the NIGC indicated that it needed to verify (i.e., double check) that quorum requirements were satisfied during the approval of such ordinance or resolution, or amendment thereto. While this proposed requirement may not appear overly burdensome on its face, we find the reasons behind this part of the Proposed Rule offensive to traditional notions of tribal sovereignty and insulting to the integrity and competency of Tribal governments to interpret their own laws. As we understand it, this Proposed Rule boils down to attempting to grant the NIGC, an arm of the United States Federal Government, the authority to interpret Tribal law in order determine whether each and every sovereign Tribal government that submits a gaming ordinance or ordinance amendment has followed its own duly enacted laws. However, as provided in greater detail in the excerpt below, a federal agency has no place in interpreting laws of Tribal governments except as specifically and narrowly required by Congress. As published on the Interior Office of Hearings and Appeals webpage: Tribes have primary authority to interpret their own law and where the tribe has put forth a reasonable interpretation of its law, the Bureau must defer to that interpretation. Paula Brady, Leta K. Jim, and Patricia Stevens v. Acting Phoenix Area Director, 30 IBIA 294 (1997); Shakopee Mdewakanton Sioux Community v. Acting Area Director, 27 IBIA 163 (1995). Neither the Bureau nor the Solicitor's Office should undertake to interpret tribal law without first considering whether the tribe had arrived at an interpretation of its own. Paula Brady. The Bureau should avoid interpreting tribal law unless there is a clear necessity for it to do so. Keweenaw Bay Indian Community v. Minneapolis Area Director, 29 IBIA 72 (1996); Sandra Maroquin v. Anadarko Area Director, 29 IBIA 45 (1996); Parmenton Decorah, et al. v. Minneapolis Area Director, 22 IBIA 98 (1992). In furthering the doctrines of tribal sovereignty and self-determination, the Bureau recognizes the right of tribes to interpret their own laws and gives deference to a tribe's interpretation of its own law. San Manuel Band of Mission Indians v. Sacramento Area Director, 27 IBIA 204 (1995); Donna Van Zile & James Crawford v. Minneapolis Area Director, 25 IBIA 163 (1994); Henry P. Rhatigan v. Muskogee Area Director, 21 IBIA 258 (1992); United Keetoowah Band of Cherokee Indians in Oklahoma v. Muskogee Area Director, & Joe Grayson, Jr., & Pam Thurman Jumper, Muskogee Area Director, 22 IBIA 75 (1992); James C. Greendeer v. Minneapolis Area Director, 22 IBIA 91 (1992). Once the tribe has offered a reasonable interpretation of its own law, the Bureau must defer to it even though the Bureau may also offer an equally reasonable interpretation of the tribal law. San Manuel Band of Mission Indians v. Sacramento Area Director, 27 IBIA 204 (1995) citing Shakopee Mdewakanton Sioux Community v. Acting Minneapolis Area Director, 27 IBIA 163 (1995). "Where a Secretarial election is to be conducted, BIA has the authority to make an independent interpretation of tribal law concerning voter eligibility, although it
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