TRIBAL COUNCIL

(AT LARGE)

Jesse “Jay” Taken Alive
Margaret M. Gates
Avis Little Eagle

Dave Archambault II

Joseph Meh

Jesse McLaughlin

Charles W. Murphy TRI

BAL COUNCIL

Chairman (DISTRICTS)

Adele M. White

Secretary Di

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Sharon Two Bears
Cannonball District

Henry Harrison
Long Soldier District

uane Claymore
Wakpala District

Kerby St. John

Kenel District

‘ol D. Crow Ghost
car Soldier District

Milton Brown Otter

Rock Creek District

January 28, 2011 Frank Jamerson Jr.

Running Antelope District

Samuel B. Harrison
Porcupine District

Ms. Tracie Stevens, Chairwoman
National Indian Gaming Commission
1441 L. St. N.W., Suite 9100
Washington, D.C. 20005

Re: Revision of existing Gaming Regulation and Promulgating New Regulations
Dear Chairwoman Stevens:

The Standing Rock Sioux Tribe would like to thank NIGC for your continued efforts to
include the Tribes on a government-to-government basis in providing comments and input
on the existing gaming regulations and being able to provide recommendations on
promulgating new regulations.

The Tribe would like to submit a few comments that we feel are important to the Tribe in
the revising of existing regulations. The Standing Rock Sioux Tribe believes that our
excellent working relationships and communication links that have been developed over
the year will continue to be a valuable tool in our regulatory duties. Listed below are a
few comments we would like to submit for the record during your consultation hearings.

REVISING EXISTING REGULATIONS

Part 542 Minimum Internal Control Standards for Class III Gaming

We are in support of NIGC’s efforts in continuing its recommendations for Class III
Minimum Internal Control Standards (MICS). The Tribe feels that the existing MICS
regulations that have been developed and implemented by the Tribes’ is sufficient and

does not require the added regulations to be developed by the respective States.

Part 543 Minimum Internal Control Standards for Class Il Games

BLDG. 1 NORTH STANDING ROCK AVE.:* P.O.BOX D * FORT YATES, NORTH DAKOTA 58538
PHONE: 701-854-7201 or 701-854-8500 * FAX 701-854-7299


We believe that revising the current 543 is necessary. The Tribe believes that a Tribal
Advisory Committee (TAC) should be assembled and this would provide the Tribe’s with
a communication link that the committee could use to advise NIGC. The membership of
a TAC committee should be diverse enough to adequately address the concerns of the
Revisions of Existing & Promulgating New Regulations

Page Two

larger operations and also the needs of non-profit, charitable and fund-raising operations.

Part 573 Enforcement

The Tribe strongly believes that this section should be revised as we feel that a Notice of
Violation (NOV) should be able to be withdrawn by NIGC, especially if a Settlement
Agreement can be effectively negotiated prior to it being penalized by hefty fines. We
believe that the Commission should consider new language that would allow the
Chairperson to render this decision on a case-by-case basis.

These are some of the comments that our Tribe would like to submit for your
consideration and we would like to thank you for the opportunity to address them.

Respectfully,
jedpook $

Charles W. Murphy, Chairman

Standing Rock Sioux Tribe