October 8, 2009
Ms. LauraYoshii, Acting Regional

Administrator US EPA Region

9 75 HawthorneStreet

- ORA-1 San Francisco,

CA 94105
Subject: Area designation for 2008 Lead NAAQS for the Lone Pine PaiuteShoshone

Reservation

DearMs. Yoshii.
The Lone Pine Paiute-Shoshone Reservation (LPPSR) appreciates the opportunity to make a recommendation to the US Environmental ProtectionAgency on designation for the 2008 revisedNational Ambient Air Quality Standard (NAAQS) for lead.
The Lone Pine Paiute-Shoshone Reservationis a federally recognizedTribe and has "treatmentas a state" status underthe CleanAir Act. LPPSR is locatedin southernInyo County, adjacent

to the community of Lone Pine, California. The areais known as the OwensValley and is in the Eastern California. Known as the "Deepest Valley", the area is flanked by the 14,000foot Sierra Nevada Mountains to the west, and the 12,000foot Inyo Mountains to the east. The reservationconsistsof 237 contiguousacres, with an enrolledpopulationof approximately 350 members.
In preparation of this recommendation the LPPSR Air Quality Department reviewed availableambient lead data for the region and throughoutthe state of California. LPPSR is awarethat determiningan area' s designation

is basedon comparison of the monitored lead concentrations,

averaged

for each three month period, to the level of the standard. If the concentration (known as the design value or the highest rolling three-month average)

is higher than .15 pglm', it violatesthe standard andthe area

is nonattainment.
Due to insufficient ambient lead monitoring data in the region, LPPSR is recommending a designation

of unclassifiable

for the Reservation.Under the revised 2008 NAAQS, US EPA is requiring lead monitoring near industrial

sources that emit at least 1 ton of lead per year. US EPA is also requiring monitoring in all Core Based

Statistical

Areas (CBSA's) with a population of at least500,000. LPPSR will not meet eitherof the new monitoring requirements underthe revised2008 NAAQS. LPPSR is not in close proximity to any industrial sources emitting at least I ton of lead per year. The nearest industrial sources meeting the new monitoring requirement are locatedin Los Angeles County, approximately 180 miles to the southwest. Also, LPPSR doesnot lie within, nor is it tied through; economic, employrnent,

or commuting patterns, to any CBSA with a population of at least 500,000. The nearest CBSA meetingthe new monitoring requirement is Fresno,

California. LPPSR lies approximately 40 miles east

of Fresno and is isolated from the Fresno CBSA by the Siena Nevada Mountain range, which has no through routes in the area. Again, LPPSR recommends that the US EPA designate LPPSR as unclassifiable due to insufficient ambient lead monitoring data in the region. LPPSR appreciatesthe opportunity US EPA has given to make recommendations for the 2008 revised lead NAAQS area

designation. Should you have any question regarding

this recommendation please contact Mr. JustinRaglin, LPPSR Air Quality Coordinator, at:760-876-4690.
Sincerely,

Richard Button, Tribal Chairman Lone Pine Paiute-Shoshone Reservation

Cc: Mel O. Joseph,

LPPSR EnvironmentalDirector Asia Yeary, US EPA ProjectOfficer