UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 2 290 BROADWAY NEWYORK, NY 10007-1866



## JUN 1

## 4 2011
The Honorable John P. deJongh, Jr. Office ofthe Governor Government House, 21-22 Kongens Gade Charlotte Amalie St. Thomas, VI 00802

Dear Governor deJongh:

Thankyou for yourNovember 10,2009recommendations on air quality designations for the revised National Ambient Air Quality Standards for lead throughout the US Virgin Islands. This letter is to notify you ofthe U.S. Environmental ProtectionAgency's (EPA's)preliminary decision to designate all ofUS Virgin Islands as unclassifiable/attainment, and to inform you ofour approach for completing the designations for the revised lead standards. Reducing levels oflead pollution is an importantpart ofthe EPA's commitment to a clean, healthy environment. Lead exposure can cause a range ofadverse health effects, most notably in children. Exposures to low levels oflead early in life have been linked to effects
on IQ, learning, memory, and behavior.

On October 15,2008,the EPA substantially strengthened the health-based or "primary"National AmbientAir Quality Standard by lowering it from 1.5 microgramsper cubic meter (J.!g/m3) - a level set in 1978

- to a level of0.15 J.!g/m3

. This stronger standard provides increased protection against adverse health effects associated with exposure to lead in at-risk groups, including children. To provide increased protection against lead-related environmental and other welfare effects, the EPA revised the secondary National AmbientAir Quality Standard to be identical in all respects to the revised primary standard. The EPA also determined thatthe pre-existing ambient lead monitoring network was inadequate for determining whether many areas are meeting the revised lead standards and established
new criteriafor siting ambient lead monitors and new data collection requirements. Monitors meeting the new network siting requirements were to begin operation January 1,2010.

Within two years ofpromulgating new or revised National Ambient Air Quality Standards, the Clean Air Act requires the EPA to completethe initial process ofidentifying ordesignating areas that meet or do not meet an air quality standard. Ifthe Administrator has insufficient information to make these designations, the EPA has the authority to extend the designation process by up to one year. In light of the new monitoring network, the EPA is completing the lead designations in two rounds. In the first round, published onNovember 16, 2010, the EPA designated as "nonattainment" 16 areas as violating the 2008 Lead National Ambient Air Quality Standards based on datafrom the pre-201O monitoring network. For all other areas, the EPA extended the deadline for designations by up to one year so that datafrom the newly deployed monitors can be considered in making appropriate designation decisions. States were given an opportunity to update their recommendation letters for those remaining areas for
our consideration in the second round ofdesignations by December 15,2910. The EPA intends to

Internet Address (URL). htlp:llwww.epa.gov Recycled/Recyclable.Printed with V.g.U1ble 011 Sesed Inks on Recycled Paper (Minimum SO".Postconsumercontent)

### completethe second round oflead designations by no later than October 14, 2011. Therefore, this letter is the next step in theprocess for completing lead designations by October 14,2011.
Consistent with the Clean AirAct, and after carefully considering US Virgin Islands' November 10, 2009 recommendation letter and all the associated technical information for the 2008 Lead National Ambient Air Quality Standards, including the mostrecent air quality data from 2008-2010, the EPA is proposing to designate US Virgin Islands as unclassifiable/attainment. The EPA uses this designation for initial designations to identify areas thathave data indicating attainment, or where there is no evidence ofa violation.

IfUS Virgin Islands has additional information thatthe EPA should consider with respectto our proposed modification to your designationrecommendation, please submitit to us by August 15,2011. The EPA'spreliminary designation decisions and supporting documentation will be made available to the general public for review. We will be accepting comments throughAugust 15,2011. We will review any information we receive from the US Virgin Islands and the general public by this date, and we plan to promulgatethe second round offinal designations by October 14, 2011.

We look forward to a continued dialogue withyou and your staffas we work togetherto implementthe 2008 Lead National AmbientAir Quality Standards. Should you have any questions, please do not hesitate to call me, orhave your staffcontactRaymond Werner ofmy staffat 212-637-3706.

Sincerely,

# J.\~~ Judith A. Enck Regional Administrator

cc: Alicia V. Barnes, Commissioner Virgin Islands Department ofPlanning & 

### Natural Resources 8100 Lindberg Bay, STE. #61 Cyril E. KingAirport, Terminal Bldg., Second Floor St. Thomas, Virgin Islands 00802
Gina McCarthy, Assistant Administrator for Air and Radiation Steven D. Page, Director, Office ofAir Quality Planning and Standards