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

OFFICE OF THE REGIONAL ADMINISTRATOR 

## JUN 14 2011

TheHonorable Neil Abercrombie Governor ofHawaii ExecutiveChambers, StateCapitol Honolulu, Hawaii 96813
Dear Governor Abercrombie:
Thank you for your State'srecommendation regarding the air quality designation for therevised National Ambient Air Quality Standards for lead throughout Hawaii. This letter is to notify you ofthe U.S. Environmental Protection Agency's (EPA's) preliminarydecision to designate Hawaii as unclassifiable/attainment and to inform you ofour approach for completing the designations for the revised lead standards. Reducing levels oflead pollution is an important partofthe EPA's commitment to a clean, healthy environment. Lead exposure can cause a range ofadversehealth 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 for lead by lowering it from 1.5 micrograms per cubic meter (!1g/m3) - a level set in 1978

- to a level of0.15 !1g/m3. This stronger standard provides increased protection against adverse health effects associated with exposureto 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 monitoring network was inadequate for determining whethermany areas aremeetingthe revised lead standards and established new criteria for siting ambient lead monitors and new data collection requirements. Monitors meeting the new network sitingrequirements wereto begin operationJanuary 1, 2010.
Within two years ofpromulgating new or revised National Ambient Air Quality Standards, the Clean AirAct requires the EPA to complete the initial process ofidentifying or designating areas that meet or do not meet an air quality standard. Ifthe Administrator has insufficient information to makethese designations, the EPA has the authority to extend thedesignation process byup to one year. In light of the new monitoring network, the EPA is completingthe 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 Standards based on data from the pre-20lO monitoring network. For all other areas, the EPA extended the deadline for designationsby up to one year so that**Prinr~d** on Recycled Paper­

### data from the newly deployed monitors canbe considered in making appropriate designation decisions. States were given an opportunityto update theirrecommendation letters for those remaining areas for our consideration in the second round ofdesignations by December 15, 20 10. The EPA intends to completethe second round oflead designations by no later than October 14,2011.
Consistent with the Clean Air Act, and after carefully considering Hawaii's September 11, 2009 recommendation letter and all the associated technical information for the 2008 Lead National Ambient Air Quality Standards, includingthe most recent airqualitydata from 2008-2010, the EPA is proposing to designate Hawaii as unclassifiable/attainment. The EPA uses this designation for initial designations to identify areas that have data indicating attainment, orwhere there is no evidence ofa violation. If

### your state has additional information that the EPA should consider with 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 acceptingcomments through August 15,2011. We will review anyinformation we receive from the State ofHawaii and the general public by this date, and we plan to promulgate the second round offinal designations byOctober 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 any questions, pleasedo not hesitate to call me, orhave your staffcontact Air Division Director Deborah Jordan at415-947-8715.

cc: Gary Gill DeputyDirector, Hawaii DOH
Wilfred K. Nagimine Manager, Clean Air Branch, Hawaii DOH