I still have concerns related to administrative plans. These concerns should have been addressed prior to the finalization of the Land Buy-Back Program plan. These concerns are:

1) how were the initial project tribes were selected in comparison to the tribes who actually experience the greatest individually owned highly fractionated interests;

2) the diminishment of available funds if BIA establishes central clearing houses which require initial startup costs, time to fill new positions, if current employees are selected for these positions, the backfill to pick up the current workload due to vacancies. There would be promotions for some individuals, relocation costs which also include those employees being unable to contribute immediately due to transition on both ends of their old and new postions;

3) the Land Title Recording Office’s ability to be timely in providing certified title status reports to ensure that true and correct ownership conveyances will occur;

4) the impact to provide other title and appraisal services throughout the organization timely while the Land Buy Back Program is being administered.