UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 6

1445 ROSS AVENUE, SUITE1200

DALLAS, TX 75202-2733

JUN 1 4 2010

The Honorable Rick Perry

Governor ofTexas

Post Office Box 12428

Austin, Texas 78711

Dear Governor Perry:

Thank you for your recommendations on air quality designations for the revised National

Ambient Air Quality Standards (NAAQS) for lead throughout Texas. Reducing levels oflead

pollution is an important part ofthe U.S. Environmental Protection Agency's (EPA) commitment

to a clean, healthy environment. Lead exposure can cause a range of adverse 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. This letter is to notify you ofEPA's response to Texas's

designation recommendations, and to inform you of our approach for completing the

designations for the revised lead NAAQS.

On October 15, 2008, EPA substantially strengthened NAAQS for lead. The new

standards, set at 0.15 micrograms per cubic meter (ug/rrr'), are 10 times tighter than the previous

standards. In conjunction with strengthening the lead NAAQS, EPA also established new

criteria for siting ambient lead monitors. The pre-existing ambient lead monitoring network was

inadequate for determining whether many areas are meeting the revised lead NAAQS. Monitors

meeting the new network siting requirements were to begin operation January 1, 2010.

The Clean Air Act requires EPA to complete the initial designation process within two

years of promulgating a new or revised NAAQS. Ifthe Administrator has insufficient

information to make these designations, EPA has the authority to extend the designation process

by up to one year. In light ofthe new monitoring network which will generate additional

information in the upcoming year, EPA intends to complete the lead designations in two rounds.

In the first round, to be completed by October, 15,2010, EPA is designating as "nonattainment"

any area that is violating the 2008 lead NAAQS based on data from the pre-201O monitoring

network. For all other areas, EPA is extending the deadline for designations by up to one year so

that data from the newly deployed monitors can be considered in making appropriate designation

decisions. EPA will complete the second round of lead designations no later than October 15,

2011.

Consistent with the Clean Air Act, and after carefully considering Texas's October 14,

2009, recommendation letter and all the associated technical information for the 2008 lead

NAAQS, including the most recent air quality data from 2007-2009, EPA is proposing to adopt

the State's recommended nonattainment designation and boundary for a portion ofCollin

County. The enclosed draft Technical Support Document provides a detailed analysis that

supports our preliminary decisions.

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Letter to Governor Perry

Page 2

If your state has additional information that you want EPA to consider with respect to a

designation recommendation EPA proposes to modify, please submit it to us by August 16,

2010. We are also making EPA's preliminary designation decisions and supporting

documentation available to the general public for review. We are accepting public comments on

our preliminary decisions through August 16, 2010. We will review any information we receive

from the State ofTexas and the general public by this date, and we plan to promulgate the first

round offinal designations by October 15, 2010.

For all other areas in Texas, EPA is deferring the designations decisions for up to one

additional year so that additional lead air quality data can be collected. If you would like to

submit updated recommendations for those areas for our consideration in the second round of

designations, we request that you do so by December 15,2010. For the second round of

designations, we will notify states and tribes of our preliminary responses to their

recommendations no later than June 17, 2011.

We look forward to a continued dialogue with you and your staff as we work together to

implement the 2008 lead NAAQS. If you have any questions, please call me at (214) 665-2100,

or your staffmay call Mr. Emad Shahin ofmy staff at (214) 665-6717.

Enclosure

cc: Bryan W. Shaw, Ph.D.

Chairman, Texas Commission on Environmental Quality

Susana Hildebrand, P.E.

ChiefEngineer, Texas Commission on Environmental Quality