Abstract
The Department of the Interior's New Guidance on Off-Reservation Acquisitions of Land in Trust for Indian Gaming assumes that the principal value of Indian gaming is reservation employment. Although this assumption is mostly incorrect - Indian gaming operations, like state lotteries, are about public revenues, not jobs - off-reservation gaming can dramatically increase the number of public service jobs on Indian reservations. Indian gaming revenues are mostly expended on tribal services to tribal members, creating numerous public service jobs in tribal government. Off-reservation Indian gaming can also provide revenues for restoration of lands on Indian reservation, making up for limited public appropriations for land restoration. In many ways, off-reservation gaming is better for tribes than on-reservation gaming because it provides revenues but does not interfere with tribal culture and tribal communities. Interior's new policy is off base for these and other reasons explained more fully herein.
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