UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 8 1595WYNKOOP STREET DENVER, CO 80202-1129 Phone 800-227-8917 http://www.epa.gov/region08

8P-AR 

# :JUN !

# 42011

The Honorable Gary R. Herbert Governor ofUtah State Capitol Salt Lake City, Utah 84114

Dear GovernorHerbert:

Thankyou for yourrecommendations on air quality designations for the revisedNational AmbientAir Quality Standards for lead throughout Utah. This letter is to notify you ofthe U.S. Environmental ProtectionAgency's (EPA's) preliminary decision to designate all ofUtah as attainmentlunclassifiable, andto inform you ofour approach for completing the designations for the revised lead standards. Reducing levels ofleadpollution is an important part 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 Ambient Air Quality Standard by**lowerin~** it from 1.5 micrograms per cubic meter (llg/m3) - a level set in 1978

- to a level of0.15 Ilg/m

. 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 otherwelfare effects, the EPA revised the secondary National 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 monitoring network was inadequate for determining whethermany areas are meeting the revised lead standard and established new criteriafor siting ambient lead monitors and new data collectionrequirements. Monitors meeting the new network sitingrequirements
were to begin operation January 1,2010.

Within two years ofpromulgating new orrevised National AmbientAir Quality Standards, the Clean AirActrequires the EPA to complete the initial process ofidentifying ordesignating 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 designation process by up to one year. In light ofthe 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 AmbientAir Quality Standards based on data from the pre-201O monitoring network. For all other areas, the EPA extended thedeadline for designations by up to one year so that data from the newly deployed monitors canbe considered in making appropriate designation decisions. States were given an opportunity to update theirrecommendation letters for those remaining areas for ourconsideration in the second round ofdesignations by December 15,2010. The EPA intends to complete the second round of lead designations by no laterthan October 14, 2011.

Consistent withthe Clean Air Act, and after carefully considering Utah's October 12,2009 recommendation letter, and all the associated technical information for the 2008 LeadNational Ambient Air Quality Standards, includingthe mostrecent air quality data from 2008-2010, the EPA is proposing to designate Utah as unclassifiable/attainment. The EPA uses this designation for initial designations to identify areas that have data indicating attainment, or where there is no evidence ofa violation.

Ifyour state has additional informationthat the EPA should consider with respect to our proposed modification to your designation recommendation, please submit it to us by August 15, 2011. The EPA's preliminary designation decisions and supporting documentation will be made available to the general public for review. We will be accepting comments through August 15,2011. We will review any information we receive from the state ofUtah and the general public bythis date, and we planto promulgate the second round offinal designations by October 14,2011.

We look forward to a continued dialogue with you and your staffas we worktogetherto implement the 2008 Lead National Ambient Air Quality Standards. Should you have any questions, please do not hesitate to call me, orhave your staffcontact Carl Daly ofmy staffat (303) 312-6416.

Sincerely,

cc: Amanda Smith, Executive Director Utah Department ofEnvironmental Quality Bryce Bird, Acting Director Division ofAir Quality

Gina McCarthy, Assistant Administrator for Air and Radiation Steven D. Page, Director, Office ofAir Quality Planning and Standards