October 8, 2009

Ms. Laura Yoshii,

Acting Regional Administrator

US EPA Region 9

75 Hawthorne Street - ORA-1

San Francisco, CA 94105

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

Dear Ms. Yoshii.

The Lone Pine Paiute-Shoshone Reservation (LPPSR) appreciates the opportunity to

make a recommendation to the US Environmental Protection Agency on designation for

the 2008 revised National Ambient Air Quality Standard (NAAQS) for lead.

The Lone Pine Paiute-Shoshone Reservation is a federally reco gnized Tribe and has

"treatment as a state" status under the Clean Air Act. LPPSR is located in southern Inyo

County, adjacent to the community of Lone Pine, California. The area is known as the

Owens Valley and is in the Eastern California. Known as the "Deepest Valley", the area

is flanked by the 14,000 foot Sierra Nevada Mountains to the west, and the 12,000 foot

Inyo Mountains to the east. The reservation consists of 237 contiguous acres, with an

enrolled population of approximately 350 members.

In preparation of this recommendation the LPPSR Air Quality Department reviewed

available ambient lead data for the region and throughout the state of California. LPPSR

is aware that determining an area' s designation is based on 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 violates the standard and the 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 least 500,000. LPPSR

will not meet either of the new monitoring requirements under the revised 2008 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

located in Los Angeles County, approximately 180 miles to the southwest. Also, LPPSR

does not 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 meeting the 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 appreciates the

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. Justin Raglin, LPPSR Air Quality Coordinator, at:760-876-4690.

Sincerely,

Richard Button, Tribal Chairman

Lone Pine Paiute-Shoshone Reservation

Cc: Mel O. Joseph, LPPSR Environmental Director

Asia Yeary, US EPA Project Officer