           BIA staff.
                           OHTA plans to commence this project during the next reporting period.
                           Forensic Examination of Overwritten Tapes
                           No new activity for this project was conducted during the July through September 2002
                           reporting period. This project is scheduled to be completed in the next quarter.
                           Accounting Standards Manual
                           Grant Thornton, with the assistance of CD&L, D&T, E&Y, KPMG and NORC, prepared
                           an Accounting Standards Manual (Manual). OHTA issued the Manual on July 2, 2002.
                           The Manual provides guidance to accounting firm consultants, other OHTA contractors,
                           and OHTA staff on the key documents to use in performing the historical accountings of
                           IIM accounts. Copies of the Manual have been distributed to DOI officials to inform
                           them of an important part of the historical accounting process. As the historical
                           accounting progresses, OHTA expects the Manual to be updated.
                           Named Cobell Plaintiffs and Predecessors-in-Interest
                           OHTA selected E&Y to complete historical accountings for four of the named plaintiffs
                           in the Cobell litigation, and their agreed-upon predecessors-in-interest. As part of a
                           separate contract with Justice, E&Y has previously reconciled documents that were
                           collected as part of the "Paragraph 19" effort to the IIM account transactional histories of
                           the four plaintiffs. One of the five named plaintiffs is not believed to have had an IIM
                           account as of the planned December 31, 2000, end date for the historical accounting.
                           E&Y will update the existing named plaintiffs' IIM account reconstructions to the
                           standards set forth for a historical accounting in the Manual described above. This will
                           include extending the existing work (which ended as of August 12, 1999) to the historical
                           accounting end date of December 31,2000. The following are the primary steps involved
                           in this task.



                                                                                 59



                           Eleventh Report to the Court
                           November 1, 2002

                                    Obtain updated ownership information and transaction histories for each plaintiff
                                     through December 31, 2000.
                                    Verify the calculated December 31, 2000, account balances to the TFAS
                                     balances.
                                    Identify transactions dated after August 12, 1999. Obtain leases and other
                                     supporting documents.
                                    Review each transaction and associated supporting documents to verify the
                                     accuracy of each transaction per OHTA's Accounting Standards Manual.
                                    Identify any variances noted between the transaction amounts and supporting
                                     documents.
                                    Perform quality control to verify all work.
                                     Report proposed Historical Statements of Account to OHTA.
                            As in all historical accountings, Grant Thornton will perform an independent quality
                            control check of E&Y's work.
                           Historical Accounting Software
                           During this reporting period, OHTA's integrator contractor, Booz Allen Hamilton
                           (BAH), commenced work on centralized historical accounting software. BAH is
                           coordinating its development efforts with the accounting firms and other contractors and
                           OHTA staff to finalize the software technical requirements.
                           BAH projects requirements should be identified in early November 2002, programming
                           to commence in mid-November, with completion of the software targeted for early
                           March 2003.
                           The historical accounting software will standardize the historical accountings conducted
                           by each of the accounting firms, and facilitate use of electronic and hard-copy land and
                           transaction documents, which will have been imaged and indexed.
                           Obstacles/Delays
                           OHTA has identified the following problems and concerns.
                                    (1) December 5, 2001, Temporary Restraining Order/Computer Shutdown - In
                                    the description of the Land Title Project and the New Accounts in Trust Fund
                                    Accounting System Project above, OHTA, as discussed in previous status repons,


                                                                                 60



                           Eleventh Report to the Court
                           November 1, 2002

                                    continues to indicate that the computer shutdown has delayed the completion of
                                    these projects.
                                    (2) OHTA Has Little Authority to Obtain Relevant Documents in Custody of Third
                                    Parties - As stated in the Status Reports to the Court Numbers Nine and Ten,
                                    OHTA may be unable to obtain access to IIM records held by third parties due to
                                    the lack of a requirement for parties outside of DOI to retain trust-related records.
                                    Interior's Office of the Solicitor is preparing guidance for retention of trust-
                                    related records which will address what authority the Federal Oil and Gas Royalty
                                    Management Act of 1982 may provide as it relates to the collection of missing
                                    information from outside sources. This guidance is expected during the
                                    forthcoming quarter.
                                    (3) Historical Accounting of Tribal Trust Accounts---On June 27, 2002, Secretary
                                    Norton amended Secretarial Order No. 3231 to direct OHTA to plan, organize and
                                    execute the historical accounting of Tribal Trust accounts. This additional
                                    assignment will require OHTA to reallocate its staff, time and other resources
                                    from OHTA's ongoing work for the historical accounting of IIM accounts.
                           Assurance Statement
                           I concur with the contents of the above information on OHTA's activities contained in
                           the Status Report to the Court Number Eleven. The information provided in this section
                           is accurate to the best of my knowledge.
                           Date:  November 1, 2002
                           Name: Signature on File
                                    Bert T. Edwards
                                    Executive Director















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                           Eleventh Report to the Court
                           November 1, 2002

                               V.  OFFICE OF THE SPECIAL TRUSTEE
                           ACTING SPECIAL TRUSTEE'S OBSERVATIONS
                           The Department of the Interior's (DOI) commitment to trust reform is reflected in its
                           continued support for the Office of the Special Trustee's (OST) efforts towards a
                           restructuring to focus on accountability and greater staff awareness of the Trustee's
                           fiduciary responsibility. I have stressed to managers the importance of reaching out to all
                           bureaus and offices that are responsible for Indian trust management. OST has received
                           positive feedback as a result of these efforts. For reform to succeed, it is imperative that
                           managers make every effort to work together and that they be held accountable to
                           exacting performance measures and deadlines.
                           Current efforts within OST include evaluating the most suitable way to provide
                           independent objective oversight and review of the Department's delivery of trust
                           services. This major effort includes a reorganization that will strengthen the trust reform
                           management capabilities of OST by incorporating the broader trust training and policies
                           and procedures projects. An additional strengthening will result by segregating staff to
                           coordinate and contract with private sector companies for the review and performance
                           evaluation of each DOI office performing trust duties.
                           The Office of the Comptroller of the Currency (OCC) evaluates national private sector
                           trust operations according to a grading system. OCC is scheduled to begin working with
                           OST during the next reporting period to help establish a grading system to evaluate the
                           error rate, compliance with established trust standards, and corrective measures at each
                           location providing trust services. Locations found to be providing consistently high
                           quality services will require less oversight than those demonstrating difficulty meeting
                           the standards required by our fiduciary responsibilities.
                           Progress is being made. The "As-Is" business process study effort has involved hundreds
                           of employees from offices throughout Indian country. A careful, methodical approach is
                           being taken to trust reform and improvement. This approach is expected to have great
                           benefit for the future.
                           I endorse the Business Process Modeling project but realize the utmost challenge for trust
                           reform is persuading managers and staff to accept the resulting changes in the business
                           culture. These changes will require the forfeiture of some independence at local sites and
                           DOI central offices in order to achieve standard practices and demand greater
                           accountability. Bringing about these changes will require the perseverance and
                           encouragement of DOI executives and Indian leaders.
                           A major issue that requires much continued work and study is fractionation. The
                           Department must devote even greater time and effort to the study of the Indian Land
                           Consolidation Act (ILCA) pilot projects that are currently in place. These pilots require
                           an in-depth evaluation of results, obstacles and costs before considering nationwide

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                           Eleventh Report to the Court
                           November 1, 2002


                           deployment. The magnitude of problems resulting from the continued exponential
                           growth of miniscule individual interests in allotments will require focused efforts from
                           the Department, Congress, Tribes, individual allottees, and other interested parties to
                           resolve.
                           Another concern is seeing that the historical accounting and information technology
                           efforts move forward with greater coordination and cooperation from all bureaus and
                           agencies within the Department. As bureaus and offices work towards improving trust
                           systems that respond to beneficiary needs and requests for information, it is essential that
                           the lines of communication remain open to prevent duplication of efforts. The
                           Department is making great strides in improving information security.
                           A debate continues on the proper reporting alignment for the Indian land valuation and
                           appraisal function. A final decision on the proper placement of this work is expected
                           during the reengineering process.
                           Assurance Statement
                           I prepared the Acting Special Trustee's Observations.
                           Date:  November 1,2002

                           Name: Signature on File
                                    Donna Erwin
                                    Acting Special Trustee for American Indians


















                                                                                 63



                           Eleventh Report to the Court
                           November 1, 2002

                                    A. CURRENT ACCOUNTING ACTIVITIES
                           1.       Locate missing mandatory documents for unrestricted accounts (formerly
                                    OST Data Cleanup)
                           Introduction
                           Administrative data and supporting documentation in the Individual Indian Monies (IIM)
                           module of the Bureau of Indian Affairs' (BIA) Integrated Records Management System
                           (IRMS) and the IIM file jacket folders were not maintained consistently throughout BIA
                           and Office of Trust Funds Management (OTFM) field offices. Numerous deficiencies
                           existed in the data because of inconsistent application of any "standard" method of data
                           input, account/data review, or standardized use of system codes.
                           Upon completion of the TFAS conversion, OTFM implemented centralized encoding,
                           which provided standards and controls for data input with a 100% pre-quality assurance
                           verification of work tickets and backup documentation for all transactions manually
                           entered, and post-quality assurance of data encoded in TFAS.
                           In preparation for the conversion from the IIM Legacy System to the Trust Funds
                           Accounting System (TFAS), a data cleanup project was required. This project identified
                           account jacket folders without the mandatory documentation required by OTFM policy,
                           POL 98-003 (Mandatory Documentation Requirements for IIM Account Jacket Folders).
                           That policy states that mandatory documentation for individual, unsupervised, flow-
                           through accounts includes disbursement authorizations and W-9 forms or copies of Social
                           Security cards.
                           Phase I of the data collection task included updating unrestricted accounts having
                           cumulative disbursements exceeding $5,000 over a 12-month period. 472 accounts were
                           identified and letters and forms seeking required information were sent to the account
                           holders.
                           Phase II included data collection for all remaining unrestricted accounts regardless of
                           their disbursement totals, excluding accounts that already contained the mandatory
                           documents. A total of 39,258 initial letters were mailed to account holders requesting
                           mandatory documents. A minimum of three requests will be sent to these unrestricted
                           account holders.
                           Accomplishments and Completions
                           Phase I -Documentation was received for three accounts this reporting period.  Of the
                           472 total accounts, documentation has been received for 469 accounts as of September
                           30, 2002.  OTFM contacted the remaining three account holders, received confirmation
                           that they have received the forms and OTFM is now awaiting their response.


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                           Eleventh Report to the Court
                           November 1, 2002

                           Phase II - Documentation was received for 1,462 accounts this reporting period. Of the
                           39,258 total accounts, documentation has been received for 7,428 accounts as of
                           September 30, 2002, leaving 31,830 accounts still awaiting documentation.
                           Current Status
                           Phase I - The Solicitor has recommended restricting the accounts lacking mandatory
                           documentation, because the address must be verified to ensure the proper beneficiary is
                           receiving trust assets. A letter affording due process in accordance with 25 CFR 115
                           stating that the account will be restricted will be reviewed by the Solicitor and then
                           forwarded to the BIA Superintendent for his signature.
                           Phase II -31,830 accounts are awaiting documentation. Second requests for the
                           documentation will be mailed next quarter.
                           Options to change the difficult task of revising or changing account information are being
                           developed. Currently, address changes require notarization and witnessing arrangements,
                           which place a burden on account holders. Some decisions on alternative actions should
                           be available during the next quarter.
                           Delays/Obstacles
                           Obstacles include notarization/witnessing requirements, lack of imaging, lack of account
                           holder response, mobility of account holders and the December 5,2001, Temporary
                           Restraining Order and December 17, 2001, Consent Order blocking Internet activity.
                           2.       TFAS
                           Introduction
                           The conversion of the IIM accounts to TFAS was completed in April 2000. TFAS is a
                           generic term for the SEI Investments, Inc. off-the shelf standard trust accounting system.
                           TFAS provides the basic receipt, accounting, investment, disbursing and reporting
                           functions common to commercial trust funds management operations. The system is
                           owned and operated by SEI Investments, Inc. in a service bureau environment.
                           OST is exploring ways in which it can store additional information in TFAS to provide
                           performance statements to account holders which will identify the source of income and a
                           listing of all assets owned.
                           Delays/Obstacles
                           The current contract with SEI, the company that manages the TFAS accounting system,
                           is expected to be rebid during the next reporting period.


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                           Eleventh Report to the Court
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                           3.       SPECIAL DEPOSIT ACCOUNTS
                           At the end of this reporting period, September 30, 2002, there are 20,698 special deposit
                           accounts (SDAs) representing $62,327,750 in TFAS. Funds in these accounts will be
                           distributed to IIM account holders, tribes or other third party interests.
                           Project(s) Accomplishments/Completions:
                           During the week of July 8, 2002, OTFM Special Projects staffand Chavarria, Dunne &
                           Lamey LLC, worked with the BIA Rocky Mountain Regional Office (RMRO) Land
                           Titles and Records Office (LTRO) on title and ownership issues on 172 allotments. The
                           purpose of the ownership research was to determine the proper recipients of SDA
                           balances. As a result of the research, proper ownership was established for 135 (78%) of
                           172 allotments. At the time of the field visit, the Land Records Information System
                           (LRIS) was still not available; therefore, title research was based on manual records
                           maintained by the LTRO.
                           During the week of July 22, 2002, a similar field visit was conducted at the BIA
                           Southwest Regional LTRO, at which time the LRIS was available. Of 107 allotments
                           identified for research, proper ownership was established for 90 (84%) allotments. The
                           Southwest Region LTRO relies on LRIS for recordation of title changes, so during the
                           LRIS system shut down, the agency recorded backlogged changes and modifications on
                           an off-line DBASE program pending reactivation of the LRIS system. A review of the
                           DBASE recording module was conducted to take into consideration any backlogged title
                           changes. Reliance on the LRIS is evident in that there were no manually maintained
                           reports such as the "Form 188' reports, Land Index or Chaining Sheets obtained at the
                           Southwest Region. This methodology differs from the Rocky Mountain and Great Plains
                           Regional LTROs.
                           In this reporting period, OTFM received from the BIA Office of Information Records
                           Management (OIRM) electronic files containing LRIS and IRMS data for the four pilot
                           sites (Wind River, Fort Peck, Standing Rock and Navajo Reservations) for which SDAs
                           have been worked, to be used for sample testing to compare title to ownership
                           distribution information. OTFM also worked with the BIA Great Plains Region to obtain
                           electronic ownership distribution files from the Management & Accounting Distribution
                           (MAD) system for the Standing Rock Agency. The files will be used to perform an
                           electronic comparison of ownership versus monetary distribution for a sample of
                           allotments. After this sample testing is completed, the contractor will make
                           recommendations for the distribution of the residual balance in the SDAs. OTFM will
                           then work with the BIA staff to obtain concurrence on the recommendation and obtain
                           the necessary authorizing documents to distribute the residual balances from SDAs.
                           On August 7, 2002, a meeting was held with the Director and Deputy Director, BIA
                           Navajo Region, at Gallup, New Mexico to discuss continued work and research on
                           ownership issues on the pilot project SDAs. The Director informed OTFM that the

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                           Eleventh Report to the Court
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                           Realty Office was closed due to asbestos in the building and that no one was allowed in
                           the building until the asbestos was cleaned up by a contractor. With the Realty Office
                           closed, the BIA staff did not have access to trust records and therefore could not provide
                           additional requested information. However, the OTFM staff was able to make a field
                           visit to the Farmington Indian Minerals Office on August 19, 2002, to obtain lease and
                           contract documents for oil and gas-related SDAs for the Navajo Region. Based on
                           continuing communication with the Navajo Regional Office, we expect the Realty Office
                           to be available for business in the next reporting period.
                           On August 21, 2002, OTFM hosted the Interagency Procedures Handbook training in
                           Albuquerque for OTFM and BIA program managers. The Interagency Procedures
                           Handbook, Chapter 12, is specific to SDAs. In the next quarter, OTFM managers will
                           brief the Acting Special Trustee on the status of the SDA pilot project and the draft
                           procedures for SDA document preparation and encoding. Handed out at the training was
                           a Draft Recommended Prospective Action for the SDA Document Preparation and
                           Encoding (Draft) that is specific to the SDA comprehensive database (as described in the
                           10 th
                                 Report to the Court). OTFM asked participants to provide any comments,
                           suggestions or questions on the Draft to the OTFM Special Projects Office for
                           consideration in the final procedures. This database and related procedures will support
                           the issuance and enforcement of an SDA policy. Once the BIA, in consultation with
                           OTFM, issues a final policy, that will be incorporated into the Interagency Procedures
                           Handbook and training. Meanwhile, the OTFM is coordinating efforts with the BIA
                           managers on the proposed procedures affecting special deposit accounts through the
                           Interagency Procedures Handbook training, which started in August 2002 and is expected
                           to continue through fiscal year 2003.
                           On September 11, 2002, a meeting was held with the Rocky Mountain Regional Deputy
                           Director and agency program managers to discuss the testing and implementation of the
                           prospective database developed during Phase II of the pilot project. In the next quarter,
                           three BIA RMRO agencies (Blackfeet, Wind River and Fort Peck) will serve as new pilot
                           agencies for the standardization of data input for the SDA prospective database pilot
                           project.
                           OTFM continues to have monthly status meetings with the BIA, Office of Trust Risk
                           Management (OTRM) and the contractor as part of coordinating efforts to resolve SDA
                           issues.
                           Current Status of Work in Progress
                           As reported in previous Court Reports, activities for the SDA pilot project continue with
                           an anticipated project completion date of December 31, 2002. Current activities include:
                                   testing and implementation of a centrally-managed tracking system/database for
                                    SDAs



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                           Eleventh Report to the Court
                         November 1, 2002

                                analyzing database files received from the Legacy System (LRIS/IRMS) and
                                 MAD to determine how they can be used in constructing distribution files for
                                 aged collections to past owners
                                sample testing of title versus monetary ownership distribution files
                                preparing distribution recommendations for BIA's consideration for approval as
                                 title and monetary ownership issues are researched and
                                preparation for training the staffat the three database pilot sites
                         Throughout this process, OTFM Special Projects continues to work with BIA program
                         managers and staffto secure appropriate authorized disbursing documents to effect
                         distribution of funds to the beneficial owners from SDAs.
                         Based on pilot results, the work plan procedures will be made available to the senior
                         management of OST and BIA for decision making on the national roll-out of the SDA
                        project.
                         Delays/Obstacles:
                         An environmental problem (mold and asbestos) at the Navajo Region Realty Office in
                         Window Rock, Arizona, continues to delay the contractor in completing its review of
                        pilot SDAs. The Deputy Director, Navajo Region, informed OTFM that access to the
                        building should occur in the next reporting period.
                         The BIA reactivated the Land Records Information System (LRIS) and Trust Asset and
                         Accounting Management System (TAAMS) title for use during this reporting period.
                         However, the pilot sites have informed OTFM that updating the backlog to process and
                         record land title changes, conveyances, sales, probates, modifications, etc., may take
                         longer than expected. The backlog may delay updates to the respective monetary
                         distribution systems to process payments to beneficiaries.
                         In addition, competing priorities for trust reform projects and workforce staffing delays
                         have hindered BIA staff in performing tasks associated with the SDAs pilot project.
                         4.      Accounting Discrepancies
                         The difference between the aggregate of all positive fund balances from the IIM detailed
                         subsidiary accounts and the IIM investment pool was reduced by over $780,000. This
                         reduction was the result of previously initiated research that was completed as part of the
                         Special Deposit Accounts Pilot Project (Phase 2). The difference, originally $6.7 million,
                         is now approximately $6 million.
                         A meeting with Department of the Treasury officials has been scheduled by the Office of
                         Historical Accounting to discuss accounting discrepancies.  The results of this meeting
                         will be reported in the next report.


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                           Eleventh Report to the Court
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                           Assurance Statement
                           I believe that the information provided by me in the Current Accounting Activities
                           section, except for the "Accounting Discrepancies" task, which will be surnamed by
                           Michael Fansler, is an objective and informative analysis of that project as of September
                           30, 2002. My belief is based on my knowledge and review of credible evidence.
                           Date:  October 30, 2002
                           Name: Signature on File
                                    Dianne M. Moran
                                    Trust Operations Officer

                           Date:  October 30, 2002
                           Name: Signature on File
                                    Helen Riggs
                                    Project Manager

                           I believe that the information provided by me in the Accounting Discrepancies section of
                           the Current Accounting Activities Report is an objective and informative analysis of that
                           project as of September 30, 2002. My belief is based on my knowledge and review of
                           credible evidence.
                           Date:  October 28, 2002
                           Name: Signature on File
                                    Michael Fansler
                                    Program Analysis Officer














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                           Eleventh Report to the Court
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                                    B. RECORDS MANAGEMENT
                           Introduction
                           An active, continuing records management program must be developed and implemented
                           to ensure that necessary Indian records are created and maintained; records retention
                           needs are met through authorized schedules; and that the records are safeguarded
                           throughout their life-cycle. The Office of Trust Records (OTR) was established in 1999
                           to develop and implement an active program for the economical and efficient
                           management of trust records, consistent with the American Indian Trust Fund
                           Management Reform Act of 1994, the Federal Records Act, other statutes and their
                           implementing regulations.
                           Management of OTR changed this past quarter. A new Acting Director was detailed to
                           OTR on July 29, 2002, and a competitive vacancy announcement for the Director
                           position was issued on September 25, 2002. The line authority for supervision and
                           management of OTR changed on September 5, 2002, to the Assistant Deputy Secretary.
                           The purpose of this change was to ensure that appropriate priority and support is given to
                           OTR's mission.
                           The Acting Director initiated an assessment of the ongoing activities of OTR and a draft
                           OTR work plan was developed. These were discussed at a meeting with the Special
                           Master on September 10, 2002. Flow charts depicting the life cycle of records for BIA
                           and the Office of Trust Funds Management (OTFM) were also developed and presented
                           to the Special Master.
                           OTR developed strategic goals (and associated objectives and tasks) in its draft work
                           plan. This report will use the strategic goals as the format for reporting OTR activities.
                           Previously reported activities are subsumed in the strategic goals where the activity is
                           consistent with the work plan. The draft work plan will be further developed in the next
                           quarter.
                           Strategic Goal 1: Establish records retention schedules
                           The BIA/OTR Records Schedule Working Group met in July 2002. The group continued
                           developing proposed records retention schedules for the following BIA programs: realty,
                           forestry, fish and wildlife, agriculture, range, irrigation, environmental, water rights,
                           safety of dams, and minerals and mining. These proposals will be sent out for comment
                           to BIA's Office of Trust Responsibility in the next quarter.
                           As reported in the previous report, the OTR record schedule teams planned to submit
                           proposed trust-program related schedules to the National Archives and Records
                           Administration (NARA), for review and approval during this reporting period.  The
                           submission was delayed while the teams awaited additional inputs, including comments
                           they had requested from BIA. OTR plans to submit the proposed electronic schedules to

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                           Eleventh Report to the Court
                           November 1, 2002

                           the appropriate BIA official for concurrence during the next reporting period and to
                           submit them to NARA 30 days after receiving the concurrence.
                           Strategic Goal 2:  Establish and implement record keeping requirements that allow
                           for record retrieval on an as-needed basis
                           OTR developed and presented to the Special Master flow charts identifying the life cycle
                           of BIA and OST's Office of Trust Funds Management (OTFM) records. Evaluation of
                           options for the inventory of records in OTR's possession was initiated. Reviews of
                           existing draft records management policies and procedures manuals were conducted. It
                           was concluded that the drafts require further revisions. A timetable for the development
                           of policies and procedures is expected during the next reporting period.
                           As described in the Tenth Report, a draft Chapter One for a new BIA records manual was
                           submitted to OST management for review and comment. No comments were received.
                           Chapter one and additional draft BIA manual chapters that had not been submitted for
                           OST management review will now be reassessed by OTR. All chapters, including
                           Chapter 1, will be redrafted, as appropriate, and submitted to OST, BIA and other parts of
                           DOI upon completion.
                           A re-evaluation of the pilot project for Electronic Record Keeping is included as a part of
                           OTR's draft work plan. On September 12, 2002, OTR attended a demonstration of
                           electronic record keeping software used by the Bureau of Reclamation. During the next
                           quarter, OTR expects to advance this re-evaluation, including a reexamination of the
                           Statement of Work reported in the Tenth Report.
                           Strategic Goal 3: Safeguard records
                           Records site assessments were conducted at the BIA Central Office East on August 12-
                           14, 2002. Site assessments of OTFM IIM field locations were conducted at the Great
                           Plains Regional Office (July 8-9, 2002), Cheyenne River Agency (August 8, 2002), Pine
                           Ridge Agency (July 31, 2002), Crow Agency (August 15, 2002), Rosebud Agency
                           (August 29, 2002), and Northem Cheyenne Agency (September 12, 2002). OTR
                           continues to honor the request of the Makah Field Office not to undertake an assessment
                           of the field office.
                           Requisitions for equipment to store records at two BIA Regional Offices and 34 Agencies
                           were submitted to the OST Contracts Office on September 25, 2002.
                           The April 16, 2002, directive from the Deputy Secretary to maintain all Indian records in
                           their current geographic locations pending further direction on their disposition continues
                           in effect. The notice provided to the employees union regarding the movement of up to
                           32,000 boxes of records from Albuquerque to the Lee's Summit Federal Records Center
                           was rescinded.


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                           Eleventh Report to the Court
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                           Further, there was no activity on the initiative to replace historical records with working
                           copies pending security clearances for contract employees.
                           OTR provided technical assistance to the Ft. Belknap Agency to prepare records
                           necessary for P.L. 93-638 programs contracted by the Assiniboine and Gros Ventre
                           Tribes. No records have been transferred to the Tribes as of this reporting period.
                           Strategic Goal 4: Implement trainin_ Drouram
                           OTR provided basic records management training to BIA, OTFM, and tribal employees.
                           The training was held at Aberdeen, SD (July 16-17; 28 BIA attendees), Oklahoma City,
                           OK (July 23-24; 31 BIA attendees), Pine Ridge, SD (July 30-31; 39 BIA and tribal
                           attendees), Billings, MT (two sessions: August 13-14; 32 BIA attendees, and September
                           10-11; 36 BIA/OTFM attendees), Albuquerque, NM (August 22-23; 26 BIA attendees),
                           Rapid City, SD (August 27-28; 32 BIA attendees) and Tulsa, OK (September 24-25; 27
                           attendees).
                           The Special Master expressed concern about the current training program at the meeting
                           on September 10, 2002. OTR determined that it would be appropriate to suspend the
                           training program as of October 1, 2002, until such time as the draft policies and
                           procedures for this program are reviewed and modified and new training materials are
                           developed. Draft OTR procedures for records management training were reviewed and
                           will provide a basis from which to develop policies and procedures for the training
                           program. A timetable for the development of training policies and procedures is expected
                           during the next reporting period. Training by OTR will be coordinated with the training
                           initiative being developed by the Office of the Special Trustee and the Office of Indian
                           Trust Transition.
                           Strategic Goal 5: Undertake continual evaluation of records program
                           On July 10-12, 2002, at the request of the Special Master, the Associate Deputy
                           Secretary, Assistant Deputy Secretary and an attorney from the Department of Justice
                           met with employees of OTR to hear their assessment of the records program. As
                           reflected in the introduction, changes were made to the management of the program
                           shortly thereafter. A draft work plan was developed and review of program activities
                           initiated.
                           Draft procedures for cyclic evaluation of the records management program are being
                           developed as part of the draft OTR work plan. A timetable for the development of these
                           procedures is expected during the next reporting period.





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                           Eleventh Report to the Court
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                           Strategic Goal 6:  Establish program to meet trust and other record retrieval needs
                           of customers and document production requests
                           Users of records were identified. An effort to measure the volume and types of requests
                           (documents produced) was initiated. The use of a contractor to index boxes at the level
                           of document type, date and source is being considered.
                           Strategy Goal 7: Report, as appropriate, on progress in meeting Strategies 1-6
                           OTR will periodically inform DOI management on its progress. In addition, DOI has
                           agreed to share an OTR monthly report with the Department of Justice and, subsequently,
                           the Special Master.
                           Delays/Obstacles
                           Delays and obstacles include: lack of staff/resources in BIA and OST to manage records;
                           lack of communication and true partnerships between OST and BIA to achieve records
                           management initiatives; lack of records retention schedules for OST and electronic
                           records schedules for OST/BIA; need to complete work on updating Volume 16 Bureau
                           of Indian Affairs Manual; varying quality of inventories/indexes for boxes of records in
                           OTR's possession; lack of policies and procedures; and the inability to move records
                           among BIA/OST offices. Many of these delays/obstacles are being addressed through
                           the OTR draft work plan.
                           Assurance Statement
                           I concur with the content of the information contained in the Records Management
                           section of the 11 th
                                                  Report to the Court. The information provided in this section is
                           accurate to the best of my knowledge.
                           Date:  October 28, 2002
                           Name: Signature on File
                                     Ethel J. Abeita
                                     Acting Director, Office of Trust Records











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                           Eleventh Report to the Court
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                                    C. TRAINING AND TRUST MANAGEMENT STAFFING
                           Introduction
                           The lack of adequate training of those persons who manage Indian trust assets has been
                           cited in numerous Office oflnspcctor General and General Accounting Office reports and
                           has been identified as a significant obstacle to the more effective management of, and
                           accountability for, the proper discharge of the Secretary's trust responsibilities to Indian
                           tribes and individual Indians for whom the Department holds or controls trust assets. The
                           Secretary has a continuing responsibility to provide adequate staffing, supervision and
                           training for trust fund management and accounting (25 U.S.C.  162 a(d)(7)). Coupled
                           with accountable supervision and productive experience, training is essential to the
                           successful management of any operation.
                           Project Goals
                           The objective of the trust asset management training project is to support the systems and
                           specialized skills needed to increase the job performance and interorganizational
                           effectiveness of Departmental and Tribal personnel who manage these assets.
                           Current Status
                           As reported in the 10 th
                                                        Quarterly Report, efforts continue within the Office of the Special
                           Trustee (OST) and Office of Indian Trust Transition (OITT) to develop a centralized
                           training program to supply the trust organization training and education needs in the
                           future. An individual has been detailed to OITT for this project. Meetings between OST,
                           OITT and the Acting Training Coordinator have been scheduled for the next reporting
                           period with Cannon Financial Institute to begin curriculum development for more
                           technical training. While this additional technical trust training course development is
                           considered by the Department, OST will continue to offer its basic and introductory trust
                           foundation training course to the entire trust asset management workforce.
                           Trust Foundations: An Introduction to Trust Reform and Change:
                           During the period of July 1, 2002 to September 30, 2002, Upper Mohawk Inc., the
                           contractor that has been retained to provide general trust training to Departmental and
                           Tribal trust asset managers, provided its Trust Foundations: An Introduction to Trust
                           Reform and Change course to 186 employees. As has been mentioned previously, this is
                           a non-technical course designed to provide trust employees at every level with an
                           increased understanding of the Government's and the Department's fiduciary
                           responsibilities with respect to the Indian assets held in trust. This course is three days in
                           length. A one-day course is offered to students who have taken the first two days
                           previously, and a three-day course is offered to those who have not taken any portion of
                           the Trust Foundations course to date. As illustrated by the table below, the vast majority
                           of attendees have rated the class as either completely or generally successful in meeting

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                           Eleventh Report to the Court
                           November 1, 2002

                           its stated objectives that include: to understand the purpose of the 1994 Reform Act; to be
                           familiar with the Secretary's Trust Principles; and to be familiar with the concepts of
                           fiduciary conduct.


                           Course                   Number of Students   Completely              Generally
                                                        Attending this           Successful               Successful
                                                        Quarter
                           Trust Foundations-                62                        76%                       23%
                           One Day Training
                           Trust Foundations-               124                       74%                       25%
                           Three Day Training


                           As reported in the Tenth Quarterly Report to the Court, the contractor is responsible for
                           the implementation of an outcome study to determine the long-term value of this basic
                           training course. Specifically, the outcome study will measure students' retention of the
                           material presented in the Trust Foundation class and elicit their continued understanding
                           of the concepts introduced in the training. During this quarter, Upper Mohawk
                           contracted with the Center for Business and Economic Research of the School of
                           Business Administration, University of Dayton, Dayton, Ohio, to perform an appropriate
                           study. It is expected that the study will be completed before the end of the calendar year.
                           Customer Service
                           During the quarter, Upper Mohawk completed the development of the draft Customer
                           Service course curriculum. An evaluation of the timing of the rollout of the Customer
                           Service course is under consideration to determine if coordination with the reengineering
                           effort is more appropriate.
                           Delays/Obstacles
                           The project manager continues to be concerned that not all bureau and office
                           management is providing the appropriate leadership, direction and support to their
                           employees to ensure their attendance at this training course. As previously reported, the
                           Special Trustee recommended that specific performance evaluation standards be put in
                           place for SES personnel who have a responsibility for persons who manage Indian trust
                           assets to ensure that these employees attend and successfully complete the course. That
                           recommendation was not adopted. The project manager understands that after
                           discussions between the Assistant Secretary-Indian Affairs and the Acting Special
                           Trustee, a decision was made to appoint a group of individuals to work together to


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                           Eleventh Report to the Court
                           November 1, 2002

                           determine consistent SES performance elements. Standards for training will be included
                           in these discussions. The success of both the training program and the overall trust
                           reform effort depends on the strong support and leadership clearly shown in both the field
                           and the Washington, D.C. headquarters offices.
                           Assurance Statement:
                           I believe that the information provided by me in the Training portion of this 11 th
                                                                                                                               Report
                           to the Court is an objective analysis of the current status of this subproject as of October
                           1, 2002. My belief is based on my knowledge and review of what I believe to be
                           creditable evidence.
                           Date:  October 23, 2002
                           Name: Signature on File
                                    Richard V. Fitzgerald
                                    Trust Policy Officer, OST


























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                           Eleventh Report to the Court
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                                    D. RISK MANAGEMENT AND INTERNAL CONTROLS
                           Summary, Description
                           The Office of Trust Risk Management (OTRM) objectives are to (1) systematically
                           address and make recommendations to resolve management control deficiencies and (2)
                           design and implement a comprehensive risk management program that includes extensive
                           management controls to monitor and evaluate the Department's Indian trust asset
                           management program. Eventually, this program will be coordinated with many of the
                           ongoing reform efforts. Currently these include trust systems, data quality, probate and
                           special deposit cleanup projects.
                           Accomplishments and Completions
                           Pilot Risk Mana_,ement Prourams
                           Pilot programs are designed for the purpose of building risk assessment and management
                           control systems for the Indian trust asset management processes at the selected locations.
                           The pilot program development efforts in the Bureau of Indian Affairs (BIA) Southem
                           Plains and Northwest Regions have continued with several accomplishments this quarter.
                           The Bureau of Land Management (BLM) Cadastral Survey program efforts have
                           concentrated on risk assessment criteria development.
                           Final working drafts of the agency and region trust asset management business processes
                           were completed and provided to Southern Plains. These business processes included
                           identification of risk factors associated with the methods or means of controlling the
                           risks. Each of the locations was visited and a risk assessment for each business process
                           was completed. The results were summarized and reported in draft to each agency
                           manager and the Regional Director. OTRM will prepare and implement corrective action
                           plans for resolving identified control deficiencies. As the "To-Be" reengineered business
                           processes are completed, these identified controls will be incorporated into the new
                           processes where appropriate.
                           To demonstrate the management information capability of the database that stores the
                           complete risk management plan, several proposed management reports were provided to
                           Southem Plains management for review and comment. A follow-up process with the
                           Southern Plains offices began to identify potential improvements in the program
                           development and program implementation approach.
                           Development efforts and site visits relating to risk assessments and control plans in the
                           Northwest Region resumed with the Regional office and the Flathead Agency. The
                           additional refinements in the management control programs identified in the last quarter
                           have been incorporated into the program packages for the Northwest Region.



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                           Eleventh Report to the Court
                           November 1, 2002

                           OTRM began testing a draft version of the Management Control Plan Database (MCPD)
                           and will request comments from the Southern Plains Region when a workable test
                           version can be provided. The MCPD is a repository of information applicable on a
                           nationwide basis for each Indian trust business process. It includes standardized program
                           objectives, management controls, management control evaluations, a "Best Practices"
                           approach to each of the current business processes; the systematic ranking of the current
                           risks which affect Indian trust assets; the automation of the formalized tracking of control
                           deficiencies and corrective actions; and a process to streamline fieldwork.
                           Project Coordination and Trainine
                           OTRM staff and its contractor provided overview training and participated in conferences
                           and meetings this quarter. An overview of the Risk Management process and program
                           was provided to the 4 th Annual BIA Awarding Officials Conference in Las Vegas,
                           Nevada. Ninety-two people, including six tribal representatives, attended the conference.
                           An overview of Risk Management was presented to the Northwest Region Annual Realty
                           Staff Conference. One hundred thirty-five people attended this conference, mostly from
                           BIA, with some attendees from other bureaus. This overview will be followed by
                           development and implementation of risk assessment and control programs for the
                           Northwest realty operations.
                           An overview of Risk Management and an assessment of the Risk of Reengineering were
                           presented to the Probate Trust Business Process "To-Be" Modeling Workshop in
                           Albuquerque, New Mexico. Sixty-one people representing BIA, Office of Hearings and
                           Appeals (OHA), Office of the Special Trustee (OST), Office of Indian Trust Transition
                           (OITT), the Tribal Task Force and individual tribes attended this conference/workshop.
                           Audit Annual DOI Indian Trust Funds Financial Statement
                           The Indian Trust Funds Financial Statement audit is required by the Trust Fund Reform
                           Act and has been conducted independently each year since 1995. The annual audit is
                           contracted out by OTRM and is monitored for conformance to standards by the Office of
                           the Inspector General. The audit for FY 2002 is underway and on schedule to meet the
                           Department reporting milestone of December 15, 2002.
                           The Office of Trust Funds Management (OTFM) is responsible for implementing
                           corrective actions to resolve audit findings. OTRM monitors the progress of the
                           corrective actions. The FY 2001 report included 23 reportable findings. Corrective
                           action has been completed for 19 of these findings and substantial progress has been
                           made on the others. However, long-standing difficult issues (material weaknesses)
                           requiring multi-bureau coordination and cooperation remain to be resolved.
                           As summarized in the last report, corrective actions will result in the data validation
                           effort to clean and update the land ownership records and clear backlogs at the title

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                           Eleventh Report to the Court
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                           plants. The other weakness requires cooperation within thc Department and cooperation
                           from thc Department of the Treasury to resolve fund imbalances that have existed since
                           the mid-1990s. Progress on this issue was made this quarter, during a visit by DOI's
                           Office of Financial Management, discussed below. Those representatives agreed to
                           pursue the involvement and support of other responsible Departmental managers to
                           research and resolve these differences.
                           Current Status
                           Follow-up visits to implement the pilot risk management programs in the Northwest and
                           Southern Plains Regions will be completed during the next quarter. Review efforts on
                           special projects, discussed below, will continue. Also, reporting and follow-up
                           procedures and the report numbering system initiated this quarter will continue to be
                           implemented.
                           DOI's Office of Financial Management representatives visited the OST offices in
                           Albuquerque in September to review audit follow-up procedures, the risk management
                           program implemented in OTFM and the overall risk management program development
                           by OTRM. Initial feedback from the visit was positive, and a report summarizing the
                           review is expected during the next quarter.
                           Meetings are scheduled in October with the Treasury Department to obtain assistance
                           from the Office of the Comptroller of the Currency (Trust Bank Examiners) to review
                           and consult on DOI's trust risk management program and the development of a
                           performance measurement and ranking system for all offices performing trust activities.
                           Special Projects
                           These projects result from inquiries by beneficiaries or other interested groups and
                           usually question the adequacy or status of trust and fiduciary activities of the Department.
                           OTRM assigns these matters to internal audit staff to investigate and respond, or where
                           necessary, recommend corrective actions to the Special Trustee. During the reporting
                           period, OTRM audit staff initiated or continued work on seven separate projects and
                           completed one reports.
                           This report dealt with a security problem that was identified during an employee
                           background investigation. The employee was terminated and audit work was initiated to
                           ensure that transactions processed by the employee were proper. No improprieties were
                           identified.






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                           Assurance Statement
                           The information contained in this project report for Risk Management and Internal
                           Controls is, to the best of my knowledge and belief, a comprehensive portrayal of the
                           project's status. It was objectively developed and key subordinates and I have reviewed it
                           in a manner and to an extent sufficient for me to concur with its contents.
                           Date: November 1,2002
                           Name: Signature on File
                                    Kenneth M. Moyers
                                    Director, Office of Trust Risk Management






























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                                    E. APPRAISAL
                           Introduction
                           The Indian land valuation program exists to provide impartial estimates of market
                           value for a variety of specific real property interests on land owned in trust or
                           restricted status by individual American Indians and Alaska Natives or Indian
                           tribes. Various regulations governing Indian trust land transactions require the
                           Secretary of the Interior to obtain valuations. To meet this requirement, an
                           appraisal or other valuation is used as a management tool to ensure that fair and
                           just compensation is received on Indian land transactions. The types of
                           transactions are varied. Major types include commercial, industrial, recreational,
                           agricultural and other types of leases; rights-of-way; land sales and land
                           exchanges; grazing and range permits; and trespass. The process is managed in a
                           manner that promotes professionalism, objectivity, independence, leadership, and
                           accountability.
                           Examples of the requirement for an appraisal/valuation program are found in the Code of
                           Federal Regulations (CFR). For example, 25 CFR Part 162, Leases and Permits, states
                           that Interior "must determine the fair annual rental of the land prior to our grant or
                           approval of the lease... [and] fair annual rental may be determined by competitive
                           bidding, appraisal, or any other appropriate valuation method."( 162.211) Similarly, 25
                           CFR Part 166, Grazing Permits, states: "An appraisal can be used to determine the rental
                           rate of property. The development and reporting of the valuation will be completed in
                           accordance with the Uniform Standards of Professional Appraisal Practices (USPAP)."
                           (166.401)
                           Accomplishments and Completions
                           1.  A primary impetus of appraisal reform has been to ensure the integrity of the
                                valuation process by establishing an appraisal program that promotes
                                objectivity, independence, professionalism, leadership, accountability and
                                oversight.
                                On March 12, 2002, the Secretary of the Interior realigned Indian trust lands
                                valuation and appraisal functions by delegating "the authority necessary" to
                                carry out the functions to the Special Trustee for American Indians and
                                establishing an Office of Appraisal Services (OAS) in the Office of the
                                Special Trustee for American Indians (OST). As stated in the Secretarial
                                Order, "The realignment will move the lands valuation and appraisal process
                                from the BIA, which is responsible for other realty activity, and ensure the
                               independence, accountability, and oversight of the Indian trust lands valuation
                               and appraisal staff."



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                           Eleventh Report to the Court
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                                On June 16, 2002, the appraisal staff was transferred from BIA regional
                                supervision to the Office of the Special Trustee for American Indians, where
                                they reported through 12 Regional Appraisers to the Chief Appraiser.
                                On August 20, 2002, the Acting Special Trustee re-delegated to the
                                Chief Appraiser all authority necessary to carry out Indian lands
                                valuation and appraisal functions, which include:
                                              The initiation, completion, and review of Indian land
                                              valuation and appraisal reports, technical appraisal reviews,
                                              and final appraisal approval authority.
                                              Providing expert testimony for judicial and administrative
                                              hearings concerning Indian trust appraisals, consistent with
                                              Departmental policies and procedures.
                                              Maintenance of certified general appraiser credentials for
                                              the Office of Appraisal Services personnel.
                           Though independent in all appraisal matters, the Chief Appraiser must adhere to
                           OST and DOI personnel, budget, procurement, travel, credit card and other
                           policies and procedures. The Special Trustee directed the Chief Appraiser to have
                           certain policies and communications approved by senior management in advance
                           of implementation or dissemination. The Chief Appraiser is expected to keep
                           senior management informed on key matters, including significant appraisals and
                           workload. For these purposes, on June 27, 2002, the Special Trustee directed that
                           for the remainder of Fiscal Year 2002 the Chief Appraiser would report to the
                           Acting Assistant Special Trustee (Chief of Staff). This arrangement was
                           supported by the Court Monitor at the OST Senior Managers' Meeting in
                           Scottsdale, Arizona, in March 2002.
                           On September 30, 2002, the Acting Special Trustee directed that beginning
                           October 1, 2002, the Regional Appraisers would report directly to the Acting
                           Assistant Special Trustee. There is no change in the Chief Appraiser's delegated
                           authority, as the Senior Appraiser, to review Indian lands valuation and
                           appraisals.
                           OST intends to contract with an outside professional organization such as The
                           Appraisal Foundation to evaluate the appraisal function and the Office of
                           Appraisal Services. This is expected to be completed by the end of the second
                           quarter of calendar year 2003 to coincide with the roll-out of the "To-Be" process.





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                           2.  Additional objectives in the reform of Indian land appraisal include
                                ensuring timely, comprehensive valuations; eliminating backlog through
                                staffing, training, and the introduction of new methods; developing a
                                tracking and monitoring system for appraisal requests; developing
                                nationwide comprehensive valuation practices in accordance with
                                USPAP; and updating or generating pertinent provisions in trust
                                program manuals that outline options and administrative procedures for
                                ensuring the timely completion of appraisals.
                                The centralization of appraisal under a national office (whereas formerly there
                                were 12 regionally directed offices) has not only enhanced the professional
                                independence of the appraisers but also increased the flexibility of the
                                appraisal program to address localized workload. Now that the appraisal
                                function is centralized, senior management is taking initiatives to compile
                                comprehensive national workload data to address regional imbalances and to
                                assess and eliminate backlogs. Teams were organized in three instances
                                during the reporting period to assist with accumulated workload at the
                                Blackfeet and Wind River Agencies and in Alaska.
                                Previous reports discussed a backlog of appraisals at the Blackfeet Agency.
                                The Blackfeet Reservation consists of 1.5 million acres, approximately
                                658,000 acres allotted and 312,000 acres in tribal trust. In this reporting
                                period, a team of OAS appraisers from various regions traveled to the
                                Blackfeet Reservation and, according to the team leader's report, "completed,
                                reviewed and approved 405 [appraisal] reports." In his report for July-
                                September the Regional Appraiser reported that, "after 7 years [the backlog] is
                                under control."
                                The Southwest Regional Appraiser led a team at Wind River Agency in
                                September. The Wind River Reservation consists of 2.68 million acres and
                                has 101,000 allotted acres and 1.7 million acres in tribal trust. According to
                                his report, "The team cleaned up about 250 backlogged appraisal requests that
                                had been identified by the Agency to be high in priority." Appraisal reports
                                were completed for 152; the remaining 98 requests were cancelled.
                                In August, three appraisers from various regions assisted the Alaska Region.
                                After required Bear Safety, Firearms Certification (appraisers in Alaska carry
                                shotguns when in the bush), and Aircraft Safety classes, the team inspected 55
                               properties.
                                A number of long-standing vacancies have been addressed. The Alaska
                                Regional Appraiser position has been filled. The Eastern Regional Appraiser
                               position, vacant six years, was advertised during the reporting period. The
                                Pacific Northwest Regional Appraiser position was filled by the transfer of the
                               Regional Appraiser from the Navajo Region. At present the Navajo Regional

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                           Eleventh Report to the Court
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                                Appraiser position is filled by an individual on detail from the Southwest
                                Region. The Navajo vacancy should be advertised in November.
                           Delays/Obstacles
                           Final plans for structuring the Office of Appraisal Services and implementation of
                           new appraisal information systems have been deferred pending the business
                           process modeling.
                           There has been some difficulty in obtaining consistent and comprehensive
                           workload metrics. Reports produced by each region for the July-September
                           reporting period are being analyzed to establish baselines nationally and for each
                           region. These will be reported next quarter.
                           The move of appraisal personnel from BIA to OST required the payment and closure of
                           existing BIA Bank of America Government travel card accounts and the opening of new
                           accounts for each employee. An inordinate delay in this changeover resulted in
                           appraisers not being able to travel for some weeks to complete field appraisal work.
                           Assurance Statement
                           I concur with the content of the information contained in this section of the 11 th
                           Report to the Court. The information provided in this section is accurate to the
                           best of my knowledge.
                           Date:  November 1, 2002
                           Name: Signature on File
                                    Kenneth F. Rossman
                                    Acting Assistant Special Trustee for American Indians















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                           Eleventh Report to the Court
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                              VI.  BUREAU OF INDIAN AFFAIRS
                                    A. FRACTIONATION
                           Introduction
                           Fractionation of Indian land occurs when land allotted to an Indian individual is inherited
                           by several generations of the original allottee. As the land is passed from one generation
                           to the next, more and more heirs inherit undivided interests.
                           Fractionation of Indian trust and restricted lands has a long history stemming from the
                           Federal Indian policy of the 19th
                                                                    Century. Fractionation is a complex and potentially
                           emotionally charged issue due primarily to the cultural, historical and family association
                           of the present Indian owners with the original owners of those lands held in trust by the
                           United States or subject to a restriction against alienation by the Secretary of the Interior.
                           Both Congress and the Department of the Interior (DOI) are attempting to address this
                           complex issue. Upper management within DOI has taken an active role in seeking
                           solutions to this critical problem. The opportunity offered by Indian Land Consolidation
                           Act and the Amendments of 2000 (ILCA) is important to the solution of fractionated
                           ownership of Indian land. Additional ways of streamlining the ILCA process are being
                           considered.
                           Accomplishments and Completions:
                           Indian Land Consolidation Program (ILCP)
                           The goal of the ILCP is to acquire small fractional interests in trust and restricted lands
                           owned by individual Indians and consolidate the interests in the Indian tribe on whose
                           reservation the interest is situated in order to lessen the number of owners. The ILCP is
                           presently operated in two Bureau of Indian Affairs (BIA) Regions. There are five
                           reservations in the Midwest Region and one reservation in the Great Plains Region
                           participating in ILCP. Each Region has an implementing official.
                           Implementing Official: Larry Mort'in, Regional Director, Midwest Region
                           Midwest Region, Great Lakes Agency, is winding up the first three years (1999-2002) of
                           the pilot project in Indian land consolidation first authorized by Congress in 1999. The
                           objective is to purchase as many of the fractionated interests on five reservations as
                           quickly as possible. Accomplishments include:
                                *   Through September 2002 more than 47,000 interests were acquired (3,034 for this
                                    reporting period). On average, between 750 and 1,000 interests were purchased
                                    per month throughout the past three years. The project maintains a consistent
                                    stream of applications in process for approximately $1 million in purchases at any
                                    one time.

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                           Eleventh Report to the Court
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                                   Through the pilot project, the BIA purchased interests on the allotments on five
                                    reservations. More than 42,000 of the 47,000 interests purchased have been those
                                    that are 2% or less of the undivided total of the allotment.
                                   Experience shows that expansion to other reservations would allow persons
                                    owning small multiple interests on multiple reservations to be totally removed
                                    from the Department of the Interior workloads in accounting and probate. The
                                    first three reservations in the pilot were Chippewa Reservations. The Indian
                                    owners on these three reservations have inherited small interests from relatives on
                                    nearby Chippewa Reservations including the Red Cliff Band of Chippewa in
                                    Wisconsin, Keweenaw Bay Indian Community in Michigan and Fond du Lac
                                    Band of Chippewa, in Minnesota. To eliminate the Department's responsibility
                                    for administration and probate for these remaining interests of earlier sellers, their
                                    interests on the expansion reservations were purchased as well.
                           Implementing Official: Cora Jones, Regional Director, Great Plains Region
                           A second pilot ILCP project was instituted at the Great Plains Region for the Rosebud
                           Reservation. This is the first year of the ILCP at the Great Plains Region and due to
                           delays associated with the distribution of the FY 2002 funding it is in the initial process
                           of implementing its pilot. It utilized the funding to commit three Full Time Employees to
                           the project. As a result, considerable progress has been made on the development of
                           internal processes to implement the project.
                           Agency staff is working on developing draft protocols for review and concurrence by the
                           Great Plains Region. The processes include: PC-based databases system to distribute
                           proceeds of the sale, methods for updating agency records after sale completion, and sale
                           tracking system. The databases include a listing of potential sellers, a listing of current
                           land sale applications, and a listing of purchases. The Agency has contracted for
                           assistance in this effort.
                           The following new activities associated with the implementation are:
                                   Develop draft Standard Operating Procedures (SOP) for the distribution of estates
                                    affected by the Youpee decision.
                                   Collaborate with the Rosebud Sioux Tribe to develop a cooperative agreement to
                                    define the Tribe's role in the consolidation project.
                                   Collaborated with the Tribal Land Enterprise Board of Directors to identify 42
                                    targeted tracts and continue the review of an additional 58 tracts. The goal is to
                                    purchase thc individual interests and obtain 100% tribal interest. These tracts
                                    may provide future economic development opportunities for the Tribe.


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                           Eleventh Report to the Court
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                                   Implement a database to track 4,000+ applications of individuals who wish to sell
                                    their interests.
                                   Develop SOP for the ILCP draft manual and reconcile agency records for the
                                    tracts targeted for purchase.
                                   Develop SOP for the landowner interest inventory. The inventory will become
                                    part of the tracking database for this project.
                                   Reconcile land interest inventory between agency records and the certified Title
                                    Status Reports (TSRs).
                                   Complete reconciliation of 15 targeted tracts.
                                   Identify 250 additional owners/estates in the 15 targeted tracts as a result of
                                    Youpee re-distribution.
                                   Reconcile additional tracts to determine if the identified owners have other
                                    interests in order to make offers to purchase their other interests in lands located
                                    on the Rosebud Reservation.
                                   Coordinate with the Office of Trust Funds Management (OTFM) to create a
                                    process to timely disburse the sale proceeds.
                                   Request and receive a Reservation-wide Mineral Appraisal from the Bureau of
                                    Land Management (BLM).
                           Current Status:
                           Midwest Region:
                                   Some interests greater than two percent are being purchased as permitted by
                                    ILCA.
                                   BIA commissioned a study to analyze the land consolidation project for the
                                    purposes of improving the program. The study was contracted to Booz Allen
                                    Hamilton (BAH) and was completed in April 2002. The BAH recommendations
                                    should be considered prior to deploying the program across the BIA. To that end,
                                    the Midwest Region has formed a Land Consolidation Project Team to develop
                                    goals and objectives which will consider the recommendations in the BAH report.
                                    The team is working with the OPM's Western Management Development Center
                                    to develop a team approach in addressing the BAH recommendations.
                                    Additionally the team will address the Strategic Plan for Project expansion as one
                                    of its objectives.

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                           Eleventh Report to the Court
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                           Great Plains Region:
                           Personnel in the Great Plains Region are currently:
                              Continuing preparation of draft for the Region's ILCP plan and procedures manuals.
                              Analyzing statistical information to simplify the implementation process and the
                                purchase of interests utilizing the Management, Accounting and Distribution (MAD)
                                system.
                              Continuing to establish draft protocols for the implementation of the project.
                              Continuing to collaborate with the Rosebud Sioux Tribe and Tribal Land Enterprise
                                to develop a cooperative agreement with the Tribe and to identify targeted tracts.
                              Developing position descriptions for two temporary positions to employ individuals
                                with land and resource experience.
                              Continuing to reconcile estates affected by the Youpee decision focusing efforts on
                                the targeted tracts.
                              Reconciling additional tracts in which potential sellers may own interests.
                              Contracting for assistance with the posting of probates and reconciling of estates
                                affected by the Youpee decision.
                              Developing SOP for contractors to follow in the posting and reconciling efforts.
                              Identifying a process for acquiring land interests using the MAD system for
                                accounting and appraising and recording ownership changes.
                              Developing a software module to provide information on land values to assist in
                                determining the current fair market value of land interests.
                              Obtaining a report of all landowners owning interests on the Rosebud Reservation.
                              Facilitating the potential purchase of all of the sellers' interests with the goal of
                                reducing the number of Individual Indian Monies (IIM) accounts and future probates.






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                           Eleventh Report to the Court
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                           Delays and Obstacles:
                           Midwest Region:
                              The possibility of a lengthy Continuing Resolution from Congress will create a
                                serious problem for the program because it will not have the cash flow to purchase
                                significant numbers of interests. Another obstacle identified is the lack of a defined,
                                consistent process for budget distribution.
                           Great Plains Region:
                              Need an increase in funding for administrative costs.
                              Must complete redistribution of estates affected by the Youpee decision to ensure that
                                all of the seller's interests in the tracts are purchased.
                              Need flexibility to acquire an individual's interests on other reservations in addition
                                to seller's interests on the Rosebud Reservation in order to significantly reduce the
                                number of owners, IIM accounts and probates.
                              Establish a minimum purchase price. If a minimum purchase price is established
                                above the appraised value, it will present an appealing sale incentive to landowners.
                                An ILCP policy needs to be issued to set a minimum purchase price by interest or
                                seller. To date, Rosebud Agency has identified over 3500 surface interests with a
                                value of less than $1.00.
                              Lack of mineral activity generates no mineral income for the Indian landowners.
                                According to BLM, the minerals have very little value. The purchase of such mineral
                                rights would assist in eliminating and minimizing the IIM accounts and future
                                probates.
                              Train contractor to perform tasks.
                              Provide quality assurance on work performed by the contractor.
                              Require development of SOP for contractor to utilize to perform work.








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                           Eleventh Report to the Court
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                           Assurance Statement:
                           I concur with the content of the information contained in the Fractionation section of the
                           11 th
                                 Report to the Court. The information provided in this section is accurate to the best
                           of my knowledge.
                           Date:  October 29, 2002
                           Name: Signature on File
                                    Larry Morrin, Regional Director
                                    Midwest Region

                           Date:  October 30, 2002
                           Name: Signature on File
                                    Cora Jones, Regional Director
                                    Great Plains Region






















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                           Eleventh Report to the Court
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                                    B.  OFFICE OF TRUST POLICIES AND PROCEDURES
                           Introduction
                           The goals of this project are to -
                              Develop guidance for the Department's trust responsibilities;
                              Coordinate with appropriate program offices to systematically identify and update
                                regulations to ensure that the official policies comport with the trust principles;
                              Coordinate with appropriate program offices to develop or revise program manuals
                                and handbooks so that internal guidance and operational procedures reflect current
                                policies and technologies;
                              Coordinate with appropriate program offices to propose changes in legislation to
                                modernize Indian trust statutes; and
                              Assist trust management offices on an ongoing basis to identify and rectify problems
                                in their policies and procedures.
                           Accomplishments and Completions
                           Repeal of Outdated Regulations - On August 26, 2002, a final rule was published in
                           the Federal Register that removed a number of outdated regulations that are identified
                           below.
                                    Part 112 - Pro Rata Shares of Tribal Funds
                                    Part 116 - Trusts for the Five Civilized Tribes
                                    Part 121 -Osage Judgment Funds
                                    Part 124 - Alaska Native Fund
                                    Part 125 - Payment of Sioux Benefits
                                    Part 154 - Osage Roll, Certificate of Competency
                                    Part 156 - Reallotment of Lands to Unallotted Indian Children
                                    Part 178 - Resale of Lands within the Badlands Air Force Range
                                    Part 243 - Reindeer in Alaska
                           25 CFR 2 - Appeals from Administrative Actions - Revisions to current appeal
                           regulations are proposed for the following reasons:
                                1.  BIA must refrain from implementing most decisions while an appeal is pending;
                                2.  Anyone whose interests might be affected by a BIA decision can file an appeal
                                    regardless of whether those interests are intended to be protected by law or
                                    regulation; and
                                3.  The time to file an appeal is subject only to the statute of limitations ifBIA fails
                                    to provide written notice of appeal rights.


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                           Eleventh Report to the Court
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                           The proposed revisions to the appeal regulations address these and other issues. In mid-
                           August, the Office of the Solicitor completed its review of the proposed revisions. A
                           draft Notice of Proposed Rulemaking has been prepared and is undergoing internal
                           review.
                           Staffing of the Policies and Procedures Project
                           Position descriptions were written that will be used to staff a trust policies and procedures
                           organization to be located in the Office of the Special Trustee for American Indians. This
                           organization will replace the Policies and Procedures subproject that had been in BIA. A
                           vacancy announcement for a Director is expected to be made during thc next reporting
                           period and a director hired to lead the work of this office.
                           Current Status
                           Statutory Revisions:
                           Bureau of Indian Affairs/Office of the Special Trustee
                           Review of Title 25, United States Code - On June 11,2002, the Director, Office of
                           Indian Trust Transition, signed a letter to all Tribal Leaders providing a copy of Trust
                           Policies and Procedures (TPP) staff recommendations for repealing or amending
                           numerous provisions of Title 25. This represents the initial step in the consultation
                           process. At the request of the National Congress of American Indians (NCAI), the
                           deadline for tribal comments was extended from August 15, 2002 to November 15, 2002.
                           While only a few responses were received during this reporting period, those who did
                           comment indicated support for the many of the proposed changes. Additional comments
                           will be received during consultation with Tribes and other interested parties, prior to
                           amendments being published.
                           Bureau of Indian Affairs
                           25 CFR 161 - Navajo Partitioned Lands Grazing Permits - The Navajo Nation
                           completed its internal review of the draft regulations and requested the BIA Navajo
                           Region to coordinate a follow-up meeting with TPP staff. As both of the TPP staff who
                           worked on these regulations have left the project, the Office of Trust Responsibilities
                           (OTR) was asked to assume responsibility for this effort. OTR staff plan to meet with
                           tribal and regional office representatives to complete the review requirements.
                           25 CFR 124 - Deposits of Proceeds of Lands Withdrawn for Native Selection under
                           the Alaska Native Claims Settlement Act - As previously reported, TPP staff
                           completed a draft revision of Part 124 and forwarded the draft to OTFM for its review
                           and comment. The Solicitor's Office provided oral comments on the draft. Revisions
                           were submitted to the BIA Office of Trust Policies and Procedures.


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                           Eleventh Report to the Court
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                           25 CFR 162 Subparts C and D - Residential Leases and Business Leases - On June
                           5, 2002, the Director, Office of Trust Responsibilities, sent the draft regulations to all
                           BIA Regional Directors and to NCAI asking for comments by July 8, 2002. On July 30,
                           2002, the final BIA draft for the Residential and Business Lease Regulations, which
                           included consideration of comments received on the initial draft, was sent to NCAI, Inter-
                           Tribal Monitoring Association (ITMA) and the BIA Regional Offices for distribution to
                           the tribes. On September 10, 12, and 24, 2002, tribal consultation sessions were held to
                           receive comments on the final BIA draft for Residential and Business Lease Regulations.
                           The target date for publication of the proposed regulations in the Federal Register for
                           public comment is January or February of 2003. The comment period is planned to run
                           for 90 days, and the Final (Rule) publication is scheduled for July or August of 2003.

                           Energy Initiatives -- In response to the Administration's goal of increasing domestic
                           supplies of energy, the BIA established an Energy Planning Group, which held an Indian
                           Energy Summit in December 2001 in Denver, Colorado (reported in the 8 th
                                                                                                                         Report to the
                           Court). The group is continuing to consult with Tribes for recommended actions to
                           enhance energy development in Indian country. In connection with the Summit, the BIA
                           is also evaluating energy-related program areas for regulatory revision. During this
                           reporting period, TPP staff sent recommended revisions to Part 216--Surface
                           Exploration, Mining, and Reclamation to the Division of Energy and Minerals and to
                           OTR for their consideration. An intra-Departmental team with representatives from BIA,
                           BLM, and OSM are reviewing the recommended revisions, with a target date of March
                           2003 for proposed rulemaking on the revisions.
                           Minerals Management Service
                           As previously reported, the MMS proposed rule on the valuation of oil produced from
                           leases on Indian trust lands is under review by Office of the Solicitor. There is no firm
                           estimate as to when the review will be completed.
                           Internal Program Guidance
                           Agriculture and Range Program (Grazing Permits) Handbook - OTR organized a
                           large work group composed of BIA employees and tribal representatives to update the
                           agriculture and range program handbook. The target date is January 2003 for the
                           completion of the initial draft handbook and distribution to the field for review and
                           comment.
                           NEPA Compliance Handbook - A draft handbook was prepared and circulated to the
                           field for review and comment. At this time, comments are still forthcoming. The target
                           date for review and analysis of comments is January 2003.
                           Financial Conflicts of Interest - The 1994 amendments to the Ethics in Government Act
                           amended Title 18 U.S.C. (Crimes and Criminal Procedures) in Chapter 11 (Bribery,
                           Graft, and Conflicts of Interes0 and added within the section describing "acts affecting a

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                           Eleventh Report to the Court
                           November 1, 2002


                           personal financial interest" those activities that affect the financial interests of the Indian
                           tribe in which the employee or the employee's spouse is a member. During this reporting
                           period the Department's Ethics Office advised the TPP staff that the Office of
                           Government Ethics (OGE) was accepting proposed statutory amendments from agencies
                           through August 2002. Staff from the Ethics Office held a preliminary meeting with OGE
                           during the week of June 17, 2002. There will be further meetings with OGE before the
                           legislative package is finalized.
                           Forestry Program Manual - In July 2002, the Division of Forestry submitted the final
                           draft forestry handbook to the Office of Audit and Evaluation, BIA. After their review
                           and approval, it will be distributed to the field.
                           IAM Manual
                           TPP and Solicitor's Office staff worked on revisions to Part 101 of the Indian Affairs
                           Manual, Individual Indian Money Accounts. The current manual was issued in August
                           2000 prior to issuance of final regulations governing Trust Funds for Tribes and
                           Individual Indians (25 CFR 115). The revisions are designed to reflect the changes made
                           by the new regulations.
                           TPP distributed the proposed revisions to the field on August 30, 2002, with a deadline of
                           September 30, 2002, for comments. A recommendation to extend time for comments is
                           expected in the next reporting period.
                           Real Estate Services Program Handbook - The drafting team met during the week of
                           June 17, 2002, in Washington, DC, to complete work on a draft leasing handbook.
                           Comments regarding the final draft of the Leasing and Permitting Handbook were
                           received from the Regional Offices in August and September 2002. Real Estate Services,
                           OTR, is in the process of updating the draft handbook to incorporate appropriate changes
                           recommended by the field. The target date for completion and national distribution of the
                           final handbook is by the end of next quarter.
                           Delays/Obstacles
                           The Office of Trust Policies and Procedures is without staff. The position for Director
                           will be advertised and should be filled during the next reporting period. At that time staff
                           will be hired. The Trust Policies and Procedures projects will be transferred to a new
                           office in OST once a Director is hired.







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                           Eleventh Report to the Court
                           November 1, 2002


                           Assurance Statement
                           I concur with the content of the information contained in the Trust Policies and
                           Procedures section of the 11 th
                                                                 Report to the Court. The information provided in this
                           section is accurate to the best of my knowledge.
                           Date:  November 1, 2002
                           Name: Signature on File
                                    Ross O. Swimmer
                                    Director, Office of Indian Trust Transition






























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                           Eleventh Report to the Court
                           November 1, 2002

                             VII.  ACRONYMS

                           A-130          OMB Circular A-130
                           BIA             Bureau of Indian Affairs
                           BIAM          Bureau of Indian Affairs Manual
                           BIAINVs      Bureau of Indian Affairs Inventories
                           BITAM        Bureau of Indian Trust Assets Management
                           BLM            Bureau of Land Management
                           BOR            Bureau of Reclamation
                           BPM            Business Process Modeling
                           CAP            Corrective Action Plan
                           CD              Compact Disk
                           CDE            Critical Data Elements
                           CD&L          Chavarria, Dunne & Lamey LLC
                           CDS            Comparable Sales/Lease Data Base System
                           CGIS           Cadastral Geographic Information System
                           CIO             Chief Information Officer
                           CISSP          Certified Information Security System Professional
                           CLS             Case, Location, and Status Database
                           COPAS        Council of Petroleum Accounting Services
                           COTR          Contracting Officer's Technical Representative
                           COTS          Commercial Off-The-Shelf
                           CR              Continuing Resolution
                           CSEAT        Computer Security Expert Assist Team
                           D&T            Deloitte & Touche LLP
                           DCIA           Deputy Commissioner for Indian Affairs
                           DEMR         Division of Energy and Mineral Resources
                           DM             Departmental Manual
                           DMZ           Demilitarized Zone
                           DOI             Department of the Interior
                           DOIU          Department of the Interior University
                           DOJ            Department of Justice
                           DOP            Desk Operating Procedures
                           DQ&I          Data Quality and Integrity
                           EA              Enterprise Architecture, Environmental Assessment
                           EAP            Enterprise Architecture Planning
                           EDS            Electronic Data Systems
                           E&Y            Ernst & Young LLP
                           FAIR           Federal Activities Inventory Reform
                           FEDBIZOPS  Federal Business Opportunities
                           FIPS            Federal Information Processing Standard
                           FIRREA       Financial Institutions Reform, Recovery and Enforcement Act
                           FOGRMA     Federal Oil and Gas Royalty Management Act
                           FPPS           Federal Personnel and Payroll System

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                           Eleventh Report to the Court
                           November 1, 2002

                           G&B            Government & Business Solutions Inc.
                           GIS             Geographic Information System
                           GISRA         Government Information Security Reform Act
                           GPS             Global Position System
                           GSA            General Services Administration
                           HLIP           High Level Implementation Plan
                           HR              Human Resources
                           HRA            Historical Research Associates
                           IBM            Intemational Business Machines
                           IDEAS         Interior Department's Electronic Acquisition System
                           IDEF           Integration Definition for Function Modeling
                           IDP             Individual Development Plan
                           IEA             Interior Enterprise Architecture
                           IHS             Indian Health Services
                           IIM             Individual Indian Money
                           IITD            Individual Indian trust data
                           ILCA           Indian Land Consolidation Act
                           ILCP            Indian Land Consolidation Program
                           IRMS           Integrated Records Management System
                           IRS             Internal Revenue Service
                           ISC             Information Services Corporation
                           IT               Information Technology
                           ITAD           Indian Trust Accounting Division
                           ITM             Indian Trust Management
                           ITMA          Inter-Tribal Monitoring Association
                           IV&V          Independent Verification & Validation
                           KeyFile        Key File Document Imaging System
                           LAND          Land Titles Automated Network Delivery
                           LCPP           Land Consolidation Pilot Project
                           LRIS            Land Records Information System
                           LTM            Land Title Mapper
                           LTRO          Land Titles and Records Office
                           MAD           Management, Accounting & Distribution
                           MCPD         Management Control Plan Data Base
                           MCR           Management Control Review
                           MMS           Minerals Management Service
                           MOlD          Multiple Owner Identification
                           MRM          Minerals Revenue Management
                           NADCAP     Native Allotment Data Collection and Access Project
                           NAPHSIS     National Association for Public Health Statistics and Information Systems
                           NARA         National Archives and Records Administration
                           NCAI           National Congress of American Indians
                           NIST           National Institute of Standards and Technology
                           NORC          National Opinion Research Center at the University of Chicago
                           OAS            Office of Appraisal Services

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                           Eleventh Report to the Court
                           November 1, 2002

                           OCC            Office of the Comptroller of the Currency
                           OGE            Office of Government Ethics
                           OHA            Office of Hearings and Appeals
                           OHTA          Office of Historical Trust Accounting
                           OIG             Office of Inspector General
                           OIRM          Office of Information Resources Management
                           OITT           Office of Indian Trust Transition
                           OMB           Office of Management and Budget
                           OST            Office of the Special Trustee for American Indians
                           OTFM          Office of Trust Funds Management
                           OTR            Office of Trust Responsibilities, Office of Trust Records
                           OTRM         Office of Trust Risk Management
                           PAL            Performance, Acreage and Lease
                           PB               Personnel Bulletin
                           PTS             Probate Tracking System
                           QCs             Quality Controls
                           RFI             Request for Information
                           RMD           Risk Management Document
                           SAIC           Science Applications Intemational Corporation
                           SAL            Statement of Assurance Letter
                           SANS          System Administration, Networking and Security
                           SAT            Security Awareness Training
                           SDAs           Small Dollar Accounts
                           SME            Subject Matter Experts
                           SOL            Office of the Solicitor
                           SOP             Standard Operating Procedures
                           SRA            SRA International, Inc.
                           SSA             Social Security Administration
                           STIG           Standard Technology Implementation Guide
                           STRAC        State and Tribal Royalty Audit Committee
                           TAAMS       Trust Asset and Accounting Management System
                           TBA            Trust Board of Advisors
                           TFAS           Trust Funds Accounting System
                           TMIP           Trust Management Improvement Project
                           TPP             Trust Policies & Procedures
                           TRM            Technical Reference Model
                           TRO            Temporary Restraining Order
                           TS&P          Trust Systems & Projects
                           TSRs           Title Status Reports
                           USFS           United States Forest Service
                           USPAP         Uniform Standards for Professional Appraisal Practice
                           VA              Veterans Affairs
                           WAU           Whereabouts Unknown
                           WFP            Workforce Planning


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