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

OFFICE OF THE REGIONAL ADMINISTRATOR 

## JUN 14 2011

The Honorable Benigno R. Fitial Governor Commonwealth ofthe NOlihern Mariana Islands Juan A. Sablan Memorial Building Capitol Hill Saipan, Marianas Protectorate 96950
Dear GovernorFitial:
On September9,2009, the U.S. Environmental ProtectionAgency (EPA) sent a letter informing you of your opportunity to provide recommendations on air quality designations for the revised National Ambient Air Quality Standards for lead throughout the Commonwealth ofthe Northern Mariana Islands. This letter is to notify you ofthe EPA's preliminarydecision to designate all ofCNMI as unclassifiable/attainment and to inform you ofour approach for completingthe designations for the revised lead standards. Reducing levels oflead pollution is an important partoftheEPA'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,theEPA substantially strengthened thehealth-based or "primary" National Ambient Air Quality Standard for lead by lowering it from 1.5 micrograms percubic meter**(~g1m3)** - a level set in 1978

- to a level of0.15**~glm3.** 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 Ambient Air Quality Standard to beidentical in all respects to the revised primary standard. The EPA also determined that the pre-existing ambient lead monitoringnetwork was inadequate for determiningwhethermany areas are meeting the revised lead standards and established new criteria for siting ambient lead monitors and new data collection requirements. Monitors meeting the new network sitingrequirements were to begin operationJanuary 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 or designating areas that meet or do not meet an air quality standard. Ifthe Administrator has insufficient information to make these designations, the EPAhas the authority to extend the designation process by up to one year. In light of the newmonitoring network, the EPA is completingthe lead designations in two rounds. In the first

Printtd on !<t'ryc/(d Paperround, published onNovember 16, 20I0, the EPA designated as "nonattainment" 16 areas as violating the 2008 Lead National Ambient Air Quality Standards based on data from the pre-2010 monitoring network. For all otherareas, the EPA extended 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. States were given an opportunity to update their recommendation letters for thoseremaining areas for our considerationin 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 considering all the associated technical infonnation for the 2008 Lead National Ambient AirQuality Standards the EPA is proposing to designate CNMI as unclassifiable/attainment. The EPA uses this designation for initial designations to identify areas that havedata indicating attainment, orwhere there is no evidence ofa violation.
The EPA's preliminary designation decisions and supportingdocumentation will be made available to the general public for review. We will be accepting comments through August 15, 2011. We will review any information wereceive from CNMI and the general publicby this date, and we plan 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 Lead National Ambient Air Quality Standards. Should you have anyquestions, please do not hesitate to call me, orhave your staffcontact Air Division DirectorDeborah Jordan at 415-947-8715.

cc: Frank Rabauliman Director, CNMI Division ofEnvironmental Quality