Comment on SUTA

This is a wonderful start to ensure that tribes can obtain infrastructure funds, even in areas that providers (RUS borrowers) say the serve and I appreciate all of the work done on this particularly Jessica Zufolo, Janie Hipp and Eric Jensen, however I still see a few impediments and only have a few general comments. I wanted to share my thoughts with you all I honest think the best and quickest way to fix this it to amend the Farm Bill to ensure that tribes can always get a waiver of the non duplicating policy when they apply to serve their areas, this keeps with the government's current Indian policy My comments on the proposed SUTA Regulations, comments are due Dec 13, 2011 First the tribes will have to compete with the other trust area THE SUTA fails to recognize the governments trust responsibility toward tribes in that it lumps the other trust areas in with the tribal trust areas. In keeping with the federal policy of promoting self-sufficiency among the tribes should have priority in funding when only proposing to serve within their own reservation . In the regulations it is not clear what the Agency will do when a tribal reservation boundaries contain fee land within them. As you may know some tribes have a lot of fee land within their boundaries. I suggest the agency affirmatively proclaim all land with reservation boundaries qualify for this program. 17000.107 I think the burden of proof should be on the service providers to show that they are actually providing service at reasonable prices, not on the tribe to prove they are not. I think the data requirements are burdensome. Delete 1700.108a3ii I don’t see the need for the tribal areas have to show data documenting significant health risks due to fact that a significant proportion of the community is unserved. Finally, I would like some assurances that that these applicant reviewers have some tribal training before reviewing these types of applications. Tribes area often not treated fairly when reviewers are unfamiliar with the special legal status of tribes as sovereign nations