Editor's Summary: In 1984, EPA became the first federal agency to adopt an Indian policy. Congress subsequently affirmed the policy by authorizing the Agency to treat Indian tribes as states under the SDWA, the CWA, and the CAA. EPA's adoption of a common-law inherent authority test to determine jurisdiction under the statutes spawned a treat-as-states (TAS) process that requires a detailed review of factual information about each tribe. In this Article, David Coursen examines the complexity of EPA's jurisdictional analysis and evaluates whether EPA's new TAS strategy will ultimately be successful in addressing delays in these decisions.