As an earlier court in this district put it, "[D]rafting imprecisions" and "apparent textual contradictions" "pervade the regulations" and "frustrate the Court's search for a steady place to get its footing." Maniilaq Ass'n v. Burwell, 170 F. Supp. 3d 243, 250–51 (D.D.C. 2016) ( Maniilaq II ). Deriving some order from the chaos, the Maniilaq II court offered two principles drawn from section 105(l ) and the implementing rules: IHS need not grant lease "compensation requests that [are] ‘duplicative’ [of funding already provided by the government] ... or [are] not ‘reasonable.’ " Id. at 255 (citing 25 C.F.R. § 900.70 and 25 U.S.C. § 5324(l )(2) ).

Because the Secretarial amount is capped at the amount IHS would have spent, IHS may "decline any proposal seeking funds in excess of that amount." Maniilaq Ass'n v. Burwell , 170 F.Supp.3d 243, 249 (D.D.C. 2016) (citations omitted). Although it has received $11,838.

Jamestown S'Klallam Tribe, 486 F. Supp. 3d at 85 (alteration in original) (quoting Maniilaq Ass'n v. Burwell (Maniilaq II), 170 F. Supp. 3d 243, 255 (D.D.C. 2016)).

See generally Defs.' Opp'n, ECF No. 60; see also Campbell, 311 F. Supp. 3d at 327. Rather, Defendants rely on Maniilaq Association v. Burwell, 170 F. Supp. 3d 243, 256 (D.D.C. 2016) ("Maniilaq II"), to support IHS' document requests.See Defs.' Opp'n, ECF No. 60 at 9 n.6.

The Court is persuaded by opinions holding that ISDEAA requires de novo review of the government's decision to reject a "final offer" from a tribe. See, e.g., Redding Rancheria v. Hargan, 296 F. Supp. 3d 256, 265 (D.D.C. 2017); Manilaq Ass'n v. Burwell, 170 F. Supp. 3d 243, 247 (D.D.C. 2016); Pyramid Lake Paiute Tribe v. Burwell, 70 F. Supp. 3d 534, 541-42 (D.D.C. 2014). Therefore, the Court will apply the familiar standard for summary judgment under Federal Rule of Civil Procedure 56.