UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IX 75 Hawthorne Street San Francisco, CA 94105·3901

OFFICE OF THE REGIONAL ADMINISTRATOR 

## JlIN 1 4 2011

The Honorable Janice Brewer Governor ofArizona 1700 WestWashington Phoenix, Arizona 85007
Dear Governor Brewer: Thank you for your State'srecommendations regarding the air quality designation for the revised National Ambient Air Quality Standards for lead throughout Arizona. This letter is to notify you ofthe U.S. Environmental Protection Agency's (EPA's) preliminary decision to designate Arizona as unclassifiable/attainment and to inform you ofour approach for completingthe designations for the revised lead standards. Reducing levels oflead pollution is an important part ofthe EPA's commitment to a clean, healthy environment. Lead exposure can cause a range ofadversehealth effects, mostnotably in children. Exposures to low levels oflead early in life havebeen linked to effects on IQ, learning, memory, and behavior. On October 15, 2008, the EPA substantially strengthened the health-based or "primary" Lead National Ambient Air Quality Standard for lead by lowering it from 1.5 micrograms per cubic meter (flg/m3) - a level set in 1978

- to a level of0.15 flg/m3

. This stronger standard provides increased protection against adversehealth 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 secondaryNational Ambient Air Quality Standard to be identical in all respects to the revised primary standard. The EPA also determined that the pre-existing ambient lead monitoringnetwork was inadequate for determining whether many areas are meeting the revised lead standards and established new criteria for siting ambient lead monitors and new data collectionrequirements. Monitors meeting the new network sitingrequirements were to begin operation January 1,2010. Within two years ofpromulgatingnew orrevised National Ambient Air Quality Standards, the Clean Air Actrequires the EPA to complete the initial process ofidentifying or designating areas that meet or do not meet an air quality standard. Ifthe Administratorhas insufficient information to make these designations, the EPA has the authority to extend the designationprocess 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 on November 16,2010, the EPA designated as "nonattainment" 16 areas as violating the 2008 Lead National Ambient Air Quality Standardsbased on data from the pre-20lO monitoring network. For all other areas, the EPA extended the deadline for designations byup to one year so that**Prinl~d** on Recycled Paperdata from the newly deployed monitors can be considered in making appropriatedesignation decisions. States were given an opportunityto updatetheir recommendation letters for those remaining areas for our consideration in the second round ofdesignations by December 15, 2010. The EPA intends to complete the second round oflead designationsby no later than October 14, 2011.
Consistent with the Clean Air Act, and after carefully consideringArizona's recommendation letters of December 15,2009 and December 15,2010, and all the associated technical infonnation for the 2008 Lead National Ambient Air Quality Standards, includingthe most recent airquality data from 2008­ 2010, the EPA is proposingto designate Arizona as unclassifiab1e/attainment. TheEPA uses this designation for initial designations to identify areas that have data indicating attainment, or wherethere is no evidence ofa violation. Ifyour state has additional infonnation that the EPA should considerwith respect to ourproposed modification to yourdesignation recommendation, please submit it to us by August 15,2011. The EPA's preliminary designation decisions and supportingdocumentation will bemade available to the general public for review. We will be accepting comments through August 15,2011. We will review any infonnation wereceive from the State ofArizona and the general public bythis date, and weplan to promulgate the second round offinal designations by October 14, 2011. We look forward to a continued dialogue with you and your staffas we work together to implement the 2008 LeadNational Ambient Air Quality Standards. Should you have any questions, please do not hesitate to call me, orhave your staffcontact Air Division Director Deborah Jordan at 415-947-8715.

cc: Henry Darwin, Director, ADEQ Eric Massey Director, Air Quality Division, ADEQ NancyWrona Policy Advisor, ADEQ