7:00PM Delaware Gaming Commission No. 1594 oP. 2

Jun. 22.

June 22, 2015

Jonodev O. Chaudhuri, Chairman
National Indian Gaming Commission
Department of the Interior

1849 C. Street NW, Mail Stop #1621
Washington, DC 20240

Dear Chairman Chaudhuri:

The Delaware Nation Gaming Commission would like to extend its appreciation for
working with the Tribes in requesting and considering comments. Along with engaging in
discussion on the four topics described in Notice of Consultation letter dated February 26, 2015.
Those topics are as follows:

* Updates to the NIGC’s Privacy Act regulations

* NIGC’s proposed National Environmental Policy Act (NEPA) manual that
includes a categorical exclusion fox the approval of management contracts

¢ Guidance for Class III minimum internal control standards (MICS)

« A proposed regulation through which the NIGC will give preference i in
Agency purchasing to Indian-owned businesses.

First of all, The Delaware Nation Gaming Commission has no objections with the
changes proposed in the updated NIGC’s Privacy Act regulations, therefore we concur.

The Delaware Nation Gaming Commission supports the position of NIGC proposed
NEPA manual that includes a category for exclusion for actions that normally does not require
either an environmental impact statement or an environmental assessment.

The proposed NIGC regulation for “Buy Indian Goods and Services” provides for giving
preference to Indian-owned firms for the acquisition and procurement of goods and services at a
fair market price. The Delaware Nation Gaming Commission has no objections to this provision,
as long as cost is still the lowest acceptable price.

Finally, with regard to Part 542, The Delaware Nation Gaming Commission strongly
disagrees with NIGC to withdrawing Part 542 from’ the regulations. As you already know the
Compact with the State of Oklahoma when approved by the people of Oklahoma, included
compliance requirements with Part 542 of the NIGC regulations or the Tribal Internal Controls
whichever is more stringent. It would be detrimental for our Tribe if the NIGC withdraws Part
542, possibly causing a violation as for as the State of Oklahoma is concern. Along with

P.O, Box 806 31064 SH 281 Anadarko, OK 73005
Phone 405-247-2292 Fax 405-247-9155



Jun, 22. 2015 7:00PM = Delaware Gaming Commission © No. 1594 P. 3

. Yeopening compact negotiations. with the State of Oklahoma for approval of Class III gaming. .
We. respectfully submit that the Chair of NIGC should not withdraw part 542 fiom our
regulations, We-believe that the NIGC should act to promote best practices for Indian gaming
regulation, assist tribal governments to. build strong tribal regulatory agencies, and Promote
voluntaty compliance with Indian gaming regulations.

Thank you. for your thoughtful consideration.

Sincerely,

Jeanne Mosely, Chairwoman .
Delaware Nation Gaming Commission _



Jun. 22. 2015 6:59PM Delaware Gaming Commission No. 1594 P.

(aaonooae Anadarko, Oklahoma 73005 D are A in a g at mM ING

To: Jonodev Chaudhuri, Charman From: Kay Busby
Fax: 202-632-7066 Pages: 3

Phone: Date: — 6/22/2015
Re: CG:

O Urgent O ForReview OPleaseComment (Please Reply (Please Recycle

® Comments:

Attached are our comments in response to your request dated May 6, 2015.
Thank you,

Kay Busby

Executive Director
Delaware Gaming Commission