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National Tribal Water Council
PO Box 15004
Flagstaff, AZ 86011-5004
(480) 452-6774

Policy Response Kits


Policy Response Kits (PRK) are comprised of two types of responses depending on the nature of the proposed rulemaking action. The NTWC may provide a straight forward comment letter from the National Tribal Water Council on issues of concern that may potentially impact Tribes. Additionally, the NTWC may develop a PRK which includes a fact sheet, official NTWC comment letter and a template letter for Tribes to use in submitting their own comments. Below are links to comment letters by the NTWC on important USEPA and federal agency proposed rules.

NTWC crafted and released Policy Response Kits on the following USEPA or federal agency actions:

EPA and the Army Corp of Engineers (ACE) Proposal to Revised the Definition of “Waters of the United States”
The National Tribal Water Council submitted a comment letter in response to EPA and ACE’s proposal to revise the definition of the Waters of the United States (WOTUS), published in the Federal Register on February 14, 2019. The NTWC comments focuses on the potential implications of a revised definition of WOTUS for waters on tribal lands. Submitted April 1, 2019. Below is the PRK for this proposed rule.
  1. Fact Sheet
  2. NTWC Comment Letter
  3. NTWC Webinar Recording
  4. NTWC Template Letter for Tribes
EPA’s Early Engagement on Updating and Improving Implementation of Clean Water Act Section 401
The National Tribal Water Council (NTWC/Council) accepted an early engagement invitation from the Environmental Protection Agency (EPA) to respond by submitting a letter to the EPA as part of early input into the Agency’s interest in updating and improving implementation of the Clean Water Act § 401.
Click here to read NTWC’s early engagement comment letter

CWA § 404(g) State and Tribal Dredge and Fill Permit Regulatory Revision
The National Tribal Water Council (NTWC/Council) participated in early engagement with the U.S. EPA by providing early comments on EPA’s forthcoming proposal to revise the Clean Water Act (CWA) § 404(g) regulations, which EPA has stated is intended to provide clarity on the requirements for state and tribal assumption of the § 404(g) permitting program as well as to foster greater interest by authorized tribes and states in assuming the authority. These are NTWC’s comments during early engagement and intends to provide additional input once EPA publishes proposed revisions to the § 404(g) regulations in the Federal Register.
Click here to read NTWC's comment letter.

EPA National Water Program Core Measures
In response to the U.S. Environmental Protection Agency’s (EPA) request for tribal feedback on streamlining its National Water Program Measures (NWPM), the National Tribal Water Council (NTWC) provided cursory comments. The proposed streamlining is implemented through EPA’s Lean Management System (ELMS), and is designed to reduce the metrics, which tracks progress of water program measures. In addition to providing cursory comments, the NTWC requested an extension of the comment period.
Click here to read NTWC's comment letter.

GAP Guidance Comment Letter
The National Tribal Water Council (NTWC) submitted comments and recommendations to improve the content and implementation of the U.S. Environmental Protection Agency (EPA) 2013 General Assistance Program (GAP) Guidance document, referred to as the Guidance. The NTWC provided recommendations to assist EPA in achieving a nationally consistent capacity development framework for both EPA and tribes. The comment letter emphasized the strength of the GAP Program is the flexibility provided to Indian tribes to plan, and develop a reservation specific approach to environmental protection, consistent with tribally-identified environmental priorities.
Click here to read NTWC's comment letter.

CWA Coverage of “Discharges of Pollutants” via Direct Hydrologic Connection to Surface Water
The National Tribal Water Council (NTWC) submitted comments to the U.S. Environmental Protection Agency in response to a request for Comment on Clean Water Act Coverage of “Discharges of Pollutants” via a Direct Hydrologic Connection to Surface Water, 83 Fed. Reg. 7126 (Feb. 20, 2018). NTWC’s comments address how such discharges of pollutants impact surface water quality for American Indian Tribes and Alaska Native Tribes (also known as Alaska Native Villages). Submitted May 18, 2018
Click here to read NTWC's comment letter.

Environmental Protection Agency’s “Draft Summary of Potential Effects to Clean Water Act Programs for Tribal Waters”
The National Tribal Water Council (NTWC) submitted comments for consideration on the U.S. Environmental Protection Agency’s (USEPA/EPA) “Draft Summary of Potential Effects to Clean Water Act Programs for Tribal Waters,” (“Draft Summary”). The NTWC understands that the purpose of the Draft Summary is to assist the EPA in consideration of the tribal water programs in light of the proposed rulemaking to revise the definition of "Waters of the United States" (WOTUS) under the Clean Water Act (CWA). Submitted April 13, 2018
Click here to read NTWC's comment letter.

Lead and Cooper Rule Revisions
The National Tribal Water Council (NTWC) provided comments on U.S. Environmental Protection Agency’s (USEPA/EPA) request for public comments on the Lead and Copper Rule Revisions (LCR) (Docket ID. No. EPA-HQ- OW-2018- 0007). The NTWC's comment letter addressed how the Lead and Copper Rule Revisions impact drinking water quality for Indian Tribes, which is the focus of the NTWC mission. Submitted March 16, 2018
Click here to read NTWC's comment letter.

EPA and the Army Corp's Proposal to Amend the Effective Date of the 2015 Rule Defining “Waters of the United States”
The National Tribal Water Council commented on EPA’s and the Department of the Army, Corps of Engineers’(together “the Agencies”) proposal, published in the Federal Register on November 22, 2017, to add an applicability date of two years to the 2015 Clean Water Rule (currently not in effect, due to a stay) because the new proposed applicability date will not accomplish the goals that the Agencies seek, and will instead unnecessarily exacerbate confusion and uncertainty regarding the implementation of the definition of “Waters of the U.S.” (WOTUS) rule, especially for WOTUS and other waters on tribal lands. Submitted December 13, 2017
Click here to read NTWC's comment letter.