iii. “Section 518.14 – For any revocation case, the Office of Self-Regulation has the burden to show just cause for revocation and must carry that burden by a preponderance of the evidence.” We find it appropriate to place the burden of proof on the Office of Self-Regulation to show why a tribe’s certificate should be revoked. However, this does not eliminate the conflict discussed previously. Provisions for recusal or some other means of eliminating due process concerns should be further explored. III. Conclusion We hope that these comments will be accepted in the collegial spirit with which they are submitted. We appreciate your consideration and hope these comments prove useful to the Commission in determining whether and to what extent revisions to the regulatory provisions discussed herein are warranted.
National Indian Gaming Association 224 2 nd Street, SE Washington, D.C. 20003
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