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Identifying BIA Schools in EPA's Data Systems

Dec. 23, 2009 – The purpose of this document is to ensure consistent designation of so-called “BIA schools” and “BIE schools” in EPA data bases.  There are many schools (elementary, secondary and post-secondary) which are located within Indian reservations or on tribal lands.  The Bureau of Indian Affairs (BIA) and the Bureau of Indian Education (BIE) are bureaus within the U.S. Department of the Interior (DOI).  DOI provides support, including some funding, to these schools through the BIA and the BIE.   The schools are often referred to as “BIA schools,” “BIE schools,” or “tribal schools” depending on the speaker. 


EPA activities affecting these schools include inspections, compliance assistance activities and  enforcement actions which are reported into EPA data bases for tracking and accomplishment reporting purposes.  That reporting requires properly designating the ownership of the schools.  OECA has determined to designate these schools as “federal” or “federal facilities” for several reasons: 


      First, any facility operated by a federal department or agency, including the BIA and BIE, should be designated as a federal facility in EPA data bases. 

      Second, DOI publishes a Bureau of Indian Education National Directory listing many schools, including several boarding schools which are located near, but not on, Indian reservations.  Its latest edition is dated March 2009 and is found under “Directory” at  The National Directory lists which schools are within various BIE line offices.  The National Directory does not expressly say that the listed schools are owned by DOI, BIA or BIE nor does it expressly say that are owned by tribes or other entities. 

      Third, research on several colleges listed at the end of the National Directory reveal that they were “chartered” by a tribe; however the research does not establish that the tribes owned the colleges. 


Given (1) the information that DOI/BIA/BIE has a large role in funding and operating these schools AND (2) the lack of any information establishing that any other entities own them, OECA concludes that these schools should be designated as “federal” in EPA data bases.  However, if information is discovered which substantially shows that any such school is owned by some other entity, such as a tribe, a church, or a school district, it should be so designated in the EPA data base.


Other Related IPOD Documents

Federal Facilities - Final Guidance on Identifying Federal Facility Activities and Ownership in ICIS

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