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

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

Dear Governor deJongh:

I am writing you today to provide you with informationon the process for designating
areas in the US Virgin Islands that meetormay not meet the U.S. Environmental Protection Agency's (EPA) health-related National Ambient Air Quality Standardsfor lead. In orderto protect the public health and welfare EPA periodically evaluates health studies and where appropriate, revises its National AmbientAir Quality Standards accordingly. On October 15, 2008 EPA promulgated a more stringentair quality standard for lead. This new standard is based on the most recent scientific studies andprovides additional protection against adverse health effects associated with exposureto airborne lead. To provide increased protection against lead-related welfare effects, EPA also revised the -welfare-related secondary standard to be identical in all respects to the more stringenthealth-related standard.

The next step in implementingthe revised lead National AmbientAir Quality Standard is for each state to recommend to EPA those areas in the state thatmeet ormay not meet this more stringent air quality standard for lead. Theprocess for designating areas is contained in Section I07(d)(l) ofthe Clean Air Act. This section ofthe Clean AirAct provides aprocess for each governor to recommend "attainment", "nonattainment", or "unclassifiable" designations, with appropriate boundaries, to the EPA and requires that these recommendations be submitted to EPA within one year ofa promulgation ofarevised National Ambient AirQuality Standard. Therefore, we ask that you provide yourrecommendations to EPA for all areas in the US Virgin Islands by October 15,2009.
Once EPA receives and evaluates yourrecommendation it may propose modifications to the recommended designations and boundaries. EPA will notify states byno later than 120 days priorto promulgating its final designations, ofany proposed modifications. You would then have the opportunity to comment on any modification that EPAproposes to the US Virgin Islands' original designation recommendation.

I have enclosed with this letter additional guidance to states, local airpollution control agencies and Indian tribes on the time frame and process for designating areas under the revised lead standard. EPA plans to announce ourproposed designations as early as possible, but no laterthan 120 days priorto promulgating initial designations. As previously mentioned

-this 120 day period is established to allow states an opportunity to review and comment upon any changes EPA proposes to make to youroriginal recommendation.

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My staffhas already provided this same information on an informalbasis to representatives ofthe Department ofPlanning & Natural Resources andwill continuetoprovide them with technical assistance and information as this process unfolds.

Under section 107(d)(1)(B) ofthe Act, EPA is required to issue final designations within two years ofpromulgation ofthe final National Ambient Air Quality Standard. However, EPA has the discretion to extend the deadline. up to one year ifthere is insufficientinformationto make designations. EPA intends to complete initial designations by no laterthan October 15, 2010, where air quality data from the existing monitoring network is sufficient or where no additional data is expected to be available.

EPA will designate the remaining areas, where additional air quality informationis expected from an expanded lead air monitoring network, by no laterthan October 15,2011. States and Indian tribes will have an opportunity to update their recommendations forthese remaining areas by October 15,2010. Establishing area designations is a key step in the process of providing the health protection that the Clean Air Act is intended to provide. Areas that are designated as not attaining the lead National Ambient Air Quality Standard will be required to adopt plans to reduce ambient concentrations of lead. We will keep the US Virgin Islands informed of any additional guidance and other support activities. Should you have any questions regarding this matter, please do not hesitate to contact me at 212-637-5000 or have your staffcontactRaymond Werner ChiefAir programs Branch, at 212-637-3706.

, Sincerely,

# ~e~ George Pavlou Acting Regional Administrator

Enclosures

Cc: Robert Stuart Mathes, Commissioner Virgin Islands Department ofPlanning & Natural Resources