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

OFFICE OF THE REGIONAL ADMINISTRATOR 

## JUN 14 2011

The Honorable Robert H. Smith Chairman Pala Band ofMission Indians 35008 Pala Temecula Road, PMB 50 Pala, California 92059
Dear Chairman Smith:
Thank you for your recommendation regarding the air quality designation for the revised National Ambient Air Quality Standards for lead on behalfofthe Pala Band ofMission Indians. This letter is to notify you ofthe U.S. Environmental Protection Agency's (EPA's) preliminary decision to designate the Pala Band ofMission Indians reservation as unclassifiable/attainment, and to infotm you ofour approach for completing the designations for the revised lead standard. Reducing levels oflead pollution 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 lifehavebeen linked to effects on IQ, learning, memory, and behavior.
On October 15, 2008, the EPA substantially strengthened thehealth-based or "primary" National Ambient Air Quality Standard for lead by lowering it from 1.5 micrograms per cubicmeter (J.!gim3) - a level set in 1978

- to a level of0.15 J.!g/m3

. This stronger standard provides increased protection against adversehealth effects associated with exposureto 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 standards. The EPA also determined that the pre-existing ambient lead monitoring network was inadequate for determining whethermany 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 siting requirements were to begin operation January 1, 2010.
Within two years ofpromulgating new or revised National Ambient Air Quality Standards, the Clean Air Actrequires the EPA to complete the initial process ofidentifying or designating areas that meet or do not meet an air quality standard. Ifthe Administratorhas insufficient informahon to make these designations, the EPA has the authority to extend the designation processby up to one year. In light of the new monitoring network, the EPA is completingthe lead designations in two rounds. In the first round, completed on November 16,2010,the EPA designated as "nonattainment" 16 areas as violating the 2008 Lead National Ambient Air Quality Standardsbased on data from the pre-20lO monitoring network. For all other areas, the EPA extended the deadline for designationsbyup to one year so that

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### data from the newly deployed monitors can be considered in making appropriate designation decisions. Tribes were given an opportunityto update their recommendation letters for those remaining areas for ourconsideration in the second round ofdesignationsbyDecember 15,2010. The EPA intends to complete the second round oflead designations no later than October 14, 2011.
Consistent with the Clean Air Act, and after carefully consideringthe Pala Band ofMission Indians' October 6, 2009 recommendation letter and all the associated technical information for the 2008 Lead National Ambient Air Quality Standards, including the most recent air quality data from 2008-2010, the EPA is proposingto designate the Pala Band ofMission Indians reservation 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.
Ifyou have additional information that the EPA should consider with respect to our proposed modification to yourdesignation recommendation, please submit it to us by August 15, 2011. 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 the Pala Band ofMission Indians, the State ofCalifornia, and the general publicbythis date, and weplan to promulgate the second round offinal designationsby October 14,2011.
Welook 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, please do not hesitate to call me, orhave your staffcontact Associate AirDivision DirectorColleen McKaughan at 520-498-0118.

cc: Shasta Gaughen Pala EPA Director