1 

Responses to Comments on the 

Proposed Revisions to 

Lead Ambient Air Monitoring Requirements 

Docket Number OAR-2006-0735 

U.S. Environmental Protection Agency 

December 2010 

 
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Table of Contents

Introduction ..................................................................................................................................... 3 

Comments on the Proposed Emission Threshold ........................................................................... 4 

Comments on Monitoring at Airports ......................................................................................... 230 

Comments on Non-Source-Oriented Monitoring ....................................................................... 245 

Comments on Monitoring Deployment Schedule....................................................................... 252 

Comments on Other Aspects of Lead Monitoring ...................................................................... 258 

 
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Introduction 

This document, together with the preamble to the final rule on the revisions to the monitoring 

requirements for lead, presents the responses of the Environmental Protection Agency (EPA) to 

the public comments received on EPA’s proposal of December 20, 2009, proposing revisions to 

the monitoring requirements for lead. All significant issues raised in timely public comments have 

been addressed. Where comments were submitted after the close of the public comment period, 

EPA has responded to the extent feasible. 

The responses presented in this document are intended to augment the responses to comments that 

appear in the preamble to the final rule by addressing comments that are not discussed in the 

preamble to the final rule. All comments received are presented; however, the reader is referred to 

the preamble to the final rule for responses to comments that are addressed in the preamble. All 

issues on which the Administrator is taking final action in the revisions to the lead monitoring 

requirements final rule are addressed in the rulemaking record. Accordingly, this Response to 

Comments document, together with the preamble to the final rule, the Notice of Proposed 

Rulemaking, and other docketed supporting documents should be considered collectively as 

EPA’s response to all of the significant comments submitted on EPA’s 2009 proposed revisions to 

the monitoring requirements for lead. 
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Comments on the Proposed Emission Threshold 

Comment ID: OAR-2006-0735-6155 

Name: C. Barker 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. PROFIT DOES NOT TRUMP CLEAN AIR 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6154 

Name: I. Thomas 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. It is time we put the affects of our environment on 

our health in the lime light and make being healthy consumers a priority. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6153 

Name: C. Girz 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Lead has been known to be a toxin for many 

decades. Please protect the health of the citizens of this nation by enforcing 

monitoring of this dangerous substance. 

Response: Responded to in preamble. 
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Comment ID: OAR-2006-0735-6152 

Name: C. Clearwater 

Organization: 

Comment: What is more important? People's health or corporate profits? I 

strongly urge the EPA to enact rules to require monitoring at any facility that 

emits more than half a ton of airborne lead per year (.50 tpy). Monitoring this 

dangerous pollution will improve the health and well being of our community, 

especially our children who are particularly vulnerable to the risks posed by 

lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6151 

Name: C. Bylinowski 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). Help 

save us from the short-sightedness of the previous administration. Monitoring 

this dangerous pollution will improve the health and well being of our 

community, especially our children who are particularly vulnerable to the risks 

posed by lead toxicity. Lead is very dangerous. I work for an urban agriculture 

organization. We and anyone trying to grow food in the city deals with our 

legacy of lead pollution. We don't need any more in the air or in the ground! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6150 

Name: C. Barrett 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. For the environment and how our children live 

healthier in it! Please act! 

Response: Responded to in preamble. 
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Comment ID: OAR-2006-0735-6149 

Name: C. Reid 

Organization: 

Comment: I heartily support the statement below. It is in all of our best interests 

to return to stronger rules which protect the health and well-being of people and 

all living things which inhabit this country. We need to be able to count on the 

EPA to keep the public safe and to act in the best interests of public health. 

Thank you. I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6144 

Name: K. Raymond 

Organization: 

Comment: We live less than 100 miles downwind from one of the largest 

coal-fired power plants in the country, in NW New Mexico. I strongly urge the 

EPA to enact rules to require monitoring at any facility that emits more than 

half a ton of airborne lead per year (.50 tpy). Monitoring this dangerous 

pollution will improve the health and well being of our community, especially 

our children who are particularly vulnerable to the risks posed by lead toxicity. 

This issue has a huge potential impact on our community of Pagosa Springs, as 

well as many other neighboring communities. Please implement these rules! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6145 

Name: L. Ewing 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. you/we must clean up our acts! 
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Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6137 

Name: G. Bartning 

Organization: 

Comment: Without the EPA to act as a watchdog and protect us from the 

airborne pollutant, there is little that we can do. It is imperative that the EPA 

acts in the interest of the greater public good versus industrial good. This will 

help us in the long run ( it is far cheaper to make things cleaner to begin with 

than to clean up after the fact). It will help the health of American worker, 

citizens and environment. It will save from healthcare costs and lawsuit. Please 

act now! 

Response: No response needed. 

Comment ID: OAR-2006-0735-6135 

Name: K. Hoogenakker 

Organization: 

Comment: E.P.A. --- It stands for Environmental Protection Agency, in case 

anyone's forgotten. If the EPA is going to cave to industry pressure and fail to 

monitor air pollution that puts American's health and wellness at risk, they 

might as well close their doors for good. Time to grow a pair and do the job that 

needs to be done. Change can happen, one brave person at a time. Thank you. 

Response: No response needed. 

Comment ID: OAR-2006-0735-6136 

Name: K. Kleyboecker 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Work for the people of the U.S. not the lobbyists. 

Response: Responded to in preamble. 
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Comment ID: OAR-2006-0735-6142 

Name: K. Kraft 

Organization: 

Comment: Please protect our children. I strongly urge the EPA to enact rules to 

require monitoring at any facility that emits more than half a ton of airborne 

lead per year (.50 tpy). Monitoring this dangerous pollution will improve the 

health and well being of our community, especially our children who are 

particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6141 

Name: D. Hileman 

Organization: 

Comment: Come on guys, take the right path for us. I strongly urge the EPA to 

enact rules to require monitoring at any facility that emits more than half a ton 

of airborne lead per year (.50 tpy). Monitoring this dangerous pollution will 

improve the health and well being of our community, especially our children 

who are particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6139 

Name: C. Hart 

Organization: 

Comment: Why is this even a question? Don't you care about the air? Why 

would anyone think putting lead in the air is anything but criminal? I strongly 

urge the EPA to enact rules to require monitoring at any facility that emits more 

than half a ton of airborne lead per year (.50 tpy). Monitoring this dangerous 

pollution will improve the health and well being of our community, especially 

our children who are particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6138 

Name: G. Gardner 
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Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. We used to live near a freeway in Los Angeles 

when my son was born. We moved to Massachusetts when he was 15 months 

but that short exposure did a lot of damage. Despite the fact that he was never 

exposed to any lead paint in his life, at age three when he was exhibiting 

problems it was shown that the levels of lead in his blood were high. He has 

significant behavioral problems even today and he is now 11 years old. We 

must reverse this trend immediately. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6147 

Name: C. Amsden 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. I will be graduating from the Colorado School of 

Mines within 6 months with a degree in metallurgy and will most likely spend 

my life working in large scale factories and/or smelting plants and it is blatantly 

obvious that monitoring all emissions, including lead, should be done so with 

the utmost care and regard to the health and safety of workers and the general 

public despite any additional costs that may be imposed on the companies 

operating said facilities or any other liable parties. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6096 

Name: S. Wilson 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Please consider this important monitoring for the 
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well-being of our children. Thank you for your consideration. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6169 

Name: A. Leighton 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. We must certainly do all we can to support industry 

and jobs in America, but not at the cost of the health and well-being of the 

citizenry. Stricter monitoring of harmful pollutants such as lead will encourage 

industry to clean up its act (literally), and will be of substantial benefit to the 

community at large. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6168 

Name: S. Eatenson 

Organization: 

Comment: Financial interests continue to deny, ignore, and generally discount 

concerns about air (and water, and soil) pollution. The EPA is our only way to 

insist that standards are raised, tightened, and strictly enforced. We have the 

right not to be sickened and killed by companies that claim to be serving us. 

Please, act in our behalf, and refuse to be bought off. Otherwise, you're just as 

bad as them. I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6167 

Name: A. Cockrell 

Organization: 
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Comment: PLEASE, our world is fragile. We do not need more LEAD. I ask as 

a biology major and science teacher as well as a parent and grandparent. 

THANKS strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6166 

Name: P. Leaf 

Organization: 

Comment: Several years ago, my daughter had elevated lead levels and had to 

have repeated blood tests to monitor her health. This lasted almost two years 

and there was no "point source" responsible. The last thing we need is more 

ambient lead contamination in the air our children breath. I strongly urge the 

EPA to enact rules to require monitoring at any facility that emits more than 

half a ton of airborne lead per year (.50 tpy). Monitoring this dangerous 

pollution will improve the health and well being of our community, especially 

our children who are particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6165 

Name: C. Daum 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. The EPA should have the health of Americans at 

heart, and not let polluting factories continue to worsen air and water quality. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6164 

Name: B. Carter 
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Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. In my humble opinion enacting strong airborne 

lead monitoring standards will reduce both the occurrences of many cancers 

and autism. To refuse to do so would be an act of treachery against the people of 

the United States. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6163 

Name: I. Kleiman 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Dangerous levels of lead in the air that our children 

breathe are unacceptable. Is it worth saving a few dollars and allowing our 

children's IQs to be lower. Does being dumber help us to compete in the global 

marketplace? Sheesh! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6156 

Name: D. Roy 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. PROFIT DOES NOT TRUMP CLEAN AIR 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6095 
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Name: S. Bykowski 

Organization: 

Comment: I believe the EPA must create rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy): 

facilities such as factories and smelting plants. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6134 

Name: K. E. Cowen 

Organization: 

Comment: Truly, lead emissions have no place in our atmosphere-- even at half 

a ton per year-- and I hope to see the day when we eliminate all lead emissions. 

Until then, I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6097 

Name: G. Crosby 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits airborne lead. Monitoring this dangerous pollution will 

improve your personal health and well being of your community, especially 

your children who are particularly vulnerable to the risks posed by lead toxicity. 

Gated communities might keep out the "little people," but they cannot filter the 

toxins we all breath. 

Response: Monitoring at all sources of Pb is both impractical (there are well 

over 100,000 facilities that emit some amount of Pb) and unjustifiable. Very 

small sources of Pb have no potential to exceed the Pb NAAQS which was 

established at a level that protects public health with a margin of safety. The 

emission threshold finalized in this rule is intended to identify sources of Pb 

that have the potential to exceed the Pb NAAQS. 
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Comment ID: OAR-2006-0735-6061 

Name: A. Grodin 

Organization: 

Comment: As a mother and grandmother, I am writing to urge you to enact 

rules to require monitoring at any facility that emits more than half a ton of 

airborne lead per year (.50 tpy). Monitoring this dangerous pollution will 

improve the health and well being of my community and your own community, 

especially to all of our children who are particularly vulnerable to the risks 

posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6160 

Name: S. Valenti 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. I live in the lead belt and know the potential harm 

that lax standards can do to people, especially children. We must solve 

problems now and not continue to pass them down the road. The road is already 

blocked. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6159 

Name: S. Klein 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. It will also cut health care costs at the front end, by 

allowing us all to be healthier. This is real health care, not disease care. 

Response: Responded to in preamble. 
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Comment ID: OAR-2006-0735-6158 

Name: M Vargas 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Please take this opportunity to undo one of the 

many wrongs done by the Bush administration. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6130 

Name: B. Warner 

Organization: 

Comment: Please do not ignore the health and development of our next 

generation for the bottom line of corporate polluters. As someone who worked 

to implement a federal lead-based paint hazard reduction program in my 

community, I am acutely aware of what small amounts of lead can do to the 

well-being and functioning of small children. Monitoring at any facility that 

emits more than half a ton of airborne lead per year should be established 

immediately. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6157 

Name: B. Stanton 

Organization: 

Comment: Clean up our air!! I wholeheartedly urge the EPA to enact rules to 

require monitoring at any facility that emits more than half a ton of airborne 

lead per year (.50 tpy). Monitoring this dangerous pollution will improve the 

health and well being of our community, especially our children who are 

particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 
16 

Comment ID: OAR-2006-0735-6162 

Name: W. Collins 

Organization: 

Comment: I think anyone putting any lead in the air or on the ground or in the 

water ought to be highly discouraged from doing so. I'm not so sure that 

monitoring is the best way to control anything as it seems to amount to, "Keep 

doing it while we watch." More monitoring probably means more budget and 

more staff. Maybe there is a way to create a kind of permit-by-rule monitoring 

exemption for these lower emissions. The assumption is that they will emit 

even if monitored, so take any money savings by not monitoring, including 

estimated fees that each polluter would typically pay to consultants to collect 

data and prepare reports, and use that money instead to fund pollution controls. 

Otherwise, I say monitor any facility that emits more than a quarter ton of 

airborne lead per year (.25 tpy). 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6115 

Name: K. Kahn 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring and obtaining information of this pollutant is needed to ensure that 

we maintain and improve the health and well being of our community, 

especially our children who are particularly vulnerable to the risks posed by 

lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6102 

Name: B. J. Nekola 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. How can big business consistently ignore the 

health needs of people, especially children! It boggles my mind as the young 

folks say. Take care of the environment - it cannot be repaired. 
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Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6103 

Name: D. Williams 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollutant will improve the health and well-being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Airborne lead is toxic and can cause a host of 

medical problems, especially in children who are more susceptible to the 

harmful effects of lead exposure. Some of the problems it causes include lower 

IQ, behavioral problems, brain damage, kidney damage and cardiovascular 

injury. This is not a future I wish upon my progeny. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6118 

Name: K. Schockmel 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. I live in a small rural Utah valley and we have the 

WORST air pollution in the nation this winter. I am painfully aware of the 

effects of poor air quality on all citizens - especially children. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6104 

Name: S. Sesher 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 
18 

risks posed by lead toxicity. The more we study the effects of Lead in the body, 

the stronger the conclusion that there is no safe level of lead exposure. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6105 

Name: M. Bohnert 

Organization: 

Comment: I live near the Doe Run lead smelter in Herculaneum, MO. I'm tired 

of hearing about people having their lawns dug up due to lead contamination, 

and children with high lead levels in their blood. This must be stopped. I 

strongly urge the EPA to enact rules to require monitoring at any facility that 

emits more than half a ton of airborne lead per year (.50 tpy). Monitoring this 

dangerous pollution will improve the health and well being of our community, 

especially our children who are particularly vulnerable to the risks posed by 

lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6106 

Name: A. Ricci 

Organization: 

Comment: Lead is not something I want to breathe in my air. Just because 

corporations can make more money if I do breathe the air does not mean I want 

that to happen. I strongly urge the EPA to enact rules to require monitoring at 

any facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6132 

Name: C. Williams 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 
19 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. MY SON SUFFERS FROM LEAD POISONING 

FROM POLLUTION IN ANOTHER COUNTRY. PLEASE DO NOT 

ALLOW IT HERE ! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6116 

Name: J. and M. De Jonghe 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. This is after all, what environmental protection 

means! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6099 

Name: A. Moriarity 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. I live in Missouri where airborne lead has been an 

issue for years due to the lead smelter located south of St. Louis. Children in 

that area who have been tested show high levels of lead in their blood. This is 

not acceptable. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6114 

Name: K. Knepper 
20 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year. Seems the very 

least we can do. I understand our Government is now going to be run by 

corporations, for corporations, but give the people at least a little air to breathe 

or you will have fewer customers. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6107 

Name: B. Kalison 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Actually, there should be zero lead emissions allowed! I teach Anatomy & 

Physiology at the college level and I am well aware of the costs to the health of 

our children. Lead poisoning can cause mental impairments as well as anemia 

and kidney damage. These will lead to long term costs in health care. African 

American children are especially vulnerable due to calcium deficiency in 

Northern climates. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6113 

Name: K. Connell 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. In Colorado, we are currently faced with Excel 

Energy's efforts to bring a new coal burning plant on line in Pueblo. While I 

don't know its lead emissions profile, it certainly will include mercury 

poisoning fumes according to my available sources of information. Please help 

us. As citizens, we should be protected, not poisoned! Thank you for your 

consideration! 

Response: Responded to in preamble. 
21 

Comment ID: OAR-2006-0735-6112 

Name: K. Johnson 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Quite frankly even this amount of lead seems 

excessive to me and could be obviated by a shift to clean renewable green 

technologies. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6111 

Name: K. Duey 

Organization: 

Comment: THIS IS PLAIN COMMON SENSE!!!!! I strongly urge the EPA to 

enact rules to require monitoring at any facility that emits more than half a ton 

of airborne lead per year (.50 tpy). Monitoring this dangerous pollution will 

improve the health and well being of our community, especially our children 

who are particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6108 

Name: K. Van Sant 

Organization: 

Comment: This issue is a HUGE priority for us: I strongly urge the EPA to 

enact rules to require monitoring at any facility that emits more than half a ton 

of airborne lead per year (.50 tpy). Monitoring this dangerous pollution will 

improve the health and well being of our community, especially our children 

who are particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6110 

Name: A. Halter 
22 

Organization: 

Comment: Why do we still have to fight for our right to a healthy environment? 

This has been going on way too long. Stop putting corporations ahead of 

people! I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6117 

Name: L. Amerman 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. The EPA needs to take control and become an 

authority in monitoring pollutants. It cannot give way to private interests who 

pollute more than they should be allowed and harm the public health and 

environment. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6170 

Name: J. Lent 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Please, in your role as the agency responsible for protecting the environment, 

take a stand for the environment and public health.

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6123 

Name: B. Jones 
23 

Organization: 

Comment: I exhort the EPA to enact strict rules that require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Strictly monitoring the hitherto all but ignored sources of this highly toxic 

pollution will improve the health and well being of our citizens and 

environment -- and especially of our children who are particularly vulnerable to 

the dangers of this insidious poison, which has been allowed by 

profitmongering pro-industry "leaders" to contaminate our lives and 

environment for far too long. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6131 

Name: A. Miller 

Organization: 

Comment: The EPA should not shy away from its regulatory mission, as 

corporations have proven time and again that they will not police themselves. 

Therefore, I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-0 

Name: K. Koopmann 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity, and wildlife, which is also drastically affected but 

does not have a means to speak for itself. Thank you 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6129 
24 

Name: B. Tieken 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. It is the right thing to do, so please act on behalf of 

our children. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6128 

Name: B. Pratt 

Organization: 

Comment: What does EPA stand for? Show some backbone for the people and 

for our environment! I strongly urge the EPA to enact rules to require 

monitoring at any facility that emits more than half a ton of airborne lead per 

year (.50 tpy). Monitoring this dangerous pollution will improve the health and 

well being of our community, especially our children who are particularly 

vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6127 

Name: B. Pritchett 

Organization: 

Comment: China is leading the world deeper into danger from pollution with its 

recent industrial expansion explosion. The US set bad examples for the world 

for nearly a century, then when we enacted changes to become clean, we 

repealed the laws and disconnected their teeth. How can we ask China and other 

developing nations to be clean now when we have such a dirty past and a not so 

clean present? We must lead the world to a cleaner future and we must do it 

now. It is critical that the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. 

Response: Responded to in preamble. 
25 

Comment ID: OAR-2006-0735-6126 

Name: Comment submitted by B. Jansen 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Please put the people of this country first as well as 

the planet. Such short sighted policies that allow large levels of toxins into the 

air to increase profit are unthinkable. Please think of the long term health of our 

planet's biosphere as well. Respectfully, please tighten the rules about airborne 

leads and other toxins and keep them tight. We need the people in power to 

show some strength and do the right thing. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6101 

Name: P. Callen 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Lead monitoring needs to continue, we need to 

know quantitatively where and how much lead is released into the air. Thank 

you for revisiting this critical health issue. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6124 

Name: M. B. Muetzel 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Please, do it for the children. 

Response: Responded to in preamble. 
26 

Comment ID: OAR-2006-0735-6100 

Name: David J. Shaw 

Organization: New York State Department of Environmental Conservation 

(NYSDEC) 

Comment: The Department is pleased that EPA is proposing to reduce the 

threshold to require ambient monitors around facilities that emit lead. Certain 

facilities that emit less than 1.0 tpy could potentially cause significant lead 

concentrations in surrounding neighborhoods. The Department also recognizes 

that facilities cannot be categorized simply by an annual emission quantity. 

This is apparent in the EPA’s own analysis which shows more than a factor of 

10 difference in the amount of lead emitted from a facility that would cause an 

exceedence at a monitor. Some manufacturing processes result in higher 

short-term emissions that when averaged over a year would not trigger the 

monitoring requirement. Other facilities which may emit higher annual 

amounts of lead do not result in high concentrations in neighboring areas 

because their emissions are uniformly distributed over the course of a year. 

These facility comparisons are complicated by the type of emissions, the 

potential for upset conditions, whether emissions are fine or coarse, and the 

amount of the lead containing particulate matter emitted. The monitor waiver 

process is an appropriate way to reduce the requirements for monitoring at 

facilities where it is not needed. This change is necessary due to the differing 

characteristics of the sources covered under this proposal. An annual emission 

total is insufficient information to insure that the public is not exposed to 

significant lead concentrations. Sources where lead emissions vary monthly or 

seasonally will have higher ambient impacts over the 3 month averaging period 

of the rule than a source with the same total annual emissions emitted at a 

constant rate. The EPA should leave the threshold at 0.5 tpy for this revision of 

the monitoring regulation. It is unlikely but possible that some specific industry 

or type of facility could have emissions of concern even though they have 

annual emissions below 0.5 tpy. The data collected under this monitoring 

regulation will help assess the emission threshold for the next round of 

regulation review. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6098 

Name: M. Schwing 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 
27 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Let's not go backwards on common sense rules and 

regulations! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6180 

Name: J. F. McComb 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. For the sake of future generations this action is an 

imperative! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6122 

Name: L. Feurzeig 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). As a 

parent, I worked hard to be sure that repainting our house did not endanger my 

child. The country should be doing the same for all our children. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6121 

Name: X. Castleton 

Organization: 

Comment: I am the mother of an asthmatic three year old with high levels of 

lead from sources outside the home (we live near a power plant). I strongly urge 

the EPA to enact rules to require monitoring at any facility that emits more than 

half a ton of airborne lead per year (.50 tpy). Monitoring this dangerous 

pollution will improve the health and well being of our community, especially 
28 

our children who are particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6120 

Name: A. Tobar-Alatriz 

Organization: 

Comment: Have you ever spent time with a child poisoned by lead. Their 

loving, big eyes are slow to respond. They seem oddly dulled. Usually of lower 

income, their mothers do their best to integrate their poisoned children into their 

families and yet it is clear, nonetheless, that it is a huge heartache for the whole 

family. I believe in a country that takes care of its many and diverse 

communities. I strongly urge the EPA to enact rules to require monitoring at 

any facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6119 

Name: W. Gray 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. It is interesting that there has been such a ruckus 

over mercury in our fish and yet lead is just as poisonous! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6133 

Name: V. Goldie 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 
29 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. We have known for many years just how 

dangerous lead is. Please take action immediately. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6125 

Name: B. Levin 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Each piece may not seem so important, but if we 

don't stop it, piece by piece, it will become so overwhelming that it will be 

beyond our abilities to control the problem. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6218 

Name: C. Schuett 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. We are counting on you to keep the public safe 

from toxic emissions. Thanking you in advance for enacting rules that will truly 

protect our health and safety. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6228 

Name: D. Bryant 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 
30 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. As someone who suffers from asthma I believe we 

should do whatever we can to keep our air clean and prevent this disease. 

Remember, unless you move to a different planet, we all breathe the same air!!! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6227 

Name: S. Holz 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Not acting to implement stronger regulations 

harms your children too and their kids and so on. We need to protect the 

environment and people's health today for a stronger life-worth-living world for 

the future. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6225 

Name: S. Bjerke 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. THis is NOT only EPA, this impacts our health 

care issues, education, thinking, crime...look at the effects of lead.....WE cannot 

afford to have anyone hired and paid by us, the taxpayers, who is not acting in 

our best interests anymore. NOT BIG BUSINESS--us!!! WE say NO MORE. 

We can start businesses over, we can let them go bankrupt. WE can do this 

right! There is a better way, and a whole bunch of us waiting to "get it done"!!! 

Clean up our air, water and food. If it doesn't fit that, don't do it. Do you all 

shudder when the youth in your families start having children? IN our church, 

too many end up on the prayer list, holes in hearts, half hearts, holes in spines, 

and that isn't even the neurological add, seizures, sleep disorders.....etc. To stop 

that, we MUST stop the cause---if it isn't done completely clean, then please 

don't do it. Other folks, honest with transparency, integrity, morals and ethics 
31 

would love your jobs. Seriously. I for one, highly educated, capable, and 

unemployed. If you cannot do it, please, step aside and let me do your job. thank 

you for reading and acting responsibly, as we hired you to do. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6224 

Name: B. Giza 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. The experience that I and other El Paso Texas 

residents have had in the past with poisonous lead emissions from the local 

smelter has taught us that we must be equipped with the information necessary 

to be informed citizens, with the ability to act as needed to protect the health of 

our communities. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6223 

Name: D. Lopez Hughes 

Organization: 

Comment: The health of our children is foundational to our country's health and 

future progress. I implore the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6222 

Name: M. Gorder 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 
32 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. I have family who live 7 miles from Dish, Texas. 

This is of great importance to me. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6221 

Name: M. Gulledge 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. You must be willing to end this environmental 

hazard. You can and do have the power to do it and I dare say the support of the 

people. Do the right thing for all of us. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6210 

Name: L. Briers 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Lead has no place in our air ,our water, somethings 

should be free and readily available to all living things and toxin free! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6219 

Name: M. Follis 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 
33 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. I dream of the day the government protects the 

people instead of helping big business. Will that day ever come? 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6231 

Name: J. Bezanson 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits half a ton or more of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our communities, especially our children who are so vulnerable to lead toxicity 

problems. It is unconsionable to allow high exposure when we know it can lead 

to lower IQ, behavioral problems, brain damage, kidney damage and 

cardiovascular injury. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6217 

Name: D. Johnson 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Lead s a serious health hazard for every person, 

and especially to children. Please act accordingly.

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6216 

Name: C. Enders 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 
34 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. My goodness - at this point in our history and 

knowledge this should be a "no brainer". Please do the right thing. Thank you. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6215 

Name: K. Hall 

Organization: 

Comment: Protect my children!! I strongly urge the EPA to enact rules to 

require monitoring at any facility that emits more than half a ton of airborne 

lead per year (.50 tpy). Monitoring this dangerous pollution will improve the 

health and well being of our community, especially our children who are 

particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6576 

Name: P. Ehret 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. I have been shocked to discover the "out-of-range" 

amounts of lead and mercury that I have in my body. I suspect all of us have 

much more of a problem with this than is realized. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6212 

Name: C. Livesay 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 
35 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. THIS IS AN ABSOLUTE MUST!!! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5926 

Name: John H. Melby, Jr. 

Organization: Bureau of Air Management, Wisconsin Department of Natural 

Resources 

Comment: The Department supports the proposal to change the lead emissions 

monitoring threshold to 0.5 tons per year (tpy) as appropriate for public health 

protection, as this is consistent with the CASAC recommendations and EPA’s 

original proposal. Modeling during the initial assessment of emission sources in 

Wisconsin, suggested that the lead standard could be exceeded at a facility with 

emissions between 0.5 tpy and 1.0 tpy. The Regional Administrator is requiring 

monitoring at this site under the discretion allowed in the existing rule. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6178 

Name: J. Aronstam 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Clean Air---- a basic need, a basic right. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6220 

Name: M. Gabriel 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 
36 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. We have a responsibility to not hand these 

problems to the next generation. The buck stops with us, and the EPA is the 

agency of the people and is charged with this responsibility on our behalf. I pray 

you have the balls and conscience to do what's right by enacting rules to keep 

our air clean. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6239 

Name: D. Aston 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Airborne lead is a serious health hazard that can cause irreversible damage, 

especially in children. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6248 

Name: D. Macalady 

Organization: 

Comment: Airborne lead pollution should have been outdated by the end of 

leaded gas. There is no reason to allow any facility to emit airborne lead. Thus, 

I strongly urge the EPA to enact rules to require monitoring at any facility that 

emits more than half a ton of airborne lead per year (.50 tpy). Monitoring this 

dangerous pollution will improve the health and well being of our community, 

especially our children who are particularly vulnerable to the risks posed by 

lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6247 

Name: R. Caputo 

Organization: 

Comment: Protecting American citizens (and taxpayers) should be a top 
37 

priority for the EPA. It is time to put PUBLIC SAFETY before industry profits. 

I strongly urge the EPA to enact rules to require monitoring at any facility that 

emits more than half a ton of airborne lead per year (.50 tpy). Monitoring this 

dangerous pollution will improve the health and well being of our community, 

especially our children who are particularly vulnerable to the risks posed by 

lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6246 

Name: D. Hastings 

Organization: 

Comment: I am a 47 year old father of a 3 1/2 year old and a 1 year old. Their 

future health in large part, rests in the continued commitment of all of us to a 

healthy environment. Therefore, I strongly urge the EPA to enact rules to 

require monitoring at any facility that emits more than half a ton of airborne 

lead per year (.50 tpy). Monitoring this and other dangerous pollution is 

essential to maintaining the continued vitality of our country. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6245 

Name: D. Crocker 

Organization: 

Comment: WE NEED STRONG laws to protect our entire environment, That's 

your job!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! I strongly urge 

the EPA to enact rules to require monitoring at any facility that emits more than 

half a ton of airborne lead per year (.50 tpy). Monitoring this dangerous 

pollution will improve the health and well being of our community, especially 

our children who are particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6244 

Name: D. Ramin 

Organization: 
38 

Comment: Live up to your name and be an agency that truly protects the 

environment and the people that inhabit it. I strongly urge the EPA to enact 

rules to require monitoring at any facility that emits more than half a ton of 

airborne lead per year (.50 tpy). Monitoring this dangerous pollution will 

improve the health and well being of our community, especially our children 

who are particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6243 

Name: P. Jordan 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Lead directly effects the development of children's 

brains. Monitoring lead pollution is in America's vital national interest. Do your 

job! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6242 

Name: M. Bush 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Please don't side with those who would dirty up our 

air, without regard for the consequences of their actions. Instead, side with the 

innocent everyday people, whose health will be adversely affected if you are 

not there to regulate even those who pollute at the lower level of .50 ton per 

year. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6229 
39 

Name: K. Rose 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. The air in America should be as clean as it was 

when the first European-American set foot on this continent! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6240 

Name: L. Bresnan 

Organization: 

Comment: We need to get the lead out! I strongly urge the EPA to enact rules to 

require monitoring at any facility that emits more than half a ton of airborne 

lead per year (.50 tpy). Monitoring this dangerous pollution will improve the 

health and well being of our community, especially our children who are 

particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6230 

Name: M. Kokes 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. WHen it comes to health and welfare, our 

government should be protecting PEOPLE, not Big Business. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6238 

Name: D. Bailey 
40 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Get the lead out! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6237 

Name: S. Rosenblatt 

Organization: 

Comment: PLEASE enact rules to require monitoring at any facility that emits 

more than half a ton of airborne lead per year (.50 tpy). This will improve the 

health and well being of our community, especially our children who are 

particularly vulnerable to the risks posed by lead toxicity. EMISSION 

STANDARDS MUST BE ENFORCED and lead poisoning ended!!!!! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6236 

Name: C. Cassini 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. I am a Masters prepared RN. I find it very upsetting 

that the EPA. and other government agencies, is delinquent in regard to safety 

issues. Why on earth is lead STILL an issue? We have known about Lead 

toxicity for many years! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6235 

Name: T. Hayward 

Organization: 
41 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Take back your mission of protecting the 

environment and accept my apology for allowing the Bush administration to 

prevent you from doing your job. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6234 

Name: P. J. Crabill 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. The quality of the lives of all Americans now and 

in the future are dependent upon the cleanliness of our air. Please make it as 

clean as possible! Thank you!! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6233 

Name: A. Morgan 

Organization: 

Comment: Nothing is as important as the air we breathe and the water we drink. 

I strongly urge the EPA to enact rules to require monitoring at any facility that 

emits more than half a ton of airborne lead per year (.50 tpy). Monitoring this 

dangerous pollution will improve the health and well being of our community, 

especially our children who are particularly vulnerable to the risks posed by 

lead toxicity. Think of the health of the citizens of this country first and not the 

corporation's health. In the long run it will even be better for business. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6232 

Name: M. Andeson 
42 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Please preserve the health and integrity of our 

planet for all future generations. To knowingly do otherwise while we have 

non-toxic alternatives available to us would be, at minimum, an act of reckless 

endangerment for our planet and it's civilization. I hope you will choose to 

honor a non-toxic present and future for all by working to put in the place 

proper monitoring and regulations of toxic substances and the consequences of 

their use and production. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6209 

Name: C. Athey 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. It made a real difference when we got it out of paint 

and will continue to improve matters if we get it out of the air, too. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6241 

Name: A. Tanguay 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. There must also be strong airborne mercury 

controls from burning coal. It is unacceptable that we allow such large levels of 

mercury to be in the atmosphere as well as lead. 

Response: Responded to in preamble. 
43 

Comment ID: OAR-2006-0735-6179 

Name: J. Jackson 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. I had thought that the EPA was set up to protect the 

e 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6188 

Name: J. Hays 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. As a long-time teacher I fear that I am beginning to 

see some effects of environmental degradation, with lead reaching high levels 

in an alarming number of women of childbearing age.

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6187 

Name: L. Holmes 

Organization: 

Comment: We need to protect our children from lead poisoning to the very best 

of our ability. I strongly urge the EPA to enact rules to require monitoring at 

any facility that emits more than half a ton of airborne lead per year (.50 tpy. 

Children are particularly vulnerable to even tiny amounts of lead in the 

environment, and they do not have lobbyists in Congress. 

Response: Responded to in preamble. 
44 

Comment ID: OAR-2006-0735-6186 

Name: L. Atkins 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. If we know certain chemicals are toxic, we have a 

responsibility to curb corporate greed that puts profits above public health. 

There's no excuse when there is public support for ecologically sustainable 

methods of production. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6185 

Name: J. Tissavary 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. There cannot be any question as to the priority of 

this administration’s actions in this: protect us from industrial poisons. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6184 

Name: J. Falcon 

Organization: 

Comment: We've know literally for millennia that lead is poisonous. What 

possible excuse can there be for allowing polluting facilities to continue 

pumping it into the air? I strongly urge the EPA to enact rules to require 

monitoring at any facility that emits more than half a ton of airborne lead per 

year (.50 tpy). Monitoring this dangerous pollution will improve the health and 

well being of our community, especially our children who are particularly 

vulnerable to the risks posed by lead toxicity. 
45 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6183 

Name: J. Chambers 

Organization: 

Comment: Corporations are granted the PRIVILEGE of doing business in the 

US. If they are not benefitting the citizens, they should be denied this 

PRIVILEGE! I strongly urge the EPA to enact rules to require monitoring at 

any facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6182 

Name: J. Jarrett 

Organization: 

Comment: The frame for even addressing these issues is mired in self-delusion 

too often. We should be discussing the real cost of pollution, including the long 

term and environmental costs. Too often the emphasis is focused on short term 

economics, benefitting the polluters and the powerful. Not all of us are unaware 

that the decked is stacked. I was in Los Angeles when kids dropped on the 

playground due to the melathione spraying. Agribusiness sacrificing the 

children and warning us that the spraying would pit the pan on cars, but not to 

worry about our lungs. I strongly urge the EPA to enact rules to require 

monitoring at any facility that emits more than half a ton of airborne lead per 

year (.50 tpy). Monitoring this dangerous pollution will improve the health and 

well being of our community, especially our children who are particularly 

vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6211 

Name: S. Knight 

Organization: 
46 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. The health of our children and grandchildren is in 

our hands. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6082 

Name: C. D. 

Organization: 

Comment: Make health policy, please. I strongly urge the EPA to enact rules to 

require monitoring at any facility that emits more than half a ton of airborne 

lead per year (.50 tpy). Monitoring this dangerous pollution will improve the 

health and well being of our community, especially our children who are 

particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6191 

Name: L. Findley 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. I have a child with Autism, we don't need to be 

breathing anything but clean air. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6094 

Name: M. Caldwell 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 
47 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. There are no safe levels of lead or mercury 

exposure. Please act quickly to restore strict limits on emissions! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6177 

Name: J. Zugale 

Organization: 

Comment: What's next? Putting lead back in gasoline would make it cheaper 

for industry and consumers too, right? *sigh* I, along with lots of other 

Americans, strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Come on, guys, this one's a no-brainer. Any 

industry that wants the freedom to spew lead into the air needs to have an eye 

kept on them, and probably for other polluting things too. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6176 

Name: J. Sage 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. I lived 1/5 of a mile from the 2005 tire fire in WI 

and have experience interacting with the EPA. The fire caused a large 

environmental, health and financial impact. I wonder just how much the unpaid 

EPA tab is by now, given added interest. It was over $640,000 just a few years 

ago. If I owed that much money, I'd probably be in jail, not free and retired! 

Response: Responded to in preamble. 
48 

Comment ID: OAR-2006-0735-6175 

Name: H. and D. Shaul 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. This should be common knowledge, and we should 

NEVER have to remind you, of all agencies, of the damage to young children 

from exposure to lead poisoning. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6174 

Name: J. Reel 

Organization: 

Comment: Our Constitution says the government should "promote the general 

welfare." The first thing a government should do in promoting the general 

welfare is help ensure a clean, safe place to live. Why else do people band 

together into groups? For me, a chemically sensitive person, clean air is at the 

basic foundation level of my welfare. I cannot live where I cannot breathe. 

Indeed, everything on this planet is made weaker and sicker by breathing toxic 

air. I strongly urge the EPA to enact rules to require monitoring at any facility 

that emits more than half a ton of airborne lead per year (.50 tpy). Thank you for 

doing your constitutional duty, 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6173 

Name: J. Barnett 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. STOP TRYING TO KILL US!!!!!!!!!!!!! 
49 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6172 

Name: D. Collins 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Come on folks..this is a no brainer. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6181 

Name: J. Northrop 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

US facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Do the right thing! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6199 

Name: M. Hardy 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. it seems like every year we hear of toys being 

recalled because lead is unsafe for everyone, especially our developing 

children. if the government can regulate cheap toys then what's stopping them 

from regulating factories pumping this toxic metal into our air for us to breathe? 
50 

it's appalling to me that this even needs to be spoken up about because this is so 

obviously wrong. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6208 

Name: G. & L. Clark 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. We cannot address and control that which we do 

not monitor. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6207 

Name: D. Lewis 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. I want to see TEETH in this bill. No more 

sweetheart deals. Actually, I want serious monitoring of facilities emitting a 

quarter ton or more of airborne lead contaminants! Wake up you servants of the 

People! Time to get circumspect! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6206 

Name: M. Emmer 

Organization: 

Comment: As part of its 8-year assault on the environment and our health, and 

at a time when many children were suffering from asthma and other health 
51 

problems, the Bush EPA in 2008 proposed to weaken rules on monitoring 

large-scale sources of airborne lead, such as factories and smelting plants. This 

was just one of many Bush administration gifts to big polluters and big 

business, at our expense. In November 2008, the American people voted for 

change. Therefore, I strongly urge the EPA to enact rules requiring monitoring 

at any facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous lead pollution will improve our health and 

well-being, especially that of our children who are particularly vulnerable to the 

risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6205 

Name: C. McTigue 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Please help make this change for every living being 

on the earth to be healthier. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6204 

Name: J. Lifshitz 

Organization: 

Comment: Before the Corporations (per the Supreme Court)rule the country 

please do this. I strongly urge the EPA to enact rules to require monitoring at 

any facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6203 
52 

Name: H. and D. Shaul 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. This should be common knowledge, and we should 

NEVER have to remind you, of all agencies, of the damage to young children 

from exposure to lead poisoning. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6202 

Name: M. Burgess 

Organization: 

Comment: Enact rules to require monitoring at any facility that emits more than 

half a ton of airborne lead per year (.50 tpy). I know a child who has been lead 

poisoned and he is mentally and emotionally damaged for life. It hurts to see 

him have temper tantrums and not be able to speak his own name, when he 

could before. Do NOT let anyone put lead in our air to damage our children. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6189 

Name: L. J. M. Khan 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. As a country, it is in our best interests to ensure that 

our children have the healthiest environment in which to grow and develop into 

strong and valuable, contributing members of our society. How can they do that 

if their health and mental development is affected by air that is polluted with 

lead toxins? Who benefits from loose regulation of facilities that emit such 

poisons? Those companies, not the American people. Take this chance to make 

a brighter future for our children and, ultimately, our country by putting our 

children first! 
53 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6200 

Name: M. Epstein 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Even tiny amounts of lead cause lower IQs in 

children. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6190 

Name: L. Keenan 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. I am a nurse who works with mothers and infants, 

and I am very concerned about the toxic substances to which we expose our 

infants even before birth. Please do not let industry trump the health of our 

children. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6198 

Name: M. Markesteyn 

Organization: 

Comment: The time has past! So the world will be a safer place for life now and 

the generations to follow we must strongly urge the EPA to enact rules to 

require monitoring at any facility that emits more than half a ton of airborne 

lead per year (.50 tpy). Monitoring this dangerous pollution will improve the 
54 

health and well being of our community, especially our children who are 

particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6197 

Name: M. Vayanas 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. My gosh!!!! Where does it end! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6196 

Name: L. Asbury 

Organization: 

Comment: I STRONGLY urge the EPA to enact rules to require monitoring at 

any facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. We must act NOW to stop the destruction of our 

planet! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6195 

Name: S. Bonness 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. It is irresponsible to allow continued toxic 
55 

substances to pollute the air and water. Detrimental effects of the combination 

of all these substances are playing out in interaction with the Western lifestyle 

diet, and manifesting in huge numbers of individuals with chronic disease. We 

must put a stop to this. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6194 

Name: S. Woodall 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. We cannot claim to love children and yet allow the 

air they breathe to be polluted in the name of corporate profits. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6193 

Name: A. Raich 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). You 

have a responsibility to the American people to protect them from the health 

hazards posed by these emissions. Stop bowing to the pressures from big 

business and start doing your job! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6192 

Name: L. Paulson 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 
56 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Here in Milwaukee we are often warned of ozone 

levels and of various pollutants which lower our air quality and endanger the 

health of many residents. While some progress has been made and there is 

greater awareness that there indeed are problems, any relaxation of monitoring, 

particularly with several large power generating facilities and other large 

industries nearby, could well leave us unaware and therefore unprepared of the 

presence of lead and other pollutants in our air. Please enact strong monitoring 

rules which would protect public health and safety. Aren't public health and 

safety the EPA's highest priority? I would hope so.

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6171 

Name: Laurence R. 

Organization: 

Comment: The cost of the physical and mental damage done by lead poisoning 

far outweighs the profit to the industry from compromised standards. I strongly 

urge the EPA to enact rules to require monitoring at any facility that emits more 

than half a ton of airborne lead per year (.50 tpy). Monitoring this dangerous 

pollution will improve the health and well being of our community, especially 

our children who are particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6201 

Name: M. Mataya 

Organization: 

Comment: The more we put into the air, the more asthma and other respiratory 

problems we have, as well as neural and physical damage. I strongly urge the 

EPA to enact rules to require monitoring at any facility that emits more than 

half a ton of airborne lead per year (.50 tpy). Monitoring this dangerous 

pollution will improve the health and well being of our community, especially 

our children who are particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 
57 

Comment ID: OAR-2006-0735-5979 

Name: J. McCallay 

Organization: 

Comment: Please protect our environment. That's your job. I strongly urge the 

EPA to enact rules to require monitoring at any facility that emits more than 

half a ton of airborne lead per year (.50 tpy). Monitoring this dangerous 

pollution will improve the health and well being of our community, especially 

our children who are particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5971 

Name: A. Kiepe 

Organization: 

Comment: Facilities that emits more than half a ton of airborne lead per year 

(.50 tpy). Monitoring this dangerous pollution will improve the health and well 

being of our community, especially our children who are particularly 

vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5990 

Name: M. Rosenfeld 

Organization: 

Comment: I have just had 20 EDTA chelation treatments to get lead out of my 

body. And tests have shown that lead IS being eliminated by these treatments, 

which I hope will help ameliorate the chemical sensitivity condition I have. I 

strongly urge the EPA to enact rules to require monitoring at any facility that 

emits more than half a ton of airborne lead per year (.50 tpy). Monitoring this 

dangerous pollution will improve the health and well being of our community, 

especially our children who are particularly vulnerable to the risks posed by 

lead toxicity. I am almost 80 years old. I thought that the elimination of leaded 

gasoline and the warnings about drinking wine from leaded crystal would 

eliminate the hazard of lead for those younger than I. But it seems this isn't so, 

since I now find there is lead in our air from factories and smelting plants. We 

obviously need tougher emissions standards. 
58 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5988 

Name: L. Godshall 

Organization: 

Comment: As citizens, we are helpless to do anything about this daily assault 

on our health. We look to you as the only way to regulate dangerous lead in our 

atmosphere. I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5987 

Name: M. Vaughn 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. At some point we must respect human health over 

the almighty dollar. Thank you! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5986 

Name: M. Garrett 

Organization: 

Comment: The time is now. We know the dangers of lead. Now let's act upon 

this knowledge. America is watching. I strongly urge the EPA to enact rules to 

require monitoring at any facility that emits more than half a ton of airborne 

lead per year (.50 tpy). Monitoring this dangerous pollution will improve the 

health and well being of our community, especially our children who are 
59 

particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5983 

Name: S. Anderson 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. This is what I like to call a "no-brainer." It's time to 

put the human health ahead of corporate interest. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5982 

Name: M. McLoone 

Organization: 

Comment: Monitoring this dangerous pollution will improve the health and 

well being of our community, especially our children who are particularly 

vulnerable to the risks posed by lead toxicity. Not monitoring enables the 

polluters to continue sacrificing long-term community health and prosperity for 

many in favor of their short-term profits for a select few. In order for a market 

system to work properly, safeguards like these must be established. So what's it 

going to be - excessive profits and pollution or public health and prosperity? 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5992 

Name: M. Cuma 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 
60 

risks posed by lead toxicity. This is particularly pressing for me and my family 

since we live in Salt Lake City, Ut. which has a large copper smelter next to a 

1+ million metro area and is downwind from many mining operations to the 

west. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5980 

Name: L. Cohen 

Organization: 

Comment: If our intention as a group of human beings that share one planet is to 

thrive in a future of healthy existence, then we must make the necessary 

changes to allow that reality. I strongly urge the EPA to enact rules to require 

monitoring at any facility that emits more than half a ton of airborne lead per 

year (.50 tpy). Monitoring this dangerous pollution will improve the health and 

well being of our community, especially our children who are particularly 

vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5993 

Name: N. Ross 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). I can't 

imagine how someone could argue against such a rule. The harmful effects of 

lead are widely known. Don't let the financial gain of a few carry more value 

than the health of us all. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5978 

Name: R. Clarksen 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 
61 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. I urge you to put the health and safety of everyone 

in this country ahead of the interests of companies who are only concerned with 

their bottom line. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5977 

Name: D. Peick 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. We cannot afford to ignore the effects of 

cumulative exposure to even small amounts of toxins, as they are present 

everywhere in our environment. The long term health effects are not fully 

understood at this time, but preliminary evidence suggests that the effects of all 

these toxins are harming our health as a society. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5976 

Name: J. Kindel 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. We took as lead out of our gas, we are healthier 

now because of it let's not blow it now. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5975 
62 

Name: L. Dhanani 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. It is very important that the EPA be given the 

legislative means necessary to regulate clean air. Without this happening, who 

is going to make sure that toxic lead and other pollutants are not belched into 

our skys. We need strict standards to be enforced now more than ever. Please 

work for the people and not corporate interests. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5974 

Name: L. Jordan 

Organization: 

Comment: I am writing to express my strong support for enacting rules 

requiring sites releasing more than .5tpy of lead to be monitored. Speaking as a 

woman who is planning to bring children into the world in the next few years, I 

am extremely concerned about the adverse and permanent effects that 

environmental toxins, including airborne lead, have on children. We badly need 

new rules that allow us to monitor these poisons and enforce emissions 

standards. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5973 

Name: J. Knier 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Additionally, our government needs to LIMIT the 

amount of airborne lead. It is no longer acceptable to protect the profits of a few 

at the expense of every American citizen. 

Response: Responded to in preamble. 
63 

Comment ID: OAR-2006-0735-6011 

Name: W. and A. Selfridge 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children and grandchildren who are particularly 

vulnerable to the risks posed by lead toxicity. By now, everyone knows of the 

dangers of lead poisoning. Please take the lead in preventing it. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5981 

Name: L. Krantz 

Organization: 

Comment: It is important that our government agencies are funded and 

supported in their efforts to monitor the safety of all Americans. This means 

that the EPA should be directed to monitor all potential risks to human health. 

Lead is known to be of significant risk to children's mental development and 

significant sources of lead need to be monitored. As a Public Health Nurse I've 

spent many hours working with families exposed to lead in their household 

environment. To allow significant sources of airborne lead unmonitored 

borders on professional and governmental negligence of public obligations to 

protect. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6001 

Name: N. Joyce 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. I live with an air filter at home, an air filter at work. 

I had to pay for both. More needs to be done to protect people from harmful 

emissions. 
64 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6084 

Name: S. Roth 

Organization: 

Comment: After almost a decade of weakened, neglected or dismantled 

environmental policy, now is the time to undo the damage wrought upon our 

neighbors, friends, family and fellow humans. Right now is the time to enact 

stronger policies to mend the damage done to our air and planet. It's no question 

really, it's a simple choice. It's an act of responsibility and intelligence. Of 

respect and of acting fully human. Not just for future generations but for today 

and for ourselves. I strongly urge the EPA to enact rules to require monitoring 

at any facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6009 

Name: S. Glover 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. It is clear that we need to do all we can to clean up 

the emissions that threaten the health of the planet. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6008 

Name: E. Dastrup 

Organization: 
65 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Lead is a harmful neurotoxin that our society is 

working hard to get out of our homes, toys, and air. Please don't abdicate your 

ability to monitor the airborne lead from these facilities. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6007 

Name: R. Dunning 

Organization: 

Comment: Listen up EPA--this is coming from a science major...I strongly urge 

the EPA to enact rules to require monitoring at any facility that emits more than 

half a ton of airborne lead per year (.50 tpy). Monitoring this dangerous 

pollution will improve the health and well being of our community, especially 

our children who are particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6006 

Name: P. Ward 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. How can our children be future leaders with a 

diminished mental capacity from lead poisoning? 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6005 

Name: B. Christlieb 

Organization: 
66 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. While I DO NOT believe in cap and trade and 

climate change, I believe that we should "clean up our yard" and stop poisoning 

the air we breath and stop poisoning the water we drink...meaning do NOT 

fluoridate the water. It too, is poison. We are to be good stewards of what God 

has granted us! Oops...did I say that outloud? YES...GOD! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6004 

Name: O. Lahav 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Don't bend to political pressure! Peoples' lives are 

at risk! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5991 

Name: M. Suda 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. For God's sake, what could be more basic and 

decent than protecting our precious little ones from heavy metals that destroy 

their IQ's and nervous systems? C'mon EPA, get the lead out and keep it out!! 

Thank you! 

Response: Responded to in preamble. 
67 

Comment ID: OAR-2006-0735-6002 

Name: M. Okuzumi 

Organization: 

Comment: It's well known how harmful lead is to young children. To protect 

public health please enact rules to require monitoring of sources emitting more 

than half a ton a year into the air. Your own technical analysis supports this. 

please take this step to protect public health. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5970 

Name: K.J. Kaye 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. In light of incontrovertible molecular evidence of 

lead neurotoxicity, even in nanograms, downgrading lead monitoring from any 

producer is irresponsible in the extreme. It is retrograde. It flies in the face of 

knowledge. Fetal, neonate, and child health, let alone nonhuman 

considerations, are not economic blue sky factors. Have a spine and stand up for 

stringent monitoring by the EPA of all lead production sources. You know it 

makes sense. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6000 

Name: N. Griffin 

Organization: 

Comment: I am writing to urge you to revisit these rules about monitoring lead 

pollution. The volume of research showing the harmful effects of lead in the 

environment should be compelling enough reason not to keep weak and 

ineffective monitoring in place. Monitoring this dangerous pollution will 

improve the health and well being of our community, especially our children 

who are particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 
68 

Comment ID: OAR-2006-0735-5999 

Name: B. Cox 

Organization: 

Comment: Not to monitor some? Reduce the effectiveness of monitoring? 

Reduce the protections for our children?! This should not even be a question. I 

strongly urge the EPA to enact rules to require monitoring at any facility that 

emits more than half a ton of airborne lead per year (.50 tpy). Monitoring this 

dangerous pollution will improve the health and well being of our community, 

especially our children who are particularly vulnerable to the risks posed by 

lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5998 

Name: N. Mcnamara 

Organization: 

Comment: PLEASE DON'T LET CORPORATE GREED WRITE OUR

LAWS! I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5997 

Name: K. Narveson 

Organization: 

Comment: Please act in the public interest, and enact rules to require 

monitoring at any facility that emits more than half a ton of airborne lead per 

year (.50 tpy). There's no debate about the toxic effects of lead poisoning. 

Therefore, facilities should not be allowed to violate emissions standards and 

harm public health. But without monitoring, we can't know about violations, so 

clearly, we need careful monitoring - and clean facilities needn't fear 

monitoring. Please act in the public interest, and enact rules to require 

monitoring at any facility that emits more than half a ton of airborne lead per 
69 

year (.50 tpy). There's no debate about the toxic effects of lead poisoning. 

Therefore, facilities should not be allowed to violate emissions standards and 

harm public health. But without monitoring, we can't know about violations, so 

clearly, we need careful monitoring - and clean facilities needn't fear 

monitoring. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5996 

Name: N. Honeychuck 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. As a provider of primary health care I absolutely 

and firmly believe emissions should be thoroughly and strictly monitored -- 

whatever gets into our lungs, gets into our bodies!

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5995 

Name: N. Walker 

Organization: 

Comment: Lead in air = bad. I strongly urge the EPA to enact rules to require 

monitoring at any facility that emits more than half a ton of airborne lead per 

year (.50 tpy). Monitoring this dangerous pollution will improve the health and 

well being of our community, especially our children who are particularly 

vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5994 

Name: N. Wang 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 
70 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Why must the EPA neglect the health and 

wellbeing of the very people you are charged to protect? 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6003 

Name: O. Pierce 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. I have a personal interest in how clean the air is - 

my wife suffers from asthma. Please consider the health of the nation. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5935 

Name: P. Hosler 

Organization: 

Comment: I support EPA's proposed standard of monitoring air for lead at any 

facilities that emit .5 ton of lead or more. This is based on technical analysis, 

though there is no safe level of lead exposure for children. I also think it is 

important to monitor lead in the ambient air, especially downwind from the 

source. I live in Missouri, and the lead in the Herculaneum area has hurt many 

people. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5972 

Name: K. Held 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 
71 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. My son, who has learning challenges due to a 

stroke in utero, also has high lead levels, so he has to deal with a double 

whammy. Please do all you can to keep lead away from our children! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5925 

Name: Justin Casson 

Organization: 

Comment: The EPA is proposing to change the lead emission threshold at 

which monitoring agencies are presumptively required to conduct lead 

monitoring from 1.0 tpy (tons per year) to .50 tpy. The EPA’s analysis noted 

that a .50 tpy lead source could possibly cause ambient lead concentrations to 

exceed the revised lead NAAQS (National Ambient Air Quality Standards). It 

can be argued that the current 1.0 tpy emission threshold might not provide for 

an adequate margin of safety as required by the Clean Air Act. However, 

reducing the emissions threshold to .50 is an arbitrary decision that is likely to 

place an unnecessary burden on monitoring agencies to evaluate sources that 

very likely have no possibility of exceeding the NAAQS standards. Instead, I 

propose the emission threshold to be reduced to .75, allowing monitoring 

agencies more time and resources to inspect lead sources that are truly 

detrimental hazards. Requiring an air quality monitor to be placed near a 

facility emitting lead at the rate of .50 tpy will cause the unnecessary 

expenditure of funds that could be better apportioned to facilities emitting truly 

dangerous amounts of lead. Using the existing lead monitoring data, the EPA 

previously found that a threshold of 1.0 is more likely to clearly identify 

sources that would contribute to exceed the NAAQS. Lowering this threshold 

to .50 will not only burden the agencies, but also the facilities which have 

already lowered the emissions greatly, to a level considered nontoxic by the 

EPA’s original findings. The timeline proposed by the EPA would require 

monitoring agencies to evaluate, site, and install up to 161 source-oriented 

monitoring sites within 1 year of promulgation of the revised monitoring 

requirements. Because the revised standards are already ten-times tighter than 

the previous standards, compliance with the proposed emissions standards will 

impose an undue burden on the manufacturing facilities that already strove to 

comply with the current level. The EPA’s analysis shows that four of seven 

sites that were studied support an emission threshold less than the emission 

threshold of 1.0 tpy set by the final rule on the revised lead NAAQS. 

However, if the threshold is revised to .50 tpy, all but one of those sites are no 
72 

longer in compliance. I propose an emission threshold of .75, which is more 

manageable and will allow facilities that are not producing toxic amounts of 

lead to continue operation. 

Response: We based the revised threshold on an analysis which relied on three 

different approaches to determine what level of emissions could lead to an 

exceedence of the NAAQS. Our analysis indicates 0.50 tpy is the most 

appropriate level to establish the threshold. 

Comment ID: OAR-2006-0735-5945 

Name: Christina Ritter 

Organization: 

Comment: I support EPA's proposed 0.5 tons per year threshold for monitoring. 

In its final rule on the lead NAAQS, EPA determined that an ambient standard 

of 0.15 μg/m3 of lead is required to protect public health with an adequate 

margin of safety. Only through adequate monitoring to identify areas of 

noncompliance and actions to ensure compliance will the NAAQS serve its 

intended purpose of protecting sensitive populations sufficiently. EPA's 

proposed monitoring threshold of 0.5 tons per year will provide the information 

necessary to assess compliance with the ambient standard and to identify 

violations of the standard and is supported by the technical analysis. The one 

ton per year standard is insufficient to assure adequate protections and is an 

arbitrary level set more by considerations of convenience than contamination. 

Due to the elevated levels measured in the air and soils downwind of major lead 

emitting facilities, it is crucial that these areas be closely monitored so that 

unsafe levels of lead can be detected and measures taken to reduce the health 

threat to neighboring communities. There is no safe level of lead exposure for 

children, and the NAAQS is one of the few health-based standards that can help 

protect them from this toxin. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5944 

Name: Dick Valentinetti 

Organization: National Association of Clean Air Agencies (NACAA) 

Comment: EPA is proposing to lower the emissions threshold for 

source-oriented monitoring of lead from 1 ton per year (tpy) to 0.5 tpy. As there 

is evidence that high levels of lead exposure can occur even near sources 

emitting 0.5 tpy of lead, NACAA supports the proposal to lower the 
73 

source-oriented emissions threshold. Lowering the threshold to 0.5 tpy will also 

help regulatory agencies gather the data necessary for fully implementing the 

lead NAAQS. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5941 

Name: Catharine Fitzsimmons 

Organization: Iowa Department of Natural Resources (IDNR) 

Comment: EPA's primary analysis performed in support of its proposed 

monitoring threshold of 0.5 tpy is based on impact to source strength ratios at 

seven monitoring locations. For a given monitoring site, unless the monitoring 

locations happened to be at the point of maximum impact of the source, the 

extrapolated "lowest NAAQS violating emissions rates" for these sites will be 

biased high. If some of the seven sites chosen for analysis are impacted by dust 

that has been deposited near the lead source, then the results for those sites will 

be biased low, the emissions thresholds calculated will not provide a good 

estimate of the stack emissions that would give rise to a NAAQS violation. 

Even in the seven sites chosen for EPA's threshold calculation happen to be at 

the point of maximum impact of the facility emissions and were minimally 

impacted by emissions from wind- blown deposition, the sites chosen for the 

analysis would have to be representative of all lead facilities in order to 

extrapolate the emissions threshold from these facilities to all lead emitting 

facilities. We suggest that a better technique to estimate the emission threshold 

that is likely to give rise to a NAAQS violation is to perform dispersion 

modeling for a representative group of facilities and to examine the relationship 

between the emission rates and the concentration at the point of maximum 

impact. 

Response: As discussed in the preamble to this rule, the EPA worked with 

limited data. As a result of this and final rule, and the 2008 final rule, over 200 

source oriented monitors will be deployed. Data from these new monitors will 

be used in future rulemaking to determine if a different emission threshold or 

approach is needed. 

Comment ID: OAR-2006-0735-5940 

Name: Gail Wechsler 

Organization: Jewish Community Relations Council 

Comment: JCRC supports EPA’s proposed 0.5 tons per year threshold for 
74 

monitoring. In its final rule on the lead NAAQS, EPA determined that an 

ambient standard of 0.15 μg/m3 of lead is required to protect public health with 

an adequate margin of safety. Only through adequate monitoring to identify 

areas of noncompliance and actions to ensure compliance will the NAAQS 

serve its intended purpose of protecting sensitive populations sufficiently. 

EPA’s proposed monitoring threshold of 0.5 tons per year will provide the 

information necessary to assess compliance with the ambient standard and to 

identify violations of the standard and is supported by the technical analysis. 

The one ton per year standard is insufficient to assure adequate protections. Due 

to the elevated levels measured in the air and soils downwind of major lead 

emitting facilities, it is crucial that these areas be closely monitored so that 

unsafe levels of lead can be detected and measures taken to reduce the health 

threat to neighboring communities. There is no safe level of lead exposure for 

children, and the NAAQS is one of the few health-based standards that can help 

protect them from this toxin. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5939 

Name: Anonymous 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. It is a collective moral imperative to ensure that our 

children can trust the EPA to be a strong regulator for their health and well 

being. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5947 

Name: Therese M. Cirone 

Organization: RSR Corporation (RSR) 

Comment: RSR strongly supports EPA’s proposal to amend Section 58.l0(a)(4) 

and Appendix D to Part 58 to reduce from 1.0 tons per year (TPY) to 0.5 TPY 

of lead emissions as the presumptive threshold at which monitoring agencies 

must monitor the ambient air near lead sources that meet or exceed this 

threshold. While the RSR secondary lead smelters were NOT among the seven 
75 

whose emissions EPA sampled in connection with the proposal} RSR agrees 

with EPA’s conclusions that (1) lead sources emitting less than 1.0 TPY have 

the potential to cause ambient lead emissions to approach or exceed the 

recently-strengthened National Ambient Air Quality Standards (NAAQS) for 

lead}; and (2) monitoring agencies will be unable to reliably identify these 

sources based on a 1.0 TPY threshold, which ultimately could result in the 

failure to designate some areas as nonattainment for Iead.4 EPA’s proposal also 

seeks public comment on potential alterative monitoring thresholds between 

0.5 TPY and 1.0 TPY. RSR believes that no such alternative is necessary or 

appropriate. The proposed 0.5 TPY threshold most effectively would serve 

EPA’s expressed intention of protecting against observed NAAQS exceedences 

likely attributable to stationary sources of lead emissions, given what EPA 

described as a "dramatic drop" in emissions that were associated with leaded 

gasoline.5 As EPA’s fresh analysis of the data indicates that the proposed 0.5 

TPY monitoring threshold is necessary to attain and maintain the recently 

revised lead NAAQS, the selection of a monitoring trigger over 0.5 TPY would 

impede this objective. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5936 

Name: J. Carter 

Organization: 

Comment: being a resident of missouri, i support the proposed changes to the 

epa lead monitoring guidelines. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5950 

Name: Laurel L. Kroack 

Organization: llinois Environmental Protection Agency 

Comment: The Illinois EPA fully supports the comments provided by the 

National Association of Clean Air Agencies (NACAA) by letter dated February 

12, 2010. These NACAA provided comments stated the following; I. 

Supported Lowering the Source-Oriented Monitoring Threshold to 0.5 tons per 

year and Proposed Revising Non-Source- Oriented Requirements to Mandate 

Monitoring at NCore sites, 

Response: Responded to in preamble. 
76 

Comment ID: OAR-2006-0735-5934 

Name: B. Rasche 

Organization: 

Comment: I support Environmental Protection Agency's proposed rule 

revisions concerning ambient air monitoring requirements for the toxic metal 

lead because it will help ensure that all communities that face the risk of 

unhealthy levels of airborne lead pollution are adequately protected. The Clean 

Air Act requires the EPA to set National Ambient Air Quality Standards 

(NAAQS) at levels that protect public health with an adequate margin of safety 

(CAA § 109(b)(1)). Sufficient monitoring for compliance with the NAAQS is 

essential to achieve the goal of protecting sensitive subpopulations, like 

children and pregnant women, with an adequate margin of safety. I support 

EPA's proposed 0.5 tons per year threshold for monitoring. In its final rule on 

the lead NAAQS, EPA determined that an ambient standard of 0.15 μg/m3 of 

lead is required to protect public health with an adequate margin of safety. Only 

through adequate monitoring to identify areas of noncompliance and actions to 

ensure compliance will the NAAQS serve its intended purpose of protecting 

sensitive populations sufficiently. EPA's proposed monitoring threshold of 0.5 

tons per year will provide the information necessary to assess compliance with 

the ambient standard. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5933 

Name: J. Parker 

Organization: 

Comment: Please approve the monitoring level of 1/2 ton. If such a threshold 

becomes unnecessary, it can be adjusted once that has become apparent. Lead 

and its toxicity are well established and in this case, I think it wise to monitor 

more than less. As for the industry polluters who are inevitably going to lobby 

against this monitoring level, simply remind them that monitoring is not the 

same thing as regulation. Monitoring gives them the chance to mitigate the 

effects of an environmental problem before it becomes a reason to regulate. 

Thank you for your service to the citizens of the United States. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5932 
77 

Name: C. Boschert 

Organization: 

Comment: I support Environmental Protection Agency's proposed rule 

revisions concerning ambient air monitoring requirements for the toxic metal 

lead because it will help ensure that all communities that face the risk of 

unhealthy levels of airborne lead pollution are adequately protected. The Clean 

Air Act requires the EPA to set National Ambient Air Quality Standards 

(NAAQS) at levels that protect public health with an adequate margin of safety 

(CAA § 109(b)(1)). Sufficient monitoring for compliance with the NAAQS is 

essential to achieve the goal of protecting sensitive subpopulations, like 

children and pregnant women, with an adequate margin of safety. I support 

EPA's proposed 0.5 tons per year threshold for monitoring. In its final rule on 

the lead NAAQS, EPA determined that an ambient standard of 0.15 μg/m3 of 

lead is required to protect public health with an adequate margin of safety. Only 

through adequate monitoring to identify areas of noncompliance and actions to 

ensure compliance will the NAAQS serve its intended purpose of protecting 

sensitive populations sufficiently. EPA's proposed monitoring threshold of 0.5 

tons per year will provide the information necessary to assess compliance with 

the ambient standard and to identify violations of the standard and is supported 

by the technical analysis. The one ton per year standard is insufficient to assure 

adequate protections and is an arbitrary level set more by considerations of 

convenience than contamination. Due to the elevated levels measured in the air 

and soils downwind of major lead emitting facilities, it is crucial that these 

areas be closely monitored so that unsafe levels of lead can be detected and 

measures taken to reduce the health threat to neighboring communities. There is 

no safe level of lead exposure for children, and the NAAQS is one of the few 

health-based standards that can help protect them from this toxin. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5931 

Name: P. Zimmerman 

Organization: 

Comment: I submit these comments as a citizen of the State of Missouri, the 

number one lead mining state in the nation. I support Environmental Protection 

Agency’s proposed rule revisions concerning ambient air monitoring 

requirements for the toxic metal lead because it will help ensure that all 

communities that face the risk of unhealthy levels of airborne lead pollution are 

adequately protected. I support EPA?s proposed 0.5 tons per year threshold for 

monitoring. In its final rule on the lead NAAQS, EPA determined that an 

ambient standard of 0.15 μg/m3 of lead is required to protect public health with 

an adequate margin of safety. Only through adequate monitoring to identify 
78 

areas of noncompliance and actions to ensure compliance will the NAAQS 

serve its intended purpose of protecting sensitive populations sufficiently. The 

one ton per year standard is insufficient to assure adequate protections and is an 

arbitrary level set more by considerations of convenience than contamination. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5930 

Name: Judith Zwicker 

Organization: JZ Consulting 

Comment: Sufficient monitoring for compliance with the NAAQS is essential 

to achieve the goal of protecting sensitive subpopulations, like children and 

pregnant women, with an adequate margin of safety. I support EPA’s proposed 

0.5 tons per year threshold for monitoring. In its final rule on the lead NAAQS, 

EPA determined that an ambient standard of 0.15 μg/m3 of lead is required to 

protect public health with an adequate margin of safety. Only through adequate 

monitoring to identify areas of noncompliance and actions to ensure 

compliance will the NAAQS serve its intended purpose of protecting sensitive 

populations sufficiently. EPA’s proposed monitoring threshold of 0.5 tons per 

year will provide the information necessary to assess compliance with the 

ambient standard and to identify violations of the standard and is supported by 

the technical analysis. The one ton per year standard is insufficient to assure 

adequate protections and is an arbitrary level set more by considerations of 

convenience than contamination. Due to the elevated levels measured in the air 

and soils downwind of major lead emitting facilities, it is crucial that these 

areas be closely monitored so that unsafe levels of lead can be detected and 

measures taken to reduce the health threat to neighboring communities. There is 

no safe level of lead exposure for children, and the NAAQS is one of the few 

health-based standards that can help protect them from this toxin. I support 

expansion of the lead monitoring network because the existing monitoring 

network for lead is insufficient. Few of the current sources emitting more than 

one ton of lead per year have adequate downwind monitoring. The expansion of 

the lead monitoring network contained in the proposed rule will provide crucial 

data on the concentration of lead in ambient air so as to protect vulnerable 

populations. Monitoring downwind of facilities that emit between 0.5 and 1 

tons per year of lead is necessary to provide sufficient information about 

airborne lead levels near these facilities in order to adequately enforce the 

NAAQS and to protect health with an adequate margin of safety. The addition 

of 161 additional source-oriented monitors, for a total of 272, will significantly 

expand public health protections for communities near large industrial sources. 

Response: Responded to in preamble. 
79 

Comment ID: OAR-2006-0735-5928 

Name: J. Morian 

Organization: 

Comment: I support EPA's proposed half-ton per year threshold for monitoring. 

The EPA?s final rule on lead NAAQS indicated that an ambient standard of 

0.15 μg/m3 of lead is required to protect public health with an adequate margin 

of safety. Only a monitoring threshold of 0.5 tons per year will enable the 

agency to ensure compliance and the technical data supports this. A one ton per 

year standard is arbitrary and the figure is not rationally supported by the 

technical data underlying the .5 ton standard. There is no safe level of lead 

exposure for children, and children will not be protected without adequately 

monitoring and enforcing the NAAQS. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5927 

Name: Kenneth Cohen 

Organization: Missouri Coalition for the Environment 

Comment: I am a resident of the state of Missouri. The Clean Air Act requires 

the EPA to set National Ambient Air Quality Standards (NAAQS) at levels that 

protect public health with an adequate margin of safety (CAA § 109(b)(1)). 

Sufficient monitoring for compliance with the NAAQS is essential to achieve 

the goal of protecting sensitive subpopulations, like children and pregnant 

women, with an adequate margin of safety. I support EPA's proposed 0.5 tons 

per year threshold for monitoring. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5938 

Name: D. A. McDaniel 

Organization: 

Comment: I submit these comments as a citizen of the State of Missouri, the 

number one lead mining state in the nation and home to North America's largest 

primary lead smelter, several secondary smelters, and a 300-year history of lead 

production. I support Environmental Protection Agency's proposed rule 

revisions concerning ambient air monitoring requirements for the toxic metal 

lead because it will help ensure that all communities that face the risk of 
80 

unhealthy levels of airborne lead pollution are adequately protected. The Clean 

Air Act requires the EPA to set National Ambient Air Quality Standards 

(NAAQS) at levels that protect public health with an adequate margin of safety 

(CAA § 109(b)(1)). Sufficient monitoring for compliance with the NAAQS is 

essential to achieve the goal of protecting sensitive subpopulations, like 

children and pregnant women, with an adequate margin of safety. I support 

EPA's proposed 0.5 tons per year threshold for monitoring. In its final rule on 

the lead NAAQS, EPA determined that an ambient standard of 0.15 μg/m3 of 

lead is required to protect public health with an adequate margin of safety. Only 

through adequate monitoring to identify areas of noncompliance and actions to 

ensure compliance will the NAAQS serve its intended purpose of protecting 

sensitive populations sufficiently. EPA's proposed monitoring threshold of 0.5 

tons per year will provide the information necessary to assess compliance with 

the ambient standard and to identify violations of the standard and is supported 

by the technical analysis. The one ton per year standard is insufficient to assure 

adequate protections and is an arbitrary level set more by considerations of 

convenience than contamination. Due to the elevated levels measured in the air 

and soils downwind of major lead emitting facilities, it is crucial that these 

areas be closely monitored so that unsafe levels of lead can be detected and 

measures taken to reduce the health threat to neighboring communities. There is 

no safe level of lead exposure for children, and the NAAQS is one of the few 

health-based standards that can help protect them from this toxin. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5958 

Name: Anonymous 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5969 

Name: K. Mortensen 

Organization: 
81 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Forget the politics and remember: your job is to 

look out for the common good. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5968 

Name: K. Lindley 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5967 

Name: K. Pierce 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). I live 

on the north side of Chicago, several miles from a steel mill and other factories 

with toxic pollutants, including lead. Recently I learned I have adrenal fatigue, 

which in part comes from the chemical exposure in the city. Chicago has been 

shown to have very high lead levels in the air. When I visit my parents in 

northwest Illinois, about 100 miles from Chicago, I feel much better within 

days. The best thing that can be done for my condition is to reduce or eliminate 

the stress, including the chemicals and toxins in my life. Those discharging lead 

at the current standard reap all the benefits and pay none of the costs, such as 

the steps I am taking to detoxify and support my liver to rid myself of their lead. 

My life depends on taking this important action. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5966 

Name: A. Tindell 
82 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. I want safe air to breathe, clean water to drink, and 

safe fish to eat. Toxic lead must be kept out of our environment as much as 

possible from all sources! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5965 

Name: S. Fowler 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. It is important that we consider the future of this 

planet. Actually the planet will still be here and probably some organisms deep 

in the earth but it will be very dismal on the surface! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5964 

Name: James Brook 

Organization: Maine Department of Environmental Protection (ME DEP) 

Comment: Maine supports lowering the source-oriented monitoring threshold 

and revising the non-source oriented requirements to include an option of 

monitoring at NCore sites . 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5963 

Name: James L. Kavanaugh 
83 

Organization: Missouri Department of Natural Resources (MODNR) 

Comment: Based on our analysis, a reduction from 1.0 to 0,5 tons per year (tpy) 

in the lead source emission rate that triggers the monitoring requirement is not 

expected to significantly affect the lead' monitoring network in Missouri . This 

is due to the evaluation of many of these smaller sources in our previous 

network review. To further study the use of emission thresholds as a metric for 

monitoring site placement, the Department conducted a sensitivity analysis of a 

hypothetical coal combustion source with lead emissions of two tpy and a stack 

height of 250 feet using AERIMOD. Over a five-year meteorological period, 

this source exhibited a maximum monthly lead concentration of 0.004 

microgram/cubic meter (ug/m) . These results are conservative for coal 

combustion sources because no sources in Missouri emit two tons of lead 

except lead processing facilities (mine/mill, secondary smelter, primary 

smelter) . Further, even if a source like this existed, the concentration is well 

below the 0.075 11g/m3 threshold for a waiver of the source monitoring 

requirement . In addition, nearly all the coal combustion facilities with lead 

emissions above zero in Missouri have stacks that are well over the 250 feet 

used in this sensitivity. Therefore, the Department believes that additional 

monitoring near any large coal combustion sources in Missouri is not 

meaningful and will not provide any added benefit to the rule, but could 

consume additional resources. As a result, we suggest that such large stack 

sources should be evaluated separately from other lead sources in the context of 

development of the rule. This should include a screening approach using 

AERSCREEN or another suitable model that could be utilized to reduce further 

the source oriented lead monitoring requirement at coal combustion sources. 

Response: Monitoring agencies are encouraged to use the existing waiver 

provisions for sources where dispersion modeling demonstrates the source will 

not cause Pb concentrations to exceed 50% of the Pb NAAQS. 

Comment ID: OAR-2006-0735-5946 

Name: Arthur N. Marin 

Organization: Northeast States for Coordinated Air Use Management 

(NESCAUM) 

Comment: NESCAUM agrees with the EPA proposal to change the lead 

emission threshold at which agencies are required to conduct lead monitoring 

for National Ambient Air Quality Standard (NAAQS) purposes near a source 

from 1.0 to 0.50 tons per year (tpy) (74 FR 69051).

Response: Responded to in preamble. 
84 

Comment ID: OAR-2006-0735-5960 

Name: Russ Murray 

Organization: Ohio Cast Metals Association (OCMA) 

Comment: 1. Current Standard Already Provided Sufficient Flexibility To 

account for lead sources emitting less than 1.0 tpy of lead that may have the 

potential to cause lead concentrations to exceed the lead NAAQS, the 

November 12, 2008, final rule provided the EPA Regional Administrators the 

authority to require additional monitoring beyond the minimum monitoring 

requirements where the likelihood of lead air quality violations is significant or 

where the emissions density, topography, or population locations are complex 

and varied, therefore a change in the rule is necessary. 2. An Adequate Margin 

of Safety has been Provided The petitioners argued that the 1.0 tpy emission 

threshold would not provide for an adequate margin of safety as required by the 

Clean Air Act. Use of previous submitted NEI information, the algorithms 

contained within the air dispersion model and the flexibility described above 

does provide an adequate margin of safety. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6012 

Name: D. Jacobs 

Organization: 

Comment: I strongly urge the EPA to require monitoring at any facility that 

emits more than half a ton of airborne lead per year (.50 tpy). The EPA has set 

strict standards for many things--including diesel emissions on trucks, lead 

from gasoline, and various emissions from steel plants--that are in the best 

interests of the everyday person. In some cases, these standards have been set 

even if they put a huge financial burden on the industry. Would monitoring lead 

emissions be even close to the burden that these other industries have 

endured?? I haven't seen any data that the burden would be high. And given the 

potential for VERY SERIOUS health impacts of lead emissions, I think we 

need to monitor this industry more strictly than current regulations require. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5957 

Name: Jerry Call 
85 

Organization: American Foundry Society (AFS) 

Comment: Impact of Proposed Revisions to Lead NAAQS EPA has estimated 

that pursuant to the proposed revised monitoring threshold the number of 

industrial sources that would have to install lead monitors would increase from 

111 to 217 sources. AFS is, therefore, concerned that lowering the monitoring 

threshold for lead emissions to 0.5 tons per year could potentially have a 

significant adverse impact on many small foundries with little, if any, 

additional environmental and health protection. It is, therefore, imperative that 

EPA minimize these impacts by using the best data available that are 

representative of a foundry’s current practices to reduce lead emissions. This 

will ensure that monitoring will be imposed only on those facilities that pose the 

greatest risk and where corrective measures may be needed to achieve the lead 

NAAQS. 

Response: These monitoring requirements do not apply to industrial facilities, 

but to state and local monitoring agencies. As such, small foundries which do 

not cause Pb concentrations to exceed the Pb NAAQS will not be impacted by 

this rule. 

Comment ID: OAR-2006-0735-5956 

Name: Mark R. Vickery 

Organization: Texas Commission on Environmental Quality (TCEQ) 

Comment: There should be two primary objectives of the ambient air 

monitoring network for lead: Source-Oriented Monitoring Requirements l. To 

measure maximum ambient air concentrations near potentially significant point 

sources of lead emissions to the ambient air so data will be available to identify 

whether lead in ambient air is contributing to toxicologically significant public 

exposure to lead through ` settled dust in soil, on exterior surfaces, and on 

interior surfaces. Use of a mass per year threshold for presumptively requiring 

ambient air lead monitoring near point sources is reasonable. The Appendix D 

to Part 50 §4.5(ii) provision allowing waiver of the monitoring requirement if 

the responsible agency demonstrates that the lead "source will 110t contribute 

to_ a maximum ambient air lead concentration in excess of 50% of the NAAQS 

. . ." is also appropriate. The December 23, 2009, EPA press release announcing 

the proposed rule change to the lead ambient air monitoring requirements 

states, "Lead emitted into the air can be inhaled or can be ingested after it 

settles. Ingestion is the main route of human exposure. Children are the most 

susceptible because they are more likely to ingest lead, and their bodies are 

developing rapidly." Because the lead in settled dust presents the main lead 

absorption hazard for children, who are the most susceptible population, an 

appropriate additional screening test for waiving the ambient air lead 

monitoring requirement would be a test for lead content in settled dust or in 
86 

surface soil in the area of predicted maximum ambient air impact to which 

children have meaningful access. Because the concentration of lead in surface 

soil represents an integrated measure of the impact of a point source plus other 

sources of lead on potential exposure for children, it would be an even more 

protective screening tool than air quality dispersion modeling for _ allowing 

lead monitoring waivers. Such a screening tool for exemption from monitoring 

would be appropriate for sources that have been in place long enough to allow 

significant lead concentrations to have accumulated in soil for the soil testing to 

be representative. The five year period required for air quality dispersion 

modeling would be a reasonable minimum source life to allow the use of this 

screening method for an ambient air lead monitoring waiver. 

Response: The purpose of the emission threshold approach is to identify current 

sources of Pb that may have the potential to exceed the Pb NAAQS. The 

presence or absence of Pb in soils surrounding a facility, while certainly of 

interest for health reasons, is not a good predictor of future impacts as new 

sources may have relatively little Pb contamination in the soils while older 

facilities who have recently reduced Pb emissions may have relatively higher 

Pb contamination in soils. 

Comment ID: OAR-2006-0735-5954 

Name: Mary Munn 

Organization: Fond du Lac Reservation 

Comment: The Band supports the EPA’s efforts to tighten the monitoring 

standards for source-oriented monitoring. One- thousand pounds per year (0.5 

ton/yr) of lead emitted anywhere will result in significant exposure, both to 

people and the environment, especially within the entire area of a given facility 

and the related ambient air impact isopleths. It is essential that levels of 

exposure be documented although it may be more effective to require better 

emissions scrubbing. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5953 

Name: Sandra F. Veazey 

Organization: Florida Department of Environmental Protection 

Comment: There is an internal inconsistency in the rule with regard to the size 

of the source of emissions from a facility which must be monitored. The 

requirements. (40 CFR Part 58.10 (a) (4)). states, "A plan for establishing 
87 

source- oriented lead monitoring sites in accordance with the requirements of 

appendix D of this part for lead sources emitting greater than [emphasis added] 

0.50 tpy but less than l.0 tpy shall be submitted to the Regional Administrator 

no later than June 30. 2010. The plan shall provide for the required 

source-oriented lead monitoring sites for lead sources emitting greater than 

[emphasis added] 0.50 tpy but less than l.0 tpy be operational by December 30. 

20l0." While the requirements. (40 CFR Part 58 Appendix D 4.5 (a)). later state, 

"...At a minimum there must be one source oriented SLAMS site located to 

measure the maximum lead concentration in ambient air resulting from each 

lead source which emits 0.50 or more [emphasis added] tons per year .... " The 

Division would support accepting the description of "greater than 0.50 tons per 

year" since this threshold would create greater stability in the monitoring 

requirements. 

Response: The EPA regrets the confusion created by its loose use of terms. The 

correct meaning is "which emits 0.50 tpy or more." 

Comment ID: OAR-2006-0735-5953 

Name: Sandra F. Veazey 

Organization: Florida Department of Environmental Protection 

Comment: The Florida Department of Environmental Protection`s Division of 

Air Resource Management (division) does not support the proposed lead 

ambient monitoring requirement change. The reduction of the monitoring 

threshold for lead source emissions from l .0 tons per year (tpy) to 0.5 tpy 

would not add any additional stationary lead sources in the 2005 National 

Emission Inventory for Florida. It would add 13 airports as sources 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5951 

Name: Avinash Kar 

Organization: Natural Resources Defense Council (NRDC) et al. 

Comment: I. In Establishing Monitoring Requirements Under the NAAQS, 

EPA Must Protect the Health of Sensitive Subpopulations With an Adequate 

Margin of Safety to Protect Against Uncertainties and Must Base its Decisions 

on the Latest Scientific Knowledge. The Clean Air Act (“CAA”) requires the 

EPA to set NAAQS at levels that protect public health with an adequate margin 

of safety. CAA § 109(b)(1). In its final rule on the NAAQS, EPA determined 

that an ambient standard of 0.15 μg/m3 of lead is requisite to protect public 
88 

health with an adequate margin of safety. National Ambient Air Quality 

Standards for Lead, 73 Fed. Reg. 66964, 67006 (Nov. 12, 2008). EPA has 

characterized the monitoring requirements as designed to provide the 

information necessary to assess compliance with that ambient standard and to 

identify violations. See 73 Fed. Reg. at 67024. Inadequate source-specific 

monitoring undermines the purpose of the NAAQS by making it more difficult, 

if not impossible, to assure that lead levels in the ambient air around major lead 

sources do not exceed the 0.15 μg/m3 standard required to protect public health. 

Without adequate monitoring to identify areas of noncompliance and 

subsequent steps to ensure compliance, the NAAQS cannot serve its intended 

purpose of protecting health with an adequate margin of safety. As discussed 

further below, EPA’s analysis shows that a monitoring threshold of 0.5 tons per 

year will likely capture all potential violations of the health-based NAAQS 

standard. It thus provides an adequate margin of safety to protect against 

uncertainties based on a scientific analysis, and we are pleased to support 

EPA’s proposed threshold for monitoring. To Protect Public Health with an 

Adequate Margin of Safety, EPA Should Adopt the Proposed Rule Provision 

that Would Require the Installation of Source Monitors Near Each Lead Source 

Which Emits 0.50 or More Tons Per Year of Lead. The latest and best available 

scientific evidence supports the adoption of a near-source monitoring threshold 

of 0.50 tons per year of lead to protect public health with an adequate margin of 

safety. The available evidence demonstrates that facilities emitting 0.5 tons per 

year of lead or more have the potential to contribute to a violation of the 

NAAQS. According to the US EPA 2005 National Emissions Inventory (NEI), 

almost 600 tons of lead were released into the atmosphere from industrial 

facilities. The lead from these facilities can result in unsafe levels of lead in the 

air and, once deposited in the soils, represents a reservoir for future 

contamination of airborne dust. Multiple studies have documented elevated 

levels of lead in the soils surrounding industrial facilities.1 2 3 Similarly, the 

existing network of monitors of airborne lead levels in the EPA Air Quality 

System have documented elevated levels of lead downwind from industrial 

sources. 74 Fed. Reg. at 69052-53. The average of the maximum 3-month 

average lead concentration measured between 2001 and 2003 downwind from 

the seven facilities where EPA currently has adequate monitoring was 0.78 

μg/m3. This is approximately 3 times greater than the nationwide average 

measured during those same years and more than 6 times the current NAAQS.4 

Due to the elevated levels measured in the air and soils downwind of major lead 

emitting facilities, it is crucial that these areas be closely monitored so that 

unsafe levels of lead can be detected and measures taken to reduce the health 

threat to neighboring communities. However, the existing monitoring network 

for lead is insufficient to adequately protect public health by monitoring for 

these potential violations of the NAAQS. While the 2005 NEI identifies 

approximately 100 sources emitting more than 1 ton of lead per year, only 7 of 

them currently have adequate downwind monitoring data. The expansion of the 

lead monitoring network contained in the proposed rule will provide crucial 

data on the concentration of lead in ambient air so as to protect vulnerable 
89 

populations. EPA’s evaluation of ambient lead levels measured downwind 

from major sources demonstrates that facilities with less than 1 ton per year of 

lead emissions have the potential to cause ambient lead levels in exceedence of 

the NAAQS. Therefore, monitoring downwind of facilities that emit between 

0.5 and 1 tons per year of lead is necessary to provide sufficient information 

about airborne lead levels near these facilities in order to adequately enforce the 

NAAQS and to protect health with an adequate margin of safety. The addition 

of up to 161 additional source-oriented monitors, for a total of 272, will 

significantly expand public health protections for communities near large 

industrial sources. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5951 

Name: G. Vinson Hellwig 

Organization: The Michigan Department of Natural Resources and 

Environment (MDNRE) 

Comment: 2. The implementation of lead monitoring near sources between 0.5 

and 1.0 T/v should be delayed until the EPA can review data from the 

monitoring currently being conducted near sources emitting greater than 1 T/y. 

In evaluating the need for ambient air monitoring near lead sources emitting 

between 0.5 and 1 T/y, the EPA reviewed data from existing air monitoring 

stations located near sources. While it is understandable why the EPA would do 

so, relying on such data could overestimate the impact that lead sources have on 

a nationwide basis as these existing monitors were likely sited because of 

source-specific problems. Rather than relying on this historical data, the 

MDNRE suggests that the EPA utilize the data collected by state and local 

agencies since January 1, 2010 for those sources emitting more than 1 T/y. The 

MDNRE suggests that this data would be more representative of sources on a 

nationwide basis. As such, we request that the EPA delay implementation of the 

monitoring of sources between 0.5 and 1.0 T/y until these results can be 

evaluated. Doing so would ensure the proper prioritization of the EPA and state 

resources. lf the EPA is lowering the monthly threshold to 0.5 T/y solely to 

address petitions by the National Resource Defense Council and others (74 FR 

69051), the MDNRE would like to point out that the EPA’s earlier 

requirements that modeled sources must meet fifty percent of the lead NAAQS 

before a waiver could be granted goes a long way to meeting this objective. The 

MDNRE recognizes that the EPA is once again proposing to grant a waiver 

from monitoring based upon modeling. However, modeling analyses are not 

without costs. 

Response: As described in the preamble to the final rule, the EPA believes that 

there is adequate information supporting the need to change the emission 
90 

threshold to 0.50 tpy to finalize that requirement now. Delaying this change 

could lead to delays in identifying non-attainment areas and the implementation 

of controls necessary to reduce Pb concentrations to healthy levels. 

Comment ID: OAR-2006-0735-5962 

Name: Jordan Heiman 

Organization: 

Comment: I support EPA’s proposed 0.5 tons per year threshold for 

monitoring. In its final rule on the lead NAAQS, EPA determined that an 

ambient standard of 0.15 μg/m 3 of lead is required to protect public health with 

an adequate margin of safety. Only through adequate monitoring to identify 

areas of noncompliance and actions to ensure compliance will the NAAQS 

serve its intended purpose of protecting sensitive populations sufficiently. 

EPA’s proposed monitoring threshold of 0.5 tons per year will provide the 

information necessary to assess compliance with the ambient standard and to 

identify violations of the standard and is supported by the technical analysis. 

The one ton per year standard is insufficient to assure adequate protections and 

is an arbitrary level set more by considerations of convenience than 

contamination. Due to the elevated levels measured in the air and soils 

downwind of major lead emitting facilities, it is crucial that these areas be 

closely monitored so that unsafe levels of lead can be detected and measures 

taken to reduce the health threat to neighboring communities. There is no safe 

level of lead exposure for children, and the NAAQS is one of the few 

health‐based standards that can help protect them from this toxin. Because 

healthy air is important for all human and environmental health, I further urge 

EPA to attach specific conditions to the issuance of waivers of the 

source‐oriented monitoring requirements for lead and to provide more guidance 

to states concerning the kinds of sources that are expected to contribute to 

exceedances of the lead air standard. The conditions for obtaining waivers 

should be sufficiently strict to limit their use and states should be advised how 

to conduct an adequate monitoring program so that their states demonstrably 

meet the standards for healthy air. For example, site‐specific data rather than 

generic, unreliable emissions estimates should be used to evaluate the impact of 

a source’s emissions on ambient air lead concentrations. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6065 
91 

Name: Dennis Lane 

Organization: Doe Run Resources Corporation 

Comment: EPA explained its selection process as seeking >1 tpy sites with a 

source-oriented monitor within a 1-mile radius and having 2002 lead 

concentration data. Id. This process produced seven sites with those 

characteristics from which individual site specific emission thresholds were 

calculated. Id. at 69052-53, Table 1. Given that the purpose of the exercise is to 

determine if sites with <1 tpy would cause ambient air to exceed the NAAQS 

level, the obvious question is why EPA extrapolated from >1 tpy sites rather 

than studying what actually occurred at <1 tpy sites. In support of its proposal 

to lower the monitoring emissions threshold, EPA states that "[b]ased on this 

sample" of >1 tpy sites, "it appears that lead sources that emit less than 1 tpy 

have the potential to cause ambient air concentrations to exceed or approach the 

lead NAAQS." Proposed Rule, 74 Fed. Reg. at 69054. The conditional tone of 

this sentence reflects the lack of factual analysis of emissions at <1 tpy sites, 

and the substitution, instead, of a mathematical construct that uses straight-line 

extrapolation from >1 tpy sites to estimate what would happen at a <1 tpy 

emission rate with all other things held constant. While the mathematical 

construct produces results, the real (and unanswered) question is how those 

results compare to what actually happened at <1 tpy sites. That question can be 

answered only by comparing concrete data about emissions levels at <1 tpy 

sites to the extrapolation from >1 tpy sites. No explanation was given of why 

actual data from <1 tpy sites were not used. The problems with relying on 

extrapolation is highlighted by use of the "ratio" (later called the estimated 

design values in Table 3), which is the result of dividing the 3-month average 

lead concentration by the tpy emission rate for each sample facility (74 Fed. 

Reg. at 69052-53, Table 1), to determine a site-specific threshold. Initially, a 

question arises as to whether there is any statistical basis for the premise 

inherent in the ratio calculation, viz., that a correlation exists between the two 

numbers being divided, and, if so, whether a similar correlation would be found 

at <1 tpy sites. Looking at Table 1 does not yield an apparent correlation, 

suggesting that other factors besides tpy emissions play a stronger role in 

determining whether a particular source can meet the NAAQS. See, e.g., Notice 

of Proposed Rule, 73 Fed. Reg. 29184, 29263 (May 20, 2008)("We recognize 

that a number of factors influence the actual impact a source of Pb has on 

ambient Pb concentrations (e.g., local meteorology, emission release 

characteristics, and terrain)."). While such factors were to be considered in the 

waiver process, id., the lack of correlation suggests that they should have also 

been considered in determining how to calculate a realistic "ratio." Other than 

picking a variety of sites with presumably differing individual circumstances, 

no consideration was given to what effects other factors might have on the 

"ratio" results from which the site- specific thresholds were derived. The 

efficacy of using this >1 tpy sample to extrapolate (based on tpy ratios) what 

purportedly would happen at <1 tpy sites is also called into question by the wide 

variance between the estimated minimum and maximum site specific emission 
92 

thresholds. 74 Fed. Reg. at 69053 at Table 4. The minimum and maximum 

differ by roughly a factor of 10 in both 2002 (0.42 v. 4.90) and in 2005 (0.32 v. 

2.93). Id. The wide variance also supports the view that other factors besides 

tpy should have been incorporated into the calculus. Interestingly, the "ratio" 

between the yearly emission rate (tpy) and the site-specific emission threshold 

in Table 1 appears to show the opposite of what EPA concluded. For example, 

Doe Run's smelter with by far the highest tpy also has the highest threshold, and 

site id 420110717 with the second highest tpy also has the second highest 

threshold. These two sites thus have the lowest "ratios" listed in Table 1, 

meaning the lowest Pb ambient air levels per tpy. 74 Fed. Reg. at 69052. No 

evidence has been presented as to what types of "ratios" <1 tpy sites would 

have. Rather than extrapolating from a limited range of >1 tpy sites, data should 

have been gleaned 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6055 

Name: S. Snow 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Lead poisoning can affect almost every organ 

system. Organ systems primarily affected include the central and peripheral 

nervous systems, cardiovascular, renal, gastrointestinal, endocrine, and 

hematologic systems. Lead can also adversely impact reproductive functioning 

and the developing fetus and child. Lead compounds are listed as a 2A, 

probably carcinogenic to humans and 2B, possibly carcinogenic to humans. 

With lead, the precautionary statement should be used to protect the living as 

well as the next generation --the as yet, unborn. Source: Hazardous Substances 

Data Bank at National Library of Medicine. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6072 

Name: V. Kramer 

Organization: 

Comment: The mandate of the EPA is to protect the environment and the 
93 

public, not special interests. I strongly urge the EPA to enact rules to require 

monitoring at any facility that emits more than half a ton of airborne lead per 

year (.50 tpy). Monitoring this dangerous pollution will improve the health and 

well being of our community, especially our children who are particularly 

vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6071 

Name: B. A. Daily 

Organization: 

Comment: The message below expresses my concerns about the urgent need to 

control the release of toxic pollution. Thank you for your attention to this 

serious matter. I strongly urge the EPA to enact rules to require monitoring at 

any facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6070 

Name: B. Berger 

Organization: 

Comment: The right to clean air to breathe is as central as any right mentioned 

in the Constitution. I strongly urge the EPA to enact rules to require monitoring 

at any facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6069 

Name: M. Perron 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 
94 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. I worked in lead poisoning prevention and am 

aware of the importance of this issue for children's health. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6068 

Name: M. Parse 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Today's children are tomorrow's citizens, and they 

will need large brain power and healthy bodies to keep our country functioning. 

Please don't jeopardize the world's future. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6067 

Name: J. Moss 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Those polluters will be the only people that can 

afford the healthcare needed to combat lead poisoning...

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6074 

Name: W. Henn 

Organization: 

Comment: The EPA cannot drop the ball on lead emissions monitoring. It's too 

important an issue. I strongly urge the EPA to enact rules to require monitoring 
95 

at any facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6065 

Name: Dennis Lane 

Organization: Doe Run Resources Corporation 

Comment: Indeed, the difficulty in drawing any viable conclusions about what 

would occur at <1 tpy sites from this sample is underscored by comparing the 

medians and the means of the ranges of numbers listed in Table 4. The means 

are not listed on the Table, but they can be calculated from the range of 

numbers. The median for the 2002 range is 0.64, while its mean is 1.60; for the 

2005 range, the median is 0.62, while its mean is 1.08. Proposed Rule, 74 Fed. 

Reg. at 69053, Table 4. These differences show not only that the ranges of 

numbers are skewed to the low side, but also that the choice of using the 

median, not the mean, was determinative of the conclusion that the threshold 

should be lowered. As the means (1.60 and 1.08) are above 1, they support an 

over 1 tpy threshold, and thus validate the Final Rule's conclusion that "an 

emission threshold of 1.0 tpy 'is more likely to clearly identify sources that 

would contribute to exceedances of the NAAQS' as compared to a lower 

emission threshold." Proposed Rule, 74 Fed. Reg. at 69054. In the initial 

emissions threshold analysis in this docket, EPA employed an arithmetic mean 

to determine the appropriate threshold. See Notice of Proposed Rule, 73 Fed. 

Reg. at 29263 ("The arithmetic mean of the four methods suggests a maximum 

emission impact of 0.5 μg/m3 per 1,000 kg Pb emitted per year."). Although 

comments were requested on the use of the "arithmetic mean" in the analysis, 

id., no party challenged its use. The Final Rule stated that the calculation was 

"intended to represent a reasonable worst case scenario." 73 Fed. Reg. at 67026. 

Likewise, the petitioners seeking reconsideration of the threshold did not 

challenge use of the arithmetic mean; arguing, instead, that "EPA failed to 

provide proper public comment on the 1.0 tpy threshold, [that its selection] 

"was arbitrary and capricious and that the EPA did not follow its own analysis." 

Proposed Rule, 74 Fed. Reg. at 69052.1 Nor is an explanation given in the 

Proposed Rule as to why use of arithmetic mean was abandoned in favor of the 

median. Given the critical importance of the choice between the mean and the 

median to what the ranges represent, EPA should explain why it reversed 

course by using the median instead of the mean without even calculating the 

mean, or analyzing why the mean, which had been considered the appropriate 

range point up to now, should be replaced with the median as the reasonable 
96 

measure of the ranges. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6075 

Name: K. Weinmann 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. These same children already suffer from childhood 

obesity and diabetes, it is imperative that we do all we can to protect them from 

further assaults on their development. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6063 

Name: V. Olds 

Organization: 

Comment: Please do the right thing. The EPA should enact rules to require 

monitoring at any facility that emits more than half a ton of airborne lead per 

year (.50 tpy). This is a dangerous pollutant and serious threat to human health. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6062 

Name: T. McMillan 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. My hope is that under the leadership of Secretary 

Salazar this agency will once again uphold the standard set by its name - the 

Environmental Protection Agency. 
97 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6060 

Name: B. Iverson 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Lead can lead to difficulty in learning in our young 

citizens. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6059 

Name: T. Hill 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. It's time the EPA returned to being the strong 

resolute guardian defending the environment and the citizens of the United 

States. The EPA needs the "teeth" it once had and more. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6058 

Name: L. Wiener 

Organization: 

Comment: I do not need to tell you about the many studies showing the harm 

lead does to all of us, but especially to children. We have the information. Now, 

it is your job to act on that information and require monitoring of all facilities 

which put more than one half ton per year of lead into our air. How else can you 

protect us? 
98 

Response: No response needed. 

Comment ID: OAR-2006-0735-6057 

Name: K. Taebel 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. PLEASE LET ME ASSURE MY GTRANDKIDS 

THEIR FUTURE IS SAFE-KAY TAEBEL, AUSTIN 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6010 

Name: B. McFarland 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Why do we have to constantly monitor this 

situation ~ that's your job! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6066 

Name: N. S. Rapp 

Organization: 

Comment: I support EPA's proposed 0.5 tons per year threshold for monitoring. 

In its final rule on the lead NAAQS, EPA determined that an ambient standard 

of 0.15 pg/m3 of lead is required to protect public health with an adequate 

margin of safety . Only through adequate monitoring to identify areas of 

noncompliance and actions to ensure compliance will the NAAQS serve its 
99 

intended purpose of protecting sensitive populations sufficiently. EPA's 

proposed monitoring threshold of 0.5 tons per year will provide the information 

necessary to assess compliance with the ambient standard and to identify 

violations of the standard and is supported by the technical analysis. The one 

ton per year standard is insufficient to assure adequate protections and is an 

arbitrary level set more by considerations of convenience than contamination. 

Due to the elevated levels measured in the air and soils downwind of major lead 

emitting facilities, it is crucial that these areas be closely monitored so that 

unsafe levels of lead can be detected and measures taken to reduce the health 

threat to neighboring communities. There is no safe level of lead exposure for 

children, and the NAAQS is one of the few health-based standards that can help 

protect them from this toxin. Because healthy air is important for all human and 

environmental health, I further urge EPA to attach specific conditions to the 

issuance of waivers of the source-oriented monitoring requirements for lead 

and to provide more guidance to states concerning the kinds of sources that are 

expected to contribute to exceedances of the lead air standard. The conditions 

for obtaining waivers should be sufficiently strict to limit their use and states 

should be advised how to conduct an adequate monitoring program so that their 

states demonstrably meet the standards for healthy air. For example, 

site-specific data rather than generic, unreliable emissions estimates should be 

used to evaluate the impact of a source's emissions on ambient air lead 

concentrations . I support expansion of the lead monitoring network because 

the existing monitoring network for lead is insufficient. Few of the current 

sources emitting more than one ton of lead per year have adequate downwind 

monitoring. The expansion of the lead monitoring network contained in the 

proposed rule will provide crucial data on the concentration of lead in ambient 

air so as to protect vulnerable populations. Monitoring downwind of facilities 

that emit between 0 .5 and 1 tons per year of lead is necessary to provide 

sufficient information about airborne lead levels near these facilities in order to 

adequately enforce the NAAQS and to protect health with an adequate margin 

of safety . The addition of 161 additional source-oriented monitors, for a total of 

272, will significantly expand public health protections for communities near 

large industrial sources. Otherwise, those downwind communities will not 

receive NAAQS protections. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6083 

Name: F. Epsen 

Organization: 

Comment: that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 
100 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. You are EPA, after all.....your job is to PROTECT 

the citizens of this country. Thank you for doing your job, 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6092 

Name: S. Somers 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. As a mother, my trust in our government hinges on 

protecting health and well being above all 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6091 

Name: S. Hayworth 

Organization: 

Comment: I urge the EPA to require monitoring of lead emissions by any 

large-scale polluter (any that emits more than half a ton of airborne lead per 

year). The serious health risks posed by lead are well-documented. Don't sell 

out our health to corporate lobbyists! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6090 

Name: S. Burstein 

Organization: 

Comment: Monitoring of airborne lead at finer levels is of paramount 

importance due to its toxicity. I strongly urge the EPA to enact rules to require 

monitoring at any facility that emits more than half a ton of airborne lead per 

year (.50 tpy). Monitoring this dangerous pollution will improve the health and 

well being of our community, especially our children who are particularly 
101 

vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6089 

Name: S. Linquist 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. We must be more proactive in cleaning up our air. 

Let's get this together and do it! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6088 

Name: S. S. Joseph 

Organization: 

Comment: As one who has suffered from the effects of second-hand smoke all 

of my life, I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. It may be too late to do anything for those of us 

who grew up in factory towns and who were exposed to all of toxic fumes we 

generated, through our ignorance. But, it is not too late to clean up our 

environment for future generations. For the sake of our children, grand children 

and all who will follow us, it is our duty to do whatever we can to leave this 

place better than we found it. Please do what you can to see to it that we do. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6087 

Name: S. Matchett 

Organization: 
102 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Allowing lead in our environments would be a false economy over the long run 

- and the long run is the only thing to consider with something as deadly as lead. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6086 

Name: R. Aronson 

Organization: 

Comment: Please enact rules requiring monitoring at any facility that emits 

more than half a ton of airborne lead per year (.50 tpy). Monitoring this 

dangerous pollution will improve the health and well being of our community, 

especially our children who are particularly vulnerable to the risks posed by 

lead toxicity. Thank you for considering my opinion. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6073 

Name: W. Romatowski 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. I live near Detroit and notice that nearby factories 

schedule releasing the worst of their emissions when they think no one is 

smelling: at night, Sunday mornings, during inclement weather. They are 

fooling no one, and we must take action to stop the poisoning of citizens, the 

children, the elderly. These violators must be held accountable, including the 

jailing of violating owners, payment of damages to victims, and the 

reimbursement of health care costs borne by the innocent victims of these 

heinous actions, which in truth amount to crimes of the worst sort. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6249 
103 

Name: D. Arnosti 

Organization: 

Comment: Any amount of lead is toxic and unacceptable. EPA should regulate 

lead found in air emissions, and those distributed across our environment 

through hunting and fishing activities, as well! I strongly urge the EPA to enact 

rules to require monitoring at any facility that emits more than half a ton of 

airborne lead per year (.50 tpy). Monitoring this dangerous pollution will 

improve the health and well being of our community, especially our children 

who are particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6054 

Name: M. J. Cedar 

Organization: 

Comment: The future is watching. I strongly urge the EPA to enact rules to 

require monitoring at any facility that emits more than half a ton of airborne 

lead per year (.50 tpy). Monitoring this dangerous pollution will improve the 

health and well being of our community, especially our children who are 

particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6214 

Name: J. Anderson 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Monitoring such emissions may have some 

financial costs, but not monitoring these emissions will have untold 

repercussions for generations of Americans. 

Response: Responded to in preamble. 
104 

Comment ID: OAR-2006-0735-6081 

Name: J. Bourgeois 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. We've suffered too much for too long with these 

kinds of pollutants. We're much too well-informed to continue to poison 

ourselves in this way. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6080 

Name: R. Harbin 

Organization: 

Comment: I am so pleased to see the EPA revisiting the decision to lower the 

standard for monitoring of lead emitting facilities. It would be wonderful if 

EPA once again did what it was created to do. The letter below says it well; I 

just want to add a personal note imploring you to restore the .5 ton standard for 

monitoring lead emissions for all of us, but especially for the children of our 

land. Thank you. I strongly urge the EPA to enact rules to require monitoring at 

any facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6079 

Name: R. Stow 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. I personally feel very strongly about lead emissions 
105 

as a future parent; I want my children to be safe from this and all contaminants. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6078 

Name: M. Stoesz 

Organization: 

Comment: I am an adult asthmatic over 64 with asthma starting about 10 years 

ago. Air quality is important to my health and the health of others. I strongly 

urge the EPA to enact rules to require monitoring at any facility that emits more 

than half a ton of airborne lead per year (.50 tpy). Monitoring this dangerous 

pollution will improve the health and well being of our community, especially 

our children who are particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6077 

Name: M. Sarbaugh-Thompson 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. I study the issue of childhood lead poisoning. Lead 

exposure in children reduces IQ and increases aggressive behavior, which can 

increase crime rates. We simply cannot afford to waste our human resources 

this way. I would like to see a tax on cans of paint to raise money to compensate 

for the cost of lead poisoning from old paint. And I strongly support strict rules 

on lead emissions in the air. I estimate that childhood lead poisoning costs 

somewhere between $21,500 to $122,000 per child poisoned based on lost 

income due to reduced IQ, special education costs, medical costs, and costs of 

increased crime. This is a huge program and those who are poisoning children 

should be stopped and made to pay the costs. 

Response: Responded to in preamble. 
106 

Comment ID: OAR-2006-0735-6076 

Name: W. Raw 

Organization: 

Comment: As a mom, and as a friend to children affected by lead poisoning, I 

strongly urge the EPA to enact rules to require monitoring at any facility that 

emits more than half a ton of airborne lead per year (.50 tpy). Monitoring this 

dangerous pollution will improve the health and well being of our community, 

especially our children who are particularly vulnerable to the risks posed by 

lead toxicity. It is hopeful to think of what a huge impact this could have. Thank 

you so much! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6085 

Name: J. Piani 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. I thought we were suppose to see change with this 

administration. So far all I have seen is more of Bushie Boy's Corporate 

Corruption Program. When is there going to be change? 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6021 

Name: P. Bates-Ballard 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. I have personal experience with this issue and it 

means a lot to me. 

Response: Responded to in preamble. 
107 

Comment ID: OAR-2006-0735-6056 

Name: M. Albergato 

Organization: 

Comment: Americans are disgusted with the government's inconsistency and 

vicissitude in regulations and "protection". The well being of our health and the 

health of the planet should be paramount...certainly more important than 

corporate lobbies and profits!! I strongly urge the EPA to enact rules to require 

monitoring at any facility that emits more than half a ton of airborne lead per 

year (.50 tpy). Monitoring this dangerous pollution will improve the health and 

well being of our community, especially our children who are particularly 

vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6031 

Name: C. Neely 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6030 

Name: G. McNenny 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. The role of the government is to act on the behalf 

of its citizens. Please take the lead in making sure that airborne toxic lead is no 

longer allowed to be unmonitored and uncontrolled. 

Response: Responded to in preamble. 
108 

Comment ID: OAR-2006-0735-6029 

Name: M. Church 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Additionally it will help in the fight against climate 

change. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6028 

Name: M. Haynes 

Organization: 

Comment: Far too many children suffer from asthma, and other breathing 

problems that are, without question, caused by air pollution. I strongly urge the 

EPA to enact rules to require monitoring at any facility that emits more than 

half a ton of airborne lead per year (.50 tpy). Monitoring this dangerous 

pollution will improve the health and well being of our community, especially 

our children who are particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6027 

Name: R. & M. Swain 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. THIS WOULD MAKE EVERYONE 

[INCLUDING YOU] FEEL BETTER. 

Response: Responded to in preamble. 
109 

Comment ID: OAR-2006-0735-6026 

Name: M. Howard 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). The 

dangers of lead are proven and I am sincerely concerned for the health of 

today's young children. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6033 

Name: B. Wanner 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.5I) 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6022 

Name: J. R. Conway 

Organization: 

Comment: Please enact rules to require monitoring at any facility that emits 

more than half a ton of airborne lead per year (.50 tpy). Monitoring this 

dangerous pollution will improve the health and well being of our community, 

especially for our children who are particularly vulnerable to the risks posed by 

lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6034 

Name: M. Iltis 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 
110 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Lead poisoning can cause permanent learning 

impairment, and adverse effects to the nervous system, reproductive system and 

brain. The cost of monitoring to industry and government is far outweighed by 

the cost to our children's health. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6020 

Name: P. Holmlund 

Organization: 

Comment: I have recently become a great grandmother so I strongly urge the 

EPA to enact rules to require monitoring at any facility that emits more than 

half a ton of airborne lead per year. It may not make much of a difference to me, 

but it will to the generation growing up, just born, and our future generations. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6019 

Name: P. Baley 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. No amount of profit for some is worth poisoning 

the environment for all. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6018 

Name: M. Mills 

Organization: 

Comment: Airborne lead is a very dangerous pollutant, and proper monitoring 
111 

of it should be a top priority. I strongly urge the EPA to enact rules to require 

monitoring at any facility that emits more than half a ton of airborne lead per 

year (.50 tpy). Monitoring this dangerous pollution will improve the health and 

well being of our community, especially our children who are particularly 

vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6017 

Name: S. Anderson 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. There are limits on lead in toys, but not in the air 

that's breathed by EVERYONE? That doesn't make any sense. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6015 

Name: S. Gentile 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. As I elementary school teacher, I see first hand the 

effects that exposure to lead has on children and their learning. We need you to 

take action to keep our children safe and learning.

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6014 

Name: S. Waldon 

Organization: 
112 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution is an inescapable part of improving the 

health and well being of our community, especially our children, who are 

particularly vulnerable to the risks posed by lead toxicity. As for cost, we pay 

attention to the risk of lead in children now, or we & the children, pay for it in so 

many ways, later. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6013 

Name: D. Williams 

Organization: 

Comment: Please enact rules to require monitoring at any facility that emits 

more than half a ton of airborne lead per year (.50 tpy). 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6024 

Name: C. Eliot 

Organization: 

Comment: There are many (potential) toxins that we are unsure about. Lead is 

not one of them. We KNOW lead is significant cause of many health issues. I 

strongly urge the EPA to enact rules to require monitoring at any facility that 

emits more than half a ton of airborne lead per year (.50 tpy). Monitoring this 

dangerous pollution will improve the health and well being of our community, 

especially our children who are particularly vulnerable to the risks posed by 

lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6043 

Name: L. Gibson 

Organization: 

Comment: I've lived near Houston, Texas for the last 20 years. It is shameful 

that some many industries in the area allowed to pollute our air without 
113 

regulation and oversite. Since the Texas Commission on Environmental 

Quality cannot be trusted to protect the people, the EPA must enact stronger 

regulations. I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6053 

Name: F. Hellmich 

Organization: 

Comment: As an asthma and allergy sufferer I strongly urge the EPA to enact 

rules to require monitoring at any facility that emits more than half a ton of 

airborne lead per year (.50 tpy). I did not get asthma until my late 20's and had 

no prior family history. My youngest daughter is now being watched for signs 

of asthma. Monitoring this dangerous pollution will improve the health and 

well being of our community, especially our children who are particularly 

vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6052 

Name: N. Raymond 

Organization: 

Comment: I feel very strongly that your agency has not and is not now 

protecting the lives of the citizens of this country and the Universe. It seems like 

the corporations who are causing this travesty are the ones being protected. 

THIS MUST STOP!!! I strongly urge the EPA to enact rules to require 

monitoring at any facility that emits more than half a ton of airborne lead per 

year (.50 tpy). Monitoring this dangerous pollution will improve the health and 

well being of our community, especially our children who are particularly 

vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6051 
114 

Name: E. M. Downie 

Organization: 

Comment: It's hard to believe that any government agency would allow such 

levels of a known toxin to be emitted, endangering citizens, especially the most 

vulnerable. This must change. I strongly urge the EPA to enact rules to require 

monitoring at any facility that emits more than half a ton of airborne lead per 

year (.50 tpy). Monitoring this dangerous pollution will improve the health and 

well being of our community, especially our children who are particularly 

vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6050 

Name: R. Van Arsdale 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollutant will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Preventing the monitoring of the sources of 

pollution, especially something as toxic as lead, is the worst type of corporate 

greed over the health needs of our citizenry. I would compare it to the 

abolishment of thermometers so we could not take a child's temperature to 

determine whether they are sick or not. Indeed, without monitoring lead 

emissions, when our children become mentally deficient we won't even know 

why? If we allow corporations the freedom to hide what they are doing, there is 

no limit to the abuses that will follow. Don't we know that modern American 

corporations are largely acting like sociopaths; they have no conscience and 

face very little responsibility for the most outrageous assaults on the common 

good. It is insane to not allow monitoring!!! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6049 

Name: E. Smith 

Organization: 

Comment: As a scientist and a mom, I strongly urge the EPA to enact rules to 

require monitoring at any facility that emits more than half a ton of airborne 
115 

lead per year (.50 tpy). Monitoring this dangerous pollution will improve the 

health and well being of our community, especially our children who are 

particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6048 

Name: F. B. Mullett 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. If there's any sense of accountability for cleaning 

up the messes each of us makes, business should not be exempt from their 

share. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6047 

Name: M. Bennett 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). This is 

the minimum that can be done in terms of corporate responsibility and 

ownership of the social cost of operation. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6032 

Name: M. Warner 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring of lead 

at any facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 
116 

risks posed by lead toxicity. Half a ton is a huge amount. Imagine that your 

family lives downwind, and remember - clean air is everyone's right and 

responsibility. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6044 

Name: R. Johnson 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. It is vital that public safety be protected above the 

economic interests that oppose enforcement. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6093 

Name: B. Waranowitz 

Organization: 

Comment: I agree with the provided statement below! - Ben Waranowitz 

******** I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6042 

Name: P. Rothe 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 
117 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. WAKE UP to the fact that we are all on this one 

little planet together. Let's live on it sustainably, in harmony with all life. We 

need to work together or perish. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6041 

Name: S. Teich 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. IT IS ENVIRONMENT FIRST - NOT 

INDUSTRY FIRST!!!!! NOT CORPORATIONS FIRST! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6040 

Name: P. Livingston 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Really, you should monitor for the small 

particulate, whatever its constituents but lead in particular is a concern. 

Mercury too if you are near a power plant. Thanks for working on these issues 

of importance to public health. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6039 

Name: P. Bard 

Organization: 
118 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Please get the poisons out of our air! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6038 

Name: M. Kazinka 

Organization: 

Comment: Please consider regulating lead standards to the appropriate level 

that your scientists have suggested. It is your responsibility to keep American 

citizens safe from toxic living environments, and you know that lead is an 

unsafe thing to pump into the air in large quantities. We need you to fulfill your 

duties. 

Response: No response needed. 

Comment ID: OAR-2006-0735-6036 

Name: L. Middeke 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. BUT WE ARE ALL SUSCEPTIBLE TO THE 

TOXIC EFFECTS OF LEAD. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6035 

Name: C. Tibbetts 

Organization: 

Comment: We need to know what harm is being done to our environment so we 

can stop those responsible and charge them to clean up the harm they have 
119 

already done. The EPA is the group that needs the necessary power to control 

these errant companies. I strongly urge you to make the changes required so the 

EPA can monitor and enforce the rules to police these major polluters. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6046 

Name: R. Blaber 

Organization: 

Comment: Please require monitoring at any facility that emits more than half a 

ton of airborne lead per year. Our children face so many more dangers than in 

years past in the toxic chemicals in the air and soil; please don't cave to industry 

pressure on any of them, including lead. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6458 

Name: K. McCarthy 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. That said, what is your purpose if not to protect the 

environment? Even .50 is too much lead - there should be ZERO lead. Let's try 

to get over Bush and his shortsighted (he did not care) policies. Those days are 

over - and get used to it: we want a clean earth again. That's the direction to go 

for you - get over Bush - protect the environment. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6489 

Name: E. Villamar-Robbins 

Organization: 

Comment: As the mother of a 4-year-old, soon-to-be mother of two children, I 

am very concerned about lead exposure. I was therefore horrified to learn of the 
120 

2008 EPA move to weaken monitoring of airborne lead. I strongly urge the 

EPA to enact rules to require monitoring at any facility that emits more than 

half a ton of airborne lead per year (.50 tpy). Monitoring this dangerous 

pollution will improve the health and well being of our community, especially 

our children who are particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6467 

Name: M. Lannen 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Wake up! Think of the autism pandemic!!! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6465 

Name: K. Manning 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Lead poisoning robs children of the abilities they 

will need for the challenges of the future. We know no safe level of lead 

exposure. Please act for the future! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6464 

Name: K. Wallace 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 
121 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. I don't make a lot of money, but we have to do what 

is ecologically sound for our children, our nation and our world. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6463 

Name: K. Marshall 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. When are we going to stop putting money concerns 

above the welfare of our citizens and the world at large? Pollution affects and 

hurts all of us. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6462 

Name: G. King 

Organization: 

Comment: As a parent of three, I strongly urge the EPA to enact rules on 

airborne lead that keep public safety at the forefront. Specifically, I would ask 

the EPA to require monitoring at any facility that emits more than half a ton of 

airborne lead per year (.50 tpy). 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6461 

Name: C. Richardson 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 
122 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Regulations should be about social responsibility 

not corporate or political pressure. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6469 

Name: J. Rutherford 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. It is a shame and a crime to allow this situation to 

continue and we the citizens of American require you to do your very best to 

remedy it. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6459 

Name: K. Radford 

Organization: 

Comment: WHY ISN'T LEAD BEING KEPT OUT OF OUR AIR WHEN IT 

IS COMMON KNOWLEDGE HOW DANGEROUS IT IS? THE EPA WAS 

CREATED TO PROTECT THE PEOPLE OF THIS COUNTRY FROM 

DANGERS LIKE THIS. YOU ARE FAILING IN YOUR JOB WHEN YOU 

ALLOW POLITICAL AND ECONOMIC PRESSURE TO AFFECT YOUR 

CARRYING OUT YOUR RESPONSIBILITIES. THEREFORE, I strongly 

urge the EPA to enact rules to require monitoring at any facility that emits more 

than half a ton of airborne lead per year (.50 tpy). Monitoring this dangerous 

pollution will improve the health and well being of our community, especially 

our children who are particularly vulnerable to the risks posed by lead toxicity 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6470 
123 

Name: K. Wilson 

Organization: 

Comment: Our kids have enough challenges from a weak U.S. education 

system. We certainly do not need to add nervous system damage from lead 

poisoning. And let's face it, corporations make dollars their bottom line. They 

cannot be trusted with the health of our babies and the planet. I urge the EPA to 

do the maximum to monitor facilities that emit more than half a ton of airborne 

lead per year (.50 tpy) Please, for our children. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6457 

Name: A. Nicklen 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. For Imperial Valley, where my family and I live, 

this is an important issue because my family's health is being impacted by the 

bad quality of air we have. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6456 

Name: H. Fernandez 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. It is important to keep our air breathable. 

Response: Responded to in preamble. 
124 

Comment ID: OAR-2006-0735-6455 

Name: M. Miller 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. I support any legislation &/or policy that takes the 

EPA back to being responsible for protecting the environment that citizens and 

voters live in from the corporate bottom line policy of 'pollute now & let future 

generations pay later'. I know the EPA needs industry insiders on staff to inform 

policy making but they shouldn't take on the role of lobbyists crafting weak 

policies that empower their former employers to pollute freely. The EPA needs 

the power and the will to meet its mandate of protecting 'us' from 'them'. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6454 

Name: J. Wahl 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Given the increase in global pollution from newly 

industrializing countries, we need to be vigilant where we can most effectivelyright here at home, 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6453 

Name: S. Mohr 

Organization: 

Comment: Please, public health and the environment in which we live should 

be the priority of the EPA. We have come a long way since the pollution 

belching industries of the 50's and 60's. Let's not take a step backwards! I 

strongly urge the EPA to enact rules to require monitoring at any facility that 
125 

emits more than half a ton of airborne lead per year (.50 tpy). Monitoring this 

dangerous pollution will improve the health and well being of our community, 

especially our children who are particularly vulnerable to the risks posed by 

lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6452 

Name: K. Thate 

Organization: 

Comment: This issue is common sense: we should not only monitor any toxin 

(lead) producing facilities, but find ways to reduce their output in the first place. 

I strongly urge the EPA to enact rules to require monitoring at any facility that 

emits more than half a ton of airborne lead per year (.50 tpy). Monitoring this 

dangerous pollution will improve the health and well being of our community, 

especially our children who are particularly vulnerable to the risks posed by 

lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6451 

Name: M. Worthington 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. We have made great strides in reducing the 

presence of lead in our homes, but now is the time to do more to reduce the lead 

in our environment. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6450 

Name: E. Pechuzal 

Organization: 
126 

Comment: I am very concerned about our increasingly contaminated water and 

air. I strongly urge the EPA to enact rules to require monitoring at any facility 

that emits more than half a ton of airborne lead per year (.50 tpy). Monitoring 

this dangerous pollution will improve the health and well being of our 

community, especially our children who are particularly vulnerable to the risks 

posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6460 

Name: K. Alsup 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Thank you for your work on everyone's behalf. It 

does and will not go unnoticed. Again, thank you. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6479 

Name: J. Abrams 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity and don't deserve to be treated with such disregard. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6406 

Name: D. Bonetti 

Organization: 

Comment: I live downwind of a coal plant and feel its effects. I strongly urge 
127 

the EPA to enact rules to require monitoring at any facility that emits more than 

half a ton of airborne lead per year (.50 tpy). Monitoring this dangerous 

pollution will improve the health and well being of our community, especially 

our children who are particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6487 

Name: W. Allen 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. And in case you all have not thought about how 

much air is being polluted by war, take a long look at the effects on the people 

from Vietnam! And the wars after that..... Who is running this world? Is it worth 

the pay offs to destroy the earth and innocent lives!? And if the government is 

not helping to clean up the air we breathe, then at least give us National Health 

to deal with it! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6486 

Name: V. Kime 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). Please 

note that I live in a "superfund" area (Anaconda, MT)and I know firsthand what 

damage happens when lead is allowed to spew out all over the place. The soil in 

my yard contains 2500 ppm lead - I can't grow any edible plants - and in 

summer the dust blows everywhere! I work with children and many of them 

show signs of lead poisoning. Monitoring this dangerous pollution will improve 

the health and well being of our community, especially our children who are 

particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 
128 

Comment ID: OAR-2006-0735-6485 

Name: V. Cothroll 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Please take action now to protect our children and 

our environment. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6484 

Name: M. Hernandez 

Organization: 

Comment: Science has proven to us time and again the dangers of lead to our 

bodies. It is vital that the EPA tracks any source of environmental lead to ensure 

the health and safety of all living things, but especially our children. I strongly 

urge the EPA to enact rules to require monitoring at any facility that emits more 

than half a ton of airborne lead per year (.50 tpy). Monitoring this dangerous 

pollution will improve the health and well being of our community, especially 

our children who are particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6483 

Name: M. Thompson 

Organization: 

Comment: I strongly urge the Environmental Protection Agency to enact rules 

to require monitoring at any facility that spews more than half a ton of lead into 

the atmosphere per year. Monitoring this dangerous pollution will lead to the 

improvement of the health and well being of our society. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6482 
129 

Name: M. Chapman 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Businesses certainly have the ability to control the 

lead emissions, just not the will as it will limit their profits. Our health and the 

health of our children and grandchildren is more important than corporations' 

profits. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6468 

Name: E. O'Malley 

Organization: 

Comment: For the health and well-being of every American, especially our 

children, I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6480 

Name: L. Levine 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. So many people I know have lead poisoning. How 

can we disregard such a blatant health risk? 

Response: Responded to in preamble. 
130 

Comment ID: OAR-2006-0735-6447 

Name: E. Alexander 

Organization: 

Comment: Corporations that make profits from the production of materials with 

dangerous byproducts should also be responsible for the containment and long 

term safe disposal of those byproducts. I strongly urge the EPA to enact rules to 

require monitoring at any facility that emits more than half a ton of airborne 

lead per year (.50 tpy). Monitoring this dangerous pollution will improve the 

health and well being of our community, especially our children who are 

particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6478 

Name: M. Hawks 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. LESS LEAD IS THE ONLY VIABLE ACTION 

TO TAKE! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6477 

Name: S. Dupont 

Organization: 

Comment: Enact strong airborne lead monitoring standards!! Reducing this 

dangerous pollution will improve the health and well being of our community, 

especially our children, who are particularly vulnerable to the risks posed by 

lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6476 
131 

Name: M. Koch 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. We need to monitor in order to know when and 

who we need to limit! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6475 

Name: L. Gale 

Organization: 

Comment: I urge the EPA to promote public health and clean air by enacting 

stronger rules to require monitoring at facilities that emit airborne lead. 

Monitoring this dangerous pollution will improve the health and well being of 

our communities, especially children who are particularly vulnerable to the 

risks posed by lead toxicity. The EPA's first priority as a true protection agency 

should be a safe environment for humans, animals and plant species that depend 

on it. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6474 

Name: M. McFarland 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Just keep in mind... if we kill the planet, the 

economy, lousy airlines, cheating CEOs will be relatively unimportant. 

Response: Responded to in preamble. 
132 

Comment ID: OAR-2006-0735-6473 

Name: L. Priceman 

Organization: 

Comment: As a healthcare professional I have seen the effects of lead on the 

health and learning abilities of our children Removing lead has had a very 

positive result of many people. I strongly urge the EPA to enact rules to require 

monitoring at any facility that emits more than half a ton of airborne lead per 

year (.50 tpy). Monitoring this dangerous pollution will improve the health and 

well being of our community, especially our children who are particularly 

vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6472 

Name: K. Sinclair-Smith 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Lead in glazes on pottery wrecked one civilization. 

Knowing that, why would those who are supposed to lead the country, damage 

our civilization? 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6471 

Name: A. Babcock 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. The monitoring of hazards to public health safety 

seems to me to be one of your primary missions. Why ever in this mixed up 

world would you imagine that corporations have public safety as a higher 

calling than their bottom line? The monitoring and control of corporate self 
133 

interest at the expense of the public safety and health IS your reason for 

existence (in my opinion). It is my plea to you to help this country get back on 

track and be an advocate for the public. Thank you for your time and attention 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6481 

Name: M. Perry 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and wellbeing of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. With known hazards such as lead, it is the 

responsibility of the government to protect its citizens anywhere the wind 

blows in our nation. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6415 

Name: E. Christiee 

Organization: 

Comment: Too many of our young children are brain damaged due to exposure 

to lead. Please, I strongly urge the EPA to enact rules to require monitoring at 

any facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6424 

Name: J. Vick 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). Lead 
134 

is an important pollutant to monitor, particularly given its harmful effects on 

children. Thank you. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6423 

Name: B. Williams-Pemberton 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Let's make sure our grandchildren are healthy! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6422 

Name: J. Watson 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Let's go Organic/ Solar / and Green to help the 

Earth environment for the health of future generations!~!! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6421 

Name: J. Mozenter 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. It is critical that these rules get added to EPA 
135 

regulations immediately so that this policy can begin to take effect. This is 

common sense science, it is a civic imperative and it is a continuing step toward 

a more sustainable and healthy environment which we can all live in safely. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6420 

Name: J. Killian 

Organization: 

Comment: Not monitoring a known health hazard? TOTALLY ABSURD. 

Whatever we decide about permitting emissions, it's irresponsible to not even 

know how much is being put into our air. I strongly urge the EPA to enact rules 

to require monitoring at any facility that emits more than half a ton of airborne 

lead per year (.50 tpy). Monitoring this dangerous pollution will improve the 

health and well being of our community, especially our children who are 

particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6419 

Name: J. Schneidt 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Lead is still an issue!! Please monitor lead and 

work to lower levels in our air!! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6418 

Name: T. Lamb 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 
136 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. There is a growing number of people with 

chemical sensitivities, and lead in the air (even at levels currently permitted) 

prevent these people from living full lives and contributes to these statistics. 

Please don't make it worse for all of us. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6449 

Name: A. Philippus 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits lead and other pollutants. We must do what we can to protect 

the people and our environment from these toxins. Furthermore, discovery of 

unhealthy emissions needs to lead to strong sanctions against polluters. There is 

no excuse, no ignorance of the harmful effects of these toxins in this day and 

age. 

Response: Monitoring at all sources of Pb is both impractical (there are well 

over 100,000 facilities that emit some amount of Pb) and unjustifiable. Very 

small sources of Pb have no potential to exceed the Pb NAAQS which was 

established at a level that protects public health with a margin of safety. The 

emission threshold finalized in this rule is intended to identify sources of Pb 

that have the potential to exceed the Pb NAAQS. 

Comment ID: OAR-2006-0735-6416 

Name: L. Lee 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. We know how important it is to reduce exposure to 

lead and that no amount of lead is healthy. Your job is to protect the 

environment, and thereby protect the people. That, not protecting industry, 

should be your primary goal. 

Response: Responded to in preamble. 
137 

Comment ID: OAR-2006-0735-6427 

Name: E. Fry 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. We're worried about the lead in the air we breathe 

and in the soil of our vegetable garden from airborne lead. We live close to a 

small airport. Planes landing there use leaded gasoline. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6414 

Name: D. Wiley 

Organization: 

Comment: It's time for the EPA to enact rules to require stricter monitoring of 

lead. It's in our air at too high of rates. We took it out of paint, we're taking it out 

of toys - now let's get it out of the air. Enact the stricter rules. 

Response: No response needed. 

Comment ID: OAR-2006-0735-6413 

Name: J. Woodford 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Lead is only one of many toxins given to young 

children without their knowledge or consent by industry, at the expense of their 

health, learning, and behavior. There is no acceptable level of poison, and we 

cannot allow anyone, especially vulnerable small children, to be slowly killed 

by these chemicals such as lead. Please make an effort to act responsibly by 

starting to enact reasonable limits on hazardous airborne pollutants, particularly 

lead. 

Response: Responded to in preamble. 
138 

Comment ID: OAR-2006-0735-6412 

Name: J. Brown 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. I live in an industrial area, and I know first hand 

that children in this area tend to score lower than those who live further away. 

Why should this even be an issue? We have known for hundreds of years that 

lead is toxic, so why is it in our water and our air? Please undo the damage of 

the Bush administration and make American air safe again. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6411 

Name: R. Kanost 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. I live near Galveston Bay and I don't have to look 

too closely to see the price we are paying for lax regulations. My favorite bay 

fish has been shown to contain dangerous amounts of organic pollutants so that 

a health advisory has been issued to warn those who would eat it. We have 

allowed big businesses to buy our laws for too long. It's time to let them know 

that they can clean up or shut down. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6410 

Name: J. Soffer 

Organization: 

Comment: Now is not the time to weaken air quality rules. We've made a lot of 

progress on removing lead from paints, let's keep it out of the air! It is extremely 
139 

harmful to all life, and we pay the cost in health care (cancer, lung issues, brain 

and nervous disorders) if we allow industry to contaminate our resources that 

affect our health. 

Response: No response needed. 

Comment ID: OAR-2006-0735-6409 

Name: J. H. Maguire 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). Given 

the known toxicity of lead, I would urge monitoring of any facility that emits 

even a hundred pounds of lead a year, since the lead can accumulate and 

contaminate areas within the "shadow" of the source spewing the toxin. 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6408 

Name: T. Abel 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. All our lives depend on a healthier environment to 

give us a better chance for longer survival. Reducing toxic chemicals in our 

environment today will enhance and extend our lives today and tomorrow. 

Please restore strong rules and policies on monitoring our large-scale sources of 

airborne lead and other toxic chemicals. Yours and my life depend on swift 

action TODAY! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6407 
140 

Name: S. Gambill 

Organization: 

Comment: This is really a no-brainer. The EPA ostensibly exists to protect the 

environment. So, do your job. Big industry politics likes to make issues sound 

complicated as a smoke-screen for their own agendas. This country was 

founded on the ideal of the common good, of a government by, for, and of the 

people. So do what's necessary to protect the health and safety of the American 

people, and especially our children. Do your job. I strongly urge the EPA to 

enact rules to require monitoring at any facility that emits more than half a ton 

of airborne lead per year (.50 tpy). Monitoring this dangerous pollution will 

improve the health and well being of our community, especially our children 

who are particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6417 

Name: M. Sulander 

Organization: 

Comment: It's time for the EPA to protect Americans from lead. The EPA must 

require air monitoring for lead wherever a facility may be producing harmful 

levels of lead into the air. I strongly urge the EPA to enact rules to require 

monitoring at any facility that emits more than half a ton of airborne lead per 

year (.50 tpy). Monitoring this dangerous pollution will improve the health and 

well being of our community, especially our children who are particularly 

vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6435 

Name: K. Graham 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). As a 

teacher, I see the consequences of lead poisoning on inner city students---a loss 

of human capital that costs us all. 

Response: Responded to in preamble. 
141 

Comment ID: OAR-2006-0735-6490 

Name: A. K. Brady 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. I have a preschool child who had high lead levels at 

12 months old despite the lack of lead paint on the inside or outside of our 

home. Her pediatrician suspects lead was present in the soil around our home, 

and possibly the air we breathe. My daughter is small for her age, and possibly 

more vulnerable to environmental toxins. We do not yet know if her lead 

poisoning will have long term effects on her mental or physical development. 

Please enact stronger monitoring standards to regulate industrial airborne lead 

pollution. I would hate to see another family go through what mine has--having 

a child damaged by environmental poisoning. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6446 

Name: T. Wijnterp 

Organization: 

Comment: that emits more than half a ton of airborne lead per year (.50 tpy). If 

the EPA does not monitor, and leaves the matter to the companies that produce 

the airborne lead, then the whole reason for an Environmental Protection 

Agency is removed. This is your job, ladies and gentlemen of the EPA. This is 

what I pay taxes for. Please make sure the air and the environment stay clean, 

you have all our gratitude! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6445 

Name: E. Moore 

Organization: 

Comment: It is unconscionable to knowingly allow our nation's children to be 

exposed to unsafe levels of lead. I strongly urge the EPA to enact rules to 
142 

require monitoring at any facility that emits more than half a ton of airborne 

lead per year (.50 tpy). Monitoring this dangerous pollution will improve the 

health and well being of our community, especially our children who are 

particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6444 

Name: B. Huntsberger 

Organization: 

Comment: I urge the EPA to enact rules to require stricter monitoring of 

airborne lead. This dangerous pollution harms the health and well being of our 

community, especially our children who are particularly vulnerable to the risks 

posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6443 

Name: J. Hart 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. We already have a problem in Ventura county, and 

specifically in Oxnard, with EPA not doing a cleanup on toxic waste, so let's not 

allow any more. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6442 

Name: S. Nims 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 
143 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. The whole world is at risk of being slowly 

poisoned by these toxins, not just the poor families in the immediate area of the 

polluters. No country is safe. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6441 

Name: P. Holt 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. It is a known fact that Lead is dangerous for our 

environment, both plant and animal...mankind! Please do what is the right thing 

to do! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6439 

Name: H. Drubin 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. After all, do you really think we can continue to 

pour chemical waste and poisons into the air without it eventually having a bad 

effect on us all??? 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6425 

Name: E. Moreno 

Organization: 
144 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. My daughter (now 2) was exposed to lead when 

she was just 9 months old. Since then, I have made it my mission to protect her 

from this toxin in whatever way I can. I can hire lead-certified contractors to 

make our house safe, I can only buy toys and products that I know are lead-free, 

but to protect the air she breathes I need help from the EPA. Please help us and 

all children who are at risk. It is devastating that health and behavior problems 

are suffered by children at even low levels of lead exposure. But what is even 

worse is that those problems are PREVENTABLE but aren't being prevented. 

Please help. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6436 

Name: D. Hanson 

Organization: 

Comment: I live downwind from 2 coal generators. I strongly urge the EPA to 

enact rules to require monitoring at any facility that emits more than half a ton 

of airborne lead per year (.50 tpy). Monitoring this dangerous pollution will 

improve the health and well being of our community, especially our children 

who are particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6426 

Name: E. Yeomans 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. My father's long-term exposure to industrial 

pollutants was a big factor in causing the cancer that killed him; I feel a personal 

responsibility to speak out in support of close monitoring of all known sources 

of pollution that threaten our health and/or the health of the Earth. 
145 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6434 

Name: S. Stone 

Organization: 

Comment: When I was a child, homes were painted with lead based paints... 

When the adults of that day clearly realized the dangers it imposed upon our 

health it was no longer permitted... and yet all these years later, my 

grandchildren and I are still breathing it! Why does Washington not realize why 

most of the country is beyond fed up, and are so angry? Are they too suffering 

the effects of having breathed in too much lead? One wonders why they don't 

"get it" no matter how many times we beg them to CARE ABOUT THE 

PEOPLE more than the money. I strongly urge the EPA to enact rules to require 

monitoring at any facility that emits more than half a ton of airborne lead per 

year (.50 tpy). Monitoring this dangerous pollution will improve the health and 

well being of our community, especially our children who are particularly 

vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6433 

Name: A. Smigelsky 

Organization: 

Comment: Ladies & Gentleman - Please, please, please take your positions 

seriously. I request that the EPA use it's position to enact commonsense & 

appropriate rules regarding lead emitted into the air. I ask this for my health, for 

my children's health, and that of my unborn grandchildren. It's time our 

generation start acting responsibly and hold corporations accountable. I 

strongly urge the EPA to enact rules to require monitoring at any facility that 

emits more than half a ton of airborne lead per year (.50 tpy). Monitoring this 

dangerous pollution will improve the health and well being of our community, 

especially our children who are particularly vulnerable to the risks posed by 

lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6432 
146 

Name: A. Cheek 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. For the sake of the most vulnerable among us, I 

strongly urge you to take this action. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6431 

Name: F. Mackey 

Organization: 

Comment: monitoring at any facility that emits more than half a ton of airborne 

lead per year (.50 tpy). Monitoring this dangerous pollution will improve the 

health and well being of our community, especially our children who are 

particularly vulnerable to the risks posed by lead toxicity. Thank you for your 

thoughtful consideration. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6430 

Name: E. Bartlett 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Companies may claim they can't afford to meet the 

rules that would protect our air, but the country can't afford to damage its 

children and its future. Please take your responsibilities seriously and enact and 

enforce the rules necessary to protect us all. 

Response: Responded to in preamble. 
147 

Comment ID: OAR-2006-0735-6429 

Name: E. Fuchs 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Please protect our health, and your health. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6428 

Name: A. Buster 

Organization: 

Comment: I am one of hundreds of thousands of adults who have been 

diagnosed with chronic upper respiratory conditions. I do not smoke, nor do I 

work in a dangerous environment. The environment itself has become 

problematic. Too many years of lax regulation has led to air that is making us 

sick. I fear for children because childhood asthma is on the rise. Why is it so 

difficult to understand that air pollution is destroying the health of Americans? 

Have we truly given ourselves over to greed to the extent that human life no 

longer matters? At a time when the public itself is seeking limitations on public 

exposure to smoking because we know by experience as well as by science that 

second-hand smoke is as dangerous as smoking itself, why, why, why are we 

not applying those same principles, those same lessons to the pollution emitted 

by industry? I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. If people are willing to impose bans on smoking, 

what makes you think they would not want limits on industrial pollution? We 

all want to be healthier, to safeguard the health of our children and 

grandchildren. Please keep toxic amounts of lead out of our air now! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6448 

Name: I. Franchi and I. Arce 
148 

Organization: 

Comment: Your decision will help ensure compliance with the EPA's strong 

new health-based standards to protect communities against airborne lead, in 

keeping with your agency's own analysis showing that facilities emitting half a 

ton or more of lead a year can result in violations of the health-based standard. I 

hope that you adopt this strong standard and resist any efforts to weaken these 

monitoring requirements. I also urge the EPA to ensure that monitoring near old 

sources of lead pollution, such as the dust near roadways and old and closed 

industrial facilities that can contribute to lead air pollution, is included in state 

monitoring plans. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6250 

Name: D. Slayter 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Please stop the unregulated madness. Monitoring is 

the only way to know how bad the lead pollution is.

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6542 

Name: D. Behne 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. I have almost lost faith in US agencies anymore. 

What was anyone thinking when things like this got passed? How bad do we 

have to destroy everything before THE RIGHT THINGS get done? It would be 

easier to do it NOW than wait until it is so out-of-hand that it will be a MAJOR 

sacrifice that we need to do to correct our past mistakes. When will the "let the 

next guy deal with it" attitude end and responsibility finally kick in. Please do 
149 

the right thing this time before it gets to be too late! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6488 

Name: D. Foster 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Children are especially vulnerable to lead toxicity; we must monitor this 

dangerous pollution to improve the health and well being of our future 

Americans. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6550 

Name: R. Mack 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Seriously! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6549 

Name: P. Bellonci and G. Bellonci 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. This is such a "no-brainer" - Of course we need to 

keep toxins out of our air! After all, we're all breathing. (aren't you?) 
150 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6548 

Name: C. Zulick 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). The 

health of our citizens is more important than the wealth of the few. Please do 

what is best for Americans and properly monitor lead levels in our air. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6547 

Name: A. Winston 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. FOR PETE'S SAKE, THIS IS A NO-BRAINER! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6546 

Name: C. Jennings 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. As a community health RN and a Nursing 

Educator, I can tell you that what we "pay for" today will benefit us down the 

road. We are suffering from decades of neglect in this area! Put "Protection" b 

Response: Responded to in preamble. 
151 

Comment ID: OAR-2006-0735-6545 

Name: C. Lepley 

Organization: 

Comment: I urge the EPA to enact rules to require monitoring at any facility 

that emits more than half a ton of airborne lead per year (.50 tpy). 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6552 

Name: R. Defferante 

Organization: 

Comment: Airborne lead is toxic and can cause a host of medical problems, 

especially in children who are more susceptible to the harmful effects of lead 

exposure. Some of the problems it causes include lower IQ, behavioral 

problems, brain damage, kidney damage and cardiovascular injury. I strongly 

urge the EPA to enact rules to require monitoring at any facility that emits more 

than half a ton of airborne lead per year (.50 tpy). Monitoring this dangerous 

pollution will improve the health and well being of our community, especially 

our children who are particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6543 

Name: C. Fribance 

Organization: 

Comment: In our local lakes, we can't eat most of the fish that are caught 

because of lead. This is true for many of the lakes in Wisconsin and across the 

country. Studies also show that Native Americans who eat lots of fish have 

children whose mental abilities are affected by lead poisoning. Clearly there are 

other impacts of lead upon us and our environment. I strongly urge the EPA to 

enact rules to require monitoring at any facility that emits more than half a ton 

of airborne lead per year (.50 tpy). Monitoring this dangerous pollution will 

improve the health and well being of our community, especially our children 

who are particularly vulnerable to the risks posed by lead toxicity. We need 

action before it is too late! 

Response: Responded to in preamble. 
152 

Comment ID: OAR-2006-0735-6553 

Name: A. Sorg 

Organization: 

Comment: We have two kids with monitored blood lead levels with no known 

source for the exposure. I strongly urge the EPA to enact rules to require 

monitoring at any facility that emits more than half a ton of airborne lead per 

year (.50 tpy). Monitoring this dangerous pollution will improve the health and 

well being of our community, especially our children who are particularly 

vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6541 

Name: D. Kornblum 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Let's undo the Bush/Cheney damage before it's too 

late, again. The people are with you. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6540 

Name: D. Moore 

Organization: 

Comment: I urge the EPA to enact rules to require monitoring at any facility 

that emits more than half a ton of airborne lead per year (.50 tpy). 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6539 

Name: D. Eyermann 
153 

Organization: 

Comment: I strongly DEMAND the EPA to enact rules to require monitoring at 

any facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. How many Americans do we have to read about 

with cancers, miscarriages, premature death of elderly before you people who 

are supposed to be the Watchdogs of our Quality of Life do your job???!!! I'm 

more radical; I advocate a total "Dump the Republican & sympathetic 

Democrat incumbents" ...which "movement" may be gaining momentum! 

People who fail to act in the greater society's better interest might find 

themselves dismissed soon I hope !!!! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6538 

Name: S. Dewey 

Organization: 

Comment: It is time--past time--to start undoing the damage that the Bush 

administration did to our regulations protecting public health and the 

environment. Lead pollution in the United States has been historically 

underregulated for more than a century due to ongoing pressure from industry 

lobbies. This is a shameful state of affairs, and beneath the dignity of an 

advanced modern democratic nation. I strongly urge the EPA to enact rules to 

require monitoring at any facility that emits more than half a ton of airborne 

lead per year (.50 tpy). Monitoring this dangerous pollution will improve the 

health and well being of our community, especially our children who are 

particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6537 

Name: D. Elllinger 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 
154 

risks posed by lead toxicity. Help reduce our healthcare costs by doing your 

part! You too are eating food laden with chemicals due to air and ground 

pollution. Do you have an expectation of a long and high quality life? 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6536 

Name: D. deForest 

Organization: 

Comment: I am concerned about the toxic lead in our air and I strongly urge the 

EPA to enact rules to require monitoring at any facility that emits more than 

half a ton of airborne lead per year (.50 tpy). Monitoring this dangerous 

pollution will improve the health and well being of our community, especially 

our children who are particularly vulnerable to the risks posed by lead toxicity. 

As an RN, who is well aware of the health risks to children from being exposed 

to unnecessary levels of lead and other metals, I believe it is wrong for the 

government to allow this pollution to continue. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6535 

Name: D. Sperling-Schmidt 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Just this morning there was an article in the LA 

Times about Target stores pulling a teddy bear due to concerns about high lead 

content. Maybe stronger standards starting at home can get the ball rolling on 

higher standards around the world. Time for us to take the lead(leed) and get the 

lead out of the air. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6534 

Name: T. Brittian 
155 

Organization: 

Comment: The lax regulation on lead is an outrage. We know that lead 

LOWERS IQ IN CHILDREN (and adults), that it is a neurotoxin. We've known 

about this poison since the Romans made their mistakes with lead pipes. I 

strongly urge the EPA to enact rules to require monitoring at any facility that 

emits more than half a ton of airborne lead per year (.50 tpy). Monitoring this 

dangerous pollution will improve the health and well being of our community, 

especially our children who are particularly vulnerable to the risks posed by 

lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6544 

Name: C. Fishburn 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. FOR MANY OF US, OUR LIVES ARE BEING 

SHORTENED BY THE POOR AIR QUALITY. DON'T CAVE IN TO

THOSE IN INDUSTRY WHO BENEFIT FROM LAX REGULATIONS.

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6564 

Name: R. Dueck 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. It comes down to this... do we care one wit about 

future generations? 

Response: Responded to in preamble. 
156 

Comment ID: OAR-2006-0735-6575 

Name: C. Trent 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Airborne lead is toxic and can cause many medical problems, especially in 

children who are more susceptible to the bad effects of lead exposure. We need 

to be able to more closely monitor large-scale sources of airborne lead such as 

factories and smelting plants. Please make a rule that lowers the amount of 

pollution allowed in our air. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6573 

Name: A. Magennis 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Lead has been clearly demonstrated to impair the 

development of children, and it is poor children, living in the old urban 

neighborhoods that are in the worst settings and have the highest lead levels in 

their blood. Also at risk are those who live in close proximity to lead-producing 

industries. It is not that difficult to pass legislation to clean up the air and get the 

lead out! I'm so, so tired of the dirty air (and water) that we continue to live in, 

and it is not necessary! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6572 

Name: M. Oaks 

Organization: 

Comment: Hello, I urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). Such 

rules should have already been established and it is alarming that there are no 

such rules. Monitoring this dangerous pollution will improve the health and 
157 

well being of our community, especially our children who are particularly 

vulnerable to the risks posed by lead toxicity. If we care about our children the 

decision to make is obvious. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6571 

Name: J. Moore 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Actually, I'm shocked that this is not more tightly 

regulated and monitored. We know the affects of lead. I realize that as an 

agency, the EPA had it's foundation undermined during the Bush 

administration. It is time now to make bold steps in protecting the public. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6570 

Name: G. Carver 

Organization: 

Comment: I don't think our children should have to suffer brain or kidney 

damage just because they had the misfortune(?) to be "born in the USA". I 

strongly urge the EPA to enact rules to require monitoring at any facility that 

emits more than half a ton of airborne lead per year (.50 tpy). Monitoring this 

dangerous pollution will improve the health and well being of our community, 

especially our children who are particularly vulnerable to the risks posed by 

lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6569 

Name: C. Wolstenholme 

Organization: 
158 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. No amount of money saved by not requiring 

monitoring can make up for the mental dullness or retardation that comes along 

with lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6567 

Name: R. Cano 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Please do the right thing for us, for once. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6551 

Name: B. Tzigany 

Organization: 

Comment: Clean air seems like such a basic right. Why shouldn't we do 

everything we can to have a livable habitat? I strongly urge the EPA to enact 

rules to require monitoring at any facility that emits more than half a ton of 

airborne lead per year (.50 tpy). Monitoring this dangerous pollution will 

improve the health and well being of our community, especially our children 

who are particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6565 

Name: R. Trickey 

Organization: 
159 

Comment: The EPA is the ENVIRONMENTAL Pro, not the Industrial Profit 

and Greed Protection Agency. We the people, rely on you and expect you to 

perform the function for which you were created by law. It is time to enact 

regulations that will protect the health of today's and tomorrow's children. I 

strongly urge the EPA to enact rules to require monitoring at any facility that 

emits more than half a ton of airborne lead per year (.50 tpy). Monitoring this 

dangerous pollution will improve the health and well being of our community, 

especially our children who are particularly vulnerable to the risks posed by 

lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6531 

Name: P. Rider 

Organization: 

Comment: Do we want to follow the Roman Empire. A strong theory about the 

demise of Roman leadership was poisoning from lead in the empire's famed 

aqueduct pipes. I strongly urge the EPA to enact rules to require monitoring at 

any facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6563 

Name: R. Mills 

Organization: 

Comment: Protecting the public from dangerous emissions is one of the 

responsibilities of the EPA; therefore, I strongly urge the EPA to enact rules to 

require monitoring at any facility that emits more than half a ton of airborne 

lead per year (.50 tpy). Monitoring this dangerous pollution will improve the 

health and well being of our community, especially our children who are 

particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 
160 

Comment ID: OAR-2006-0735-6561 

Name: R. Ware 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. The risks of lead poisoning, especially to the 

developing brains of children, have been well established. To insure such 

dangers are minimized a return to the previous standard of .50 tpy is essential. 

No price can be placed on the maintenance of public health and especially the 

safety of our children. I believe mandatory monitoring of this dangerous 

pollution and any other such dangers to our health is essential. I ask you to 

return to the former standards and, if anything, increase the monitoring of such 

dangerous emission. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6560 

Name: E. House 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. We count on the EPA to protect us! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6558 

Name: R. McGuire 

Organization: 

Comment: Lead pollution is dangerous to all, especially for our children. I 

strongly support the EPA's enacting rules to be able to monitor facilities 

emitting more than a half a ton of airborne lead per year. Thank you for 

considering my comments. 

Response: Responded to in preamble. 
161 

Comment ID: OAR-2006-0735-6557 

Name: R. Conn 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. It seems that whatever the Bush administration has 

done has endangered the military, financial, environmental. physical (ours) 

health of our country. We must prosecute! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6556 

Name: R. Grzeskowiak 

Organization: 

Comment: I, as a heavy metals victim, strongly urge the EPA to enact rules to 

require monitoring at any facility that emits more than half a ton of airborne 

lead per year (.50 tpy). Monitoring this dangerous pollution will improve the 

health and well being of our community, especially our children who are 

particularly vulnerable to the risks posed by lead toxicity. While you are at it, 

require monitoring for ALL heavy metals. Thank you.

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6555 

Name: R. Hartman 

Organization: 

Comment: Hey, pollution is fraud. It is a way for businesses to pass along 

legitimate costs of doing business to others downstream. Do your job and 

protect us from fraudulent practices such as dumping toxic fumes into the air. I 

strongly urge the EPA to enact rules to require monitoring at any facility that 

emits more than half a ton of airborne lead per year (.50 tpy). Monitoring this 

dangerous pollution will improve the health and well being of our community, 

especially our children who are particularly vulnerable to the risks posed by 

lead toxicity. 

Response: Responded to in preamble. 
162 

Comment ID: OAR-2006-0735-6554 

Name: R. Heffelfinger 

Organization: 

Comment: I have been dealing with lead poisoning for the past 3+ years. I have 

radiation type burns on my face and neck. I have the tell tale blue 'spot' in my 

mouth that denotes lead poisoning. Using a lead reference range of<=1.4 

Urinalysis shows I am 24.9. I would like to outlive my 85 year old parents in the 

nursing home and I would love to live to see the birth of my first grandchild this 

September. PLEASE STOP POLLUTING THE AIR I BREATHE. Could we 

knock off the toxic metal contaminates in our air, water and soil-please! I 

strongly urge the EPA to enact rules to require monitoring at any facility that 

emits more than half a ton of airborne lead per year (.50 tpy). Monitoring this 

dangerous pollution will improve the health and well being of our community, 

especially our children who are particularly vulnerable to the risks posed by 

lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6566 

Name: R. Moser 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. We can control (to a certain extent) what we eat 

and drink, but the air we breathe is another matter. Is it wise to ignore this threat 

now and then have to pay higher medical costs later? 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6501 

Name: N. Adams-Coga 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 
163 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. It is time for my elected officials to put the welfare 

of actual breathing persons before the profits of corporate "persons." 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6510 

Name: C. Elliott 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Nobody has a right to poison the air I breathe! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6509 

Name: C. Holmes 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Help protect the air WE ALL HAVE to breathe!! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6508 

Name: D. Saunkeah 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits airborne lead. Monitoring this dangerous pollution will 

improve the health and well being of Earth and it's inhabitants! 
164 

Response: Monitoring at all sources of Pb is both impractical (there are well 

over 100,000 facilities that emit some amount of Pb) and unjustifiable. Very 

small sources of Pb have no potential to exceed the Pb NAAQS which was 

established at a level that protects public health with a margin of safety. The 

emission threshold finalized in this rule is intended to identify sources of Pb 

that have the potential to exceed the Pb NAAQS. 

Comment ID: OAR-2006-0735-6507 

Name: D. Tharp 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. It's imperative that the EPA live up to its mission of 

protecting the American public from the environmental hazards unleashed by 

the lax and politicized policies of the Bush administration. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6506 

Name: D. Renfrew 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. As a researcher dedicated to the health effects of 

lead in the developing world, I know first hand the dangers caused by lead, and 

the necessity of a strong regulatory framework to control and monitor pollution 

in all its forms. Lead bio-accumulates in the organism, making it of utmost 

urgency to address and mitigate ALL the possible sources and pathways of 

environmental lead exposure. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6505 
165 

Name: W. James 

Organization: 

Comment: Please enact rules to require monitoring at any facility that emits 

more than .50 tpy. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6504 

Name: J. Kolberg 

Organization: 

Comment: As an early childhood Special Educator, I implore you to keep the 

lead out of our air! I strongly urge the EPA to enact rules to require monitoring 

at any facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6533 

Name: T. Clements 

Organization: 

Comment: I have been spending the last two years working hard to get toxins 

out of my body. I strongly urge the EPA to enact rules to require monitoring at 

any facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6502 

Name: B. Jackson 

Organization: 

Comment: The Bush administration had its priorities backward and promoted 
166 

industry over the environment and public health. Whereas the EPA's own 

technical analysis in 2008 supported monitoring any source of lead that emitted 

more than half a ton of lead into the air per year (.50 tpy), Bush era officials 

were able to get the EPA to only require monitoring of sources that emitted 

double that amount (1.00 tpy). I resent his insensitive effort to continue fouling 

our air and I want it stopped. I strongly urge the EPA to enact rules to require 

monitoring at any facility that emits more than half a ton of airborne lead per 

year (.50 tpy). Monitoring this dangerous pollution will improve the health and 

well being of our community, especially our children who are particularly 

vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6513 

Name: C. Warren 

Organization: 

Comment: I am writing to urge the EPA to enact rules to require monitoring at 

any facility that emits more than half a ton of airborne lead per year (.50 tpy). 

The deleterious health effects of lead pollution, especially to children, is well 

established. To fail to monitor this dangerous pollution would, I believe, 

amount to negligence on the part of a public agency established to protect the 

nation's environment and its health. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6500 

Name: C. Starr 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. We must make every effort to correct the damage 

we have done and are doing to the planet and public health, regardless of the 

difficulty. Life depends on it. Thank you for all your efforts. 

Response: Responded to in preamble. 
167 

Comment ID: OAR-2006-0735-6499 

Name: C. Solstad 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollutant will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Our children deserve to live without this threat to 

their health. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6497 

Name: C. Cahill 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6496 

Name: B. Whitaker 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Please take action now to monitor these lead 

emitting facilities. Thank you. Sincerely, Barbara Whitaker, Tucson, Arizona 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6495 
168 

Name: B. Davidson 

Organization: 

Comment: Pb! Pb! Pb! everywhere! What kind of PROTECTION is it that your 

agency does??? If ANYONE is still there that's worth their diploma & and has 

any conscience they will work to monitor and regulate Pb to SAFE HUMAN 

levels. I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6494 

Name: B. Biehl 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Please enact strong airborne lead standards 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6492 

Name: A. Foster 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. As a teacher, I am constantly reminded of the 

devastating effects of lead exposure to small children. Sadly, they are often 

unable to learn because of memory loss caused by the lead. It's so sad to think 

that we know about these dangers. We must do everything we can to prevent 

this!! 

Response: Responded to in preamble. 
169 

Comment ID: OAR-2006-0735-6491 

Name: 

Organization: 

Comment: All air standards from the EPA are too lax for our health and safety. 

Please begin returning safeguards by addressing the issue of lead in the air we 

all breathe. I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6503 

Name: A. Holder 

Organization: 

Comment: As one who lived in and struggled to raise a family in the polluted 

air of an ASARCO plant, I support regulations that monitor air at any facility 

that emits more than half a ton of airborne lead per year (.50 tpy). For my 

family, it is too late; I currently suffer from "severe severe" emphysema; my 

daughter, who was born with one lung, refuses to live here. Monitoring 

dangerous pollution would have given us both a better chance at living without 

oxygen and medications that severely interfere with our well being. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6521 

Name: W. Frisbie 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Get a spine! I am outraged that any "public 

servant" would accept changes that actually endanger the public they are 

supposed to be serving. Make it tougher to poison us, for God's sake! 
170 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6438 

Name: H. Bowman 

Organization: 

Comment: Thank you for taking the time to listen to this email I strongly urge 

the EPA to enact rules to require monitoring at any facility that emits more than 

half a ton of airborne lead per year (.50 tpy). Monitoring this dangerous 

pollution will improve the health and well being of our community, especially 

our children who are particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6530 

Name: T. Buchheim 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. In order to reduce the harmful effects of lead we 

need to know exactly where (and in what quantities) lead is being released into 

the environment. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6529 

Name: C. Towns 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. I am so disappointed in some recent decisions by 

the EPA, particularly with respect to mountain top clearing for the coal 
171 

industry. Please remember what your responsibility is and see to it that our 

environment has the strictest protection laws available!!!! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6528 

Name: N. Casurella 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Geez, this is a no brainer. What is the downside? 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6527 

Name: B. Castalia 

Organization: 

Comment: Restoring and strengthing EPA rules that require monitoring at any 

facility that emits airborne lead is, quite simply, in the public interest. Polluting 

industries will not, of course, see such rules in their interests (unless they are 

socially responsible). So the decision is straightforward: Serve the interests of 

the public in a healthy living environment, or the interests of privately owned 

industrial businesses in maximizing their profits. When it comes to a decision, 

who's interests are you serving? 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6526 

Name: B. Sabo 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). The 

Environmental Protection Agency is supposed to do what its name states - 

protect the environment. By revisiting the rules that weakened monitoring of 
172 

large-scale sources of airborne lead, you would be acting in the best interests of 

the citizenry rather than the interests of factories and smelting plants. The 

harmful impacts of airborne lead are well known. You have the chance to 

strengthen rules that would better the health of Americans. Please, enact strong 

monitoring rules concerning airborne lead that will protect our health. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6525 

Name: B. Barber 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. We're concerned about healthcare, but won't 

monitor and prevent the dumping of pollutants into the air that we know are 

harmful. Get your priorities in order. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6524 

Name: B. Galbreath 

Organization: 

Comment: As a mother and grandmother, I strongly urge the EPA to enact rules 

to require monitoring at any facility that emits more than half a ton of airborne 

lead per year (.50 tpy). Monitoring this dangerous pollution will improve the 

health and well being of our community, especially our children who are 

particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6511 

Name: C. Miller 

Organization: 

Comment: Let science, not politics, dictate monitoring requirements. If the 
173 

EPA's impartial scientific analysis says that any source emitting half a ton a 

year of lead needs to be monitored for compliance, then that's what we should 

do. Roll back the Bush administration's politically motivated doubling of that 

limit. Let's get back to basing our policy on solid science. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6522 

Name: B. Murphey 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. It's incomprehensible that we should even have to 

plead - it is as simple as doing the right thing, for our children, for generations 

of children and for this planet earth. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6512 

Name: C. Haug 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. As a child in the 1950s, before lead was removed 

from paint and gasoline, I was exposed to toxic levels of lead, which I still carry 

in my bones and other parts of my body. For the last 10 years, I have been 

undergoing chelation to remove the lead, but it is proving difficult. I have 

osteoporosis, which I believe is due to the lead in my bones. Please, protect 

future generations by limiting lead in our air. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6520 
174 

Name: Z. Cochran 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. As a parent of young children I urge you to enact 

stricter practices for monitoring the lead that industry releases into the air we all 

share. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6519 

Name: B. Schor 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially people like me who are plagued by asthma triggered 

by air toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6518 

Name: B. Porter and P. Porter 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. WHY DO WE BOTHER TO STUDY AND 

MEASURE THE EFFECTS OF HAZARDOUS MATERIALS IF WE ARE 

UNWILLING TO CONTROL AND LIMIT THEM TO THE "PROPER"

SAFE LEVELS? 

Response: Responded to in preamble. 
175 

Comment ID: OAR-2006-0735-6517 

Name: W. Ince 

Organization: 

Comment: Let's keep toxic lead out of our air! I strongly urge the EPA to enact 

rules to require monitoring at any facility that emits more than half a ton of 

airborne lead per year (.50 tpy). Monitoring this dangerous pollution will 

improve the health and well being of our community, especially our children 

who are particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6516 

Name: V. Nelson 

Organization: 

Comment: All it takes is a desire to really live, instead of just survive. You have 

that desire and you are in a position to use your power to enhance all life. (Yes, 

even the people employed in industry will be better for it.) I strongly urge the 

EPA to enact rules to require monitoring at any facility that emits more than 

half a ton of airborne lead per year (.50 tpy). Monitoring this dangerous 

pollution will improve the health and well being of our community, especially 

our children who are particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6515 

Name: B. Unrath 

Organization: 

Comment: I strongly urge, beg and plead with the EPA to enact rules to require 

monitoring at ALL facilities that emit more than half a ton of airborne lead per 

year (.50 tpy). Monitoring this dangerous pollution will improve the health and 

well being of our community, especially our children who are particularly 

vulnerable to the risks posed by lead toxicity. Think of the money saved on 

future health costs if we eliminate this volume of air pollution now! 

Response: Responded to in preamble. 
176 

Comment ID: OAR-2006-0735-6514 

Name: P. Walker 

Organization: 

Comment: The EPA absolutely needs to enact rules to require monitoring at 

any facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially children who are particularly vulnerable to the risks 

posed by lead toxicity, which we know results in lower IQs, among other 

negative health effects. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6532 

Name: T. Stahl 

Organization: 

Comment: I have 3+ grandchildren who I want to stay healthy and be able to 

grow. Lead in the air is bad for them. I strongly urge the EPA to enact rules to 

require monitoring at any facility that emits more than half a ton of airborne 

lead per year (.50 tpy). Monitoring this dangerous pollution will improve the 

health and well being of our community, especially our children who are 

particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6523 

Name: B. Katzoff 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). Please 

do the right thing to care for the children of our country and enact this needed 

oversight. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6303 
177 

Name: M. Fitzgibbon 

Organization: 

Comment: Facilities emit more than half a ton of airborne lead per year (.50 

tpy) should receive a tax break or grant for monitoring and reducing their 

emission of this element. Otherwise, these plants and their jobs will just move 

to India or China. The taxpayer, which benefits from products from these plants 

should just be forced to pay for what they don't pay for in the end price of the 

product. Monitoring this dangerous pollution will improve the health and well 

being of our community, especially our children who are particularly 

vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6338 

Name: P. Swackhamer 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Lack of attention to the environment and health of 

all on this planet by some administrations in the past does not mean that we 

have to continue this disregard. As more and more people inhabit this planet, 

we must reduce the effects of pollutants in our environment. Please do your part 

to decrease the amount of lead in our environment. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6314 

Name: N. Kauper 

Organization: 

Comment: We need you to protect us from harmful chemical particles in the air 

we all breathe. I call on the EPA to do the job entrusted to them by the public 

and enact rules to require monitoring at any facility that emits more than half a 

ton of airborne lead per year (.50 tpy). Monitoring this dangerous pollution will 

improve the health and well being of our community, especially our children 

who are particularly vulnerable to the risks posed by lead toxicity. Good air 

quality is of the utmost importance to everyone with lungs. Please enact these 
178 

monitoring rules. Lives depend on it. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6312 

Name: M. Jelf 

Organization: 

Comment: I strongly urge the EPA to require monitoring at any facility that 

emits more than half a ton of airborne lead per year. The greatest threat to the 

future of the Republic is stupidity, of which lead poisoning is both the cause and 

effect. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6311 

Name: V. Garcia-Kalton 

Organization: 

Comment: While it would be in the best interests of every human being to stop 

the emission of any toxic substance into our atmosphere (how can there be 

"safe" amounts?) I strongly urge the EPA to enact rules to require monitoring at 

any facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Please consider putting in place rules/laws that 

cannot be undermined by politics to the detriment of our collective health. 

Common sense tells us that we do not require life-times of research to prove the 

harm that is obvious. Thank you for your kind consideration. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6405 

Name: C. Clarke 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 
179 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Please choose health over profit. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6309 

Name: G. Hirst 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Pass laws that will keep our air safe and clean. 

Protect our childrens' lives by giving them clean air to breathe. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6440 

Name: K. Gust 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. EPA is supposed to stand for an Agency that 

Protects the Environment. Can't do that without the power to monitor the air we 

breathe from toxic lead. Hard to educate children when they're becoming 

slowly brain damaged. Please get this done. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6307 

Name: G. Sterritt 

Organization: 

Comment: I think the EPA should require monitoring at all sites that emit 

significant quantities of lead. If levels exceed more than half a ton of airborne 
180 

lead per year (.50 tpy) then it is important to establish the volume of emissions 

and warn people exposed to this hazard downwind that they need to be on the 

outlook for symptoms of lead poisoning, especially in children who are most 

vulnerable. Bring this dangerous pollution under control to improve the health 

and well being of our community! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6316 

Name: S. Lippman 

Organization: 

Comment: I am writing to ask you at the EPA to pass rules that would require 

monitoring whenever an industry releases over half a ton, or .50 tpy, of airborne 

lead per year. Lead is very dangerous, especially to children. There is no way 

the long-term costs to people in terms of medical and social costs of this brain 

toxin would be less than the cost to industry to keep lead out of people. When 

industries are so powerful that they are able to keep themselves from being 

regulated, it is just a way of shifting their costs from their own balance sheets 

and onto the burdens and costs borne by families. Please pass strong regulations 

against lead. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6304 

Name: M. Fox 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. We have a responsibility to our future generations. 

Instead, what we are doing is sacrificing their health and well-being to satisfy 

the greed of our companies. If you cannot care about my children or your 

neighbor's children, at least demonstrate that you care about your own children 

and grandchildren. 

Response: Responded to in preamble. 
181 

Comment ID: OAR-2006-0735-6317 

Name: B. Rush 

Organization: 

Comment: Did you know that lead poisoning is one of the primary factors 

leading to the fall of the Roman Empire? Perhaps it helps explain why so many 

Americans are so dumb today. I strongly urge the EPA to enact rules to require 

monitoring at any facility that emits more than half a ton of airborne lead per 

year (.50 tpy). Monitoring this dangerous pollution will improve the health and 

well being of our community, especially our children who are particularly 

vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6302 

Name: B. Nicol 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. The Bush administration had its priorities 

backward and promoted industry over the environment and public health. 

Whereas the EPA's own technical analysis in 2008 supported monitoring any 

source of lead that emitted more than half a ton of lead into the air per year (.50 

tpy), Bush era officials were able to get the EPA to only require monitoring of 

sources that emitted double that amount (1.00 tpy). This dramatically 

undermined the EPA's ability to ensure the surrounding communities were not 

exposed to harmful amounts of lead. We now have a chance to fix one of the 

problems caused by the Bush administration's desire to prioritize the interests of 

dirty polluters over everyone else's health and safety. Don't let the polluters put 

pressure on the EPA to keep the rules the same. Airborne lead is toxic and can 

cause a host of medical problems, especially in children who are more 

susceptible to the harmful effects of lead exposure. Some of the problems it 

causes include lower IQ, behavioral problems, brain damage, kidney damage 

and cardiovascular injury. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6301 
182 

Name: C. Jenner 

Organization: 

Comment: The fact that any person would put industry and economics over 

humanity and safety is absolutely sickening. The mistaken Bush-era policies 

must be undone, immediately! I strongly urge the EPA to enact rules to require 

monitoring at any facility that emits more than half a ton of airborne lead per 

year (.50 tpy). Monitoring this dangerous pollution will improve the health and 

well being of our community, especially our children who are particularly 

vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6300 

Name: A. Kintree 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits airborne lead. Monitoring this dangerous pollution will 

improve the health and well being of our community, especially our children 

who are particularly vulnerable to the risks posed by lead toxicity. Lead 

ingestion causes reduced IQ and learning disabilities. We need all the 

brainpower we can get to work with the challenges we face today. 

Response: Monitoring at all sources of Pb is both impractical (there are well 

over 100,000 facilities that emit some amount of Pb) and unjustifiable. Very 

small sources of Pb have no potential to exceed the Pb NAAQS which was 

established at a level that protects public health with a margin of safety. The 

emission threshold finalized in this rule is intended to identify sources of Pb 

that have the potential to exceed the Pb NAAQS. 

Comment ID: OAR-2006-0735-6299 

Name: C. O. Thomas 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. We only have one sky and I consider it the very 

purpose of the Environmental Protection Agency to protect our sky for all 
183 

people and not let it be ruined by those who see dollar signs instead of 

breathable, healthy air. Thank you. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6298 

Name: C. Lay 

Organization: 

Comment: It is important that the EPA enact rules that require monitoring at 

any facility that emits more than half a ton of airborne lead per year (.50 tpy). I 

am a mother of two children and know that children are particularly vulnerable 

to the risks posed by lead toxicity. A child's body will absorb more lead through 

inhalation than by eating paint chips. As a parent living in a building built in the 

1920's, I am expected to maintain the paint in my home so that it does not chip 

and expose my children to lead paint. I expect the government to protect my 

children from lead that is airborne. I have no control over what industries emit 

into the air. The EPA has this ability and should not kowtow to industry. Please 

monitor any industry that emits more than a half ton of lead into the air per year. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6297 

Name: S. Chatman 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). The 

Center for Disease Control says, "Approximately 250,000 U.S. children aged 

1-5 years have blood lead levels greater than 10 micrograms of lead per 

deciliter of blood, the level at which CDC recommends public health actions be 

initiated. Lead poisoning can affect nearly every system in the body. Because 

lead poisoning often occurs with no obvious symptoms, it frequently goes 

unrecognized." There is no reason not track the release of a significant amount 

of this toxic substance. Please help keep Americans safe. Thank you. 

Response: Responded to in preamble. 
184 

Comment ID: OAR-2006-0735-6296 

Name: E. Carter 

Organization: 

Comment: PLEASE do the right thing ! I strongly urge the EPA to enact rules 

to require monitoring at any facility that emits more than half a ton of airborne 

lead per year (.50 tpy). Monitoring this dangerous pollution will improve the 

health and well being of our community, especially our children who are 

particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6295 

Name: M. Hillman 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. As a mother of 4 children, I would strongly 

advocate the overturning of this irresponsible Bush-era relaxation of EPA rules. 

Let this issue be revisited and corrected. Most of Bush's policies are injurious to 

citizens for the sake of corporate profit, so we need to reverse this egregious 

trend until they're all undone!!! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6306 

Name: M. Sawaya 

Organization: 

Comment: I am writing to strongly urge the EPA to enact rules to require 

monitoring at any facility that emits more than half a ton of airborne lead per 

year (.50 tpy). Monitoring this dangerous pollution will improve the health and 

well being of our community, especially our children who are particularly 

vulnerable to the risks posed by lead toxicity. We should always prioritize the 

interests of human beings over the interests of corporations that pollute the 

environment. And the health of children is especially important because they 

are the future. Please ensure that the air is as clean as possible and that we (and 
185 

especially children) are not being sickened by air pollution. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6327 

Name: C. Ransom 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollutant will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. We don't let our children eat lead paint anymore; 

why would we let them BREATH lead? Get tough on led fumes, please. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6337 

Name: P. Berg 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Our heath is so important and we trust the EPA to 

keep pollution to an absolute minimum. Please protect us! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6336 

Name: L. Green 

Organization: 

Comment: Please urge the EPA to monitor lead in the air. Rules must be 

enacted to require monitoring at any facility that emits more than half a ton of 

airborne lead per year (.50 tpy). This is strongly need to protect our children 

from lead exposure. 
186 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6335 

Name: B. Bennett 

Organization: 

Comment: I do everything I can to keep toxic substances out of my family's 

diet, but I need the government's help where the air is concerned. I strongly urge 

the EPA to enact rules to require monitoring at any facility that emits more than 

half a ton of airborne lead per year (.50 tpy). Monitoring this dangerous 

pollution will improve the health and well being of our community, especially 

our children who are particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6334 

Name: M. Johnson 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Please thoughtfully consider future generations. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6333 

Name: J. Jones 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. HALF THE MEN IN THE TOWN WHERE I 

GREW UP GOT LEAD POISONING FROM AN UNREGULATED STEEL 

MILL. 
187 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6332 

Name: A. Gilbert 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Lead is a known toxin, and efforts to date have 

made a significant difference: Let's be sure to continue to bring levels down! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6331 

Name: K. A. Kwayana 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Without strong and effective regulation, there will 

continue to be massive amounts of disease. Please do not hesitate to regulate 

these lead plants. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6330 

Name: H. Gartsman 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. EVERYTHING AND ANYTHING IS 
188 

IMPORTANT TO THE HEALTH & SAFETY FOR ALL OF US. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6315 

Name: A. Doherty 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Please do this not just for our health and well-being 

but for that of future generations. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6328 

Name: G. Oakes 

Organization: 

Comment: The EPA has a responsibility to protect the environment and the 

public good, not corporate interests. Therefore, I strongly urge the EPA to enact 

rules to require the most stringent monitoring standards of airborne lead 

possible. Monitoring this dangerous source of pollution will improve the health 

and well being of our community, especially our children who are particularly 

vulnerable to the risks posed by lead toxicity. 

Response: No response needed. 

Comment ID: OAR-2006-0735-6292 

Name: M. Carey 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). The 

Romans used lead water pipes because they didn't know better. WE DO! Please 

don't let the toxic effects of airborne lead compromise the opportunity for our 

kids to reach the full potential of their talent and drive. We can't afford to lose 
189 

any of their contributions in this global economy. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6326 

Name: P. Netzer 

Organization: 

Comment: Why would the EPA not be eager to enact laws requiring monitoring 

at any facility that emits anything more than a small amount of airborne lead per 

year (.50 tpy). Why would they not want to improve the health and well being 

of our nation and world? especially our children who are particularly vulnerable 

to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6325 

Name: P. Shannon 

Organization: 

Comment: It is imperative that we take strong action and stop the poisoning of 

our country. When allot of people finally recognized the terrible damage it will 

be to late to do anything about it. I strongly urge the EPA to enact rules to 

require monitoring at any facility that emits more than half a ton of airborne 

lead per year (.50 tpy). Monitoring this dangerous pollution will improve the 

health and well being of our community, especially our children who are 

particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6324 

Name: S. Scherk 

Organization: 

Comment: The Bush administration had its priorities backward and promoted 

industry over the environment and public health. I strongly urge the EPA to 

enact rules to require monitoring at any facility that emits more than half a ton 

of airborne lead per year (.50 tpy). Monitoring this dangerous pollution will 

improve the health and well being of our community, especially our children 
190 

who are particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6323 

Name: Dr. P. Sabey 

Organization: 

Comment: No government action should ever be taken without asking, IS THIS 

GOOD FOR THE CHILDREN? I strongly urge the EPA to enact rules to 

require monitoring at any facility that emits more than half a ton of airborne 

lead per year (.50 tpy). Monitoring this dangerous pollution will improve the 

health and well being of our community, especially our children who are 

particularly vulnerable to the risks posed by lead toxicity. PUTTING 

BIUSINESS OR ECONOMIC INTERESTS AHEAD OF CHILD HEALTH IS 

TANTAMOUNT TO CO 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6322 

Name: P. Crown 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. The health and safety of all should have priority 

over the profits of polluters. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6321 

Name: P. Green 

Organization: 

Comment: It is not your job to protect industrial profits! It is your job to protect 

the public's health! This is the reason for your very existence. Our health is your 

bottom line! Corporate profits earned through the slaughter of Americans, the 
191 

poisoning of our children - do you really support this? Toxic lead does not 

belong in our air, as your own scientists concluded! You must protect us from 

this deadly contaminant! 

Response: No response needed. 

Comment ID: OAR-2006-0735-6320 

Name: C. Pacosz 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. I also suffer from a condition brought on by heavy 

metals in the water and air - Chronic Fatigue Syndrome and fibromyalgia - and 

have a very personal stake in limiting such pollutants in the environment. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6318 

Name: N. York 

Organization: 

Comment: Keep toxic lead out of our air. Strengthen monitoring. The health 

impacts are well known. Please step up these regulations. 

Response: No response needed. 

Comment ID: OAR-2006-0735-6329 

Name: P. Glick 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. As you know, the buildup of lead in the 

environment is deadly, literally. 
192 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6259 

Name: P. Estes 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. I was diagnosed with Multiple Sclerosis several 

years ago. Why I have it, I don't know. "Experts" claim it to be either 

environmentally or virally induced to those who are predisposed to the cause of 

the affliction. Whatever..... If we don't set and monitor reasonable standards to 

protect our environment/ourselves from toxic pollution, we may lead ourselves 

to self destruction. It's on your watch to prevent such things. It's your job! If you 

can't handle the task, there are plenty of people out there that need a job and 

would gladly take yours away. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6269 

Name: C. von Hendricks 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Please do not continue to roll over for corporate 

interests. The environment belongs to everyone. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6268 

Name: S. Orrock 

Organization: 
193 

Comment: For once, do your job -- enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Put the shame of your work under the Bush 

administration behind you, do what's best for the planet and all living creatures 

on it. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6267 

Name: B. Sweeney 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Not addressing this problem is just a way of 

postponing the day when someone has to address it. How many people will be 

endangered by this lack of courage? President Obama was elected by people 

who wanted a change in how this country is governed. Keep toxic lead out of 

our air. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6266 

Name: J. Cooper 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. This matter seems so logical to me. We all breathe 

air. So it is logical that we would all want to breathe clean and healthy air. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6265 
194 

Name: F. Rhodes 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Let us create the most pollution free environment 

we can for the best quality of life for all citizens. Lead is one of the toxins that 

has long been known to impair health. Please monitor our public safety. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6264 

Name: D. H. Fabian 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). Our 

legislators have become so single-mindedly obsessed with tobacco (and 

tobacco taxes!) that these far more critical breathing-related issues have 

remained neglected. The real dangers the great majority of us face are the result 

of lax monitoring and enforcement of anti-pollution laws. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6263 

Name: E. Miller 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. As many of you know the number of cases of 

asthma in children has increased in the last few years. Perhaps by limiting the 

amount of toxic lead in the air, you can help to control the spread of this disease. 

Response: Responded to in preamble. 
195 

Comment ID: OAR-2006-0735-6262 

Name: S. Guariglia 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. We need to do the best we can to keep toxins out of 

our environment! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6294 

Name: S. Monteiro 

Organization: 

Comment: This is my public comment on rules to protect the American public 

from lead poisoning, particularly air born lead. I strongly urge the EPA to enact 

rules to require monitoring at any facility that emits more than half a ton of 

airborne lead per year (.50 tpy). Monitoring this dangerous pollution will 

improve the health and well being of our community, especially our children 

who are particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6260 

Name: P. Newcomb 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Allot of good industry will do us if we are all sick. 

I live in rural Vermont and some days I cough because of smog in the air. 

Response: Responded to in preamble. 
196 

Comment ID: OAR-2006-0735-6273 

Name: M. Reddigari 

Organization: 

Comment: The EPA should put political biases aside and remember that its first 

responsibility is to maintain the health and welfare of our communities by 

protecting the environments in which we all live. Re-enacting strict rules to 

require monitoring at facilities emitting airborne lead will help ensure that none 

are exposed to lead toxicity. This is a real threat that the EPA should know more 

about than any other governing body. If the EPA is not committed to the 

environment, who will be? The EPA must lead by example here. 

Response: No response needed. 

Comment ID: OAR-2006-0735-6258 

Name: C. Pinckney 

Organization: 

Comment: I am in favor of the EPA enacting rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring and enforcing limits on this pollution should be an obvious job for 

the EPA. Limiting airborne lead emissions will help safeguard the health of our 

citizens, especially our children, who are most vulnerable. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6257 

Name: B. Rierson 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. This is a no brainer. Do the job you are appointed 

to do--protect the citizens. Obama has a mandate to change the way our 

government did business. DO IT! 

Response: Responded to in preamble. 
197 

Comment ID: OAR-2006-0735-6256 

Name: J. Austin 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Save our Health, please. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6255 

Name: N. Pate 

Organization: 

Comment: Nothing is more important than our health. I strongly urge the EPA 

to enact rules to require monitoring at any facility that emits more than half a 

ton of airborne lead per year (.50 tpy). Monitoring this dangerous pollution will 

improve the health and well being of our community, especially our children 

who are particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6254 

Name: J. Ould 

Organization: 

Comment: It's the EPA's job to protect us the citizens. We know that self 

monitoring by corporations doesn't work. The EPA needs to take on the role of 

monitoring and protecting. I strongly urge the EPA to enact rules to require 

monitoring at any facility that emits more than half a ton of airborne lead per 

year (.50 tpy). Monitoring this dangerous pollution will improve the health and 

well being of our community, especially our children who are particularly 

vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6253 
198 

Name: D. Schoech 

Organization: 

Comment: Our air in Dallas Fort Worth is bad, especially in the summer when 

kids and adults can work and play outside. I strongly urge the EPA to enact 

rules to require monitoring at any facility that emits more than half a ton of 

airborne lead per year (.50 tpy). Monitoring this dangerous pollution will 

improve the health and well being of our community, especially our children 

who are particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6252 

Name: D. Bell 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Should we even have to ask ? 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6251 

Name: A. Swank 

Organization: 

Comment: It's shameful that our government would consider continuing to 

allow companies to poison our air. Haven't you heard? Our snow is toxic. I 

strongly urge the EPA to enact rules to require monitoring at any facility that 

emits more than half a ton of airborne lead per year (.50 tpy). Monitoring this 

dangerous pollution will improve the health and well being of our community, 

especially our children who are particularly vulnerable to the risks posed by 

lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6261 
199 

Name: E. Herrera 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Please reduce the levels. My children so ill due to 

Houston’s polluted air. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6282 

Name: P. Lloyd 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. As someone with asthma, and the parent of 

children with asthma, I believe clean air is of vital importance to our future. 

Plus, I also recognize that particulates such as lead emitted into the air will 

contaminate the entire area and can lead to far more serious problems, such as 

birth defects and the reduction of children's intelligence. Please, don't let this 

happen to our children. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6310 

Name: M. Rigby 

Organization: 

Comment: As a teacher of students with learning disabilities, I have a personal 

concern with the amount of lead that is being inhaled by children. Of course 

children are much more vulnerable to the effects of lead poisoning than adults. 

The effect on the nervous system of toxic lead levels is profound and very 

difficult to reverse, especially in children who are still developing brain tissue. 

Please do whatever it takes to put a reliable, enforceable method of monitoring 

and controlling the amount of toxic lead that is dumped into the environment. 

Whatever is being produced by pumping lead into the breathable environment 
200 

simply cannot be worth the brain of even one of our children. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6291 

Name: M. Lewis 

Organization: 

Comment: I write to strongly urge the EPA to enact rules that require 

monitoring at any facility that emits more than half a ton of airborne lead per 

year (.50 tpy). The health of U.S. children and adults far outweighs the interests 

of corporations. Monitoring this dangerous pollution will improve the health 

and well being of our community. It is up to you to protect us! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6290 

Name: Comment submitted by C. Baldwin 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Please enact a commission to monitor the lead 

pollution. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6289 

Name: M. Quintana 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. We must do what we can to keep our generations of 

today and not only humans but everything living on earth as healthy and safe as 
201 

possible. To let your guards down because of the Bush administration is already 

a joke but to actually agree and think this action is okay is absurd. I really wish 

and hope you reconsider this. one love. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6288 

Name: P. McAloon 

Organization: 

Comment: We have spent far too many years ignoring the health effects of the 

pro-business decisions made during the Bush Administration!! I look into the 

faces of children every day and wonder what health problems they will 

encounter in the next 20-40-60 years as a result of our poor decisions. I strongly 

urge the EPA to enact rules to require monitoring at any facility that emits more 

than half a ton of airborne lead per year (.50 tpy). Monitoring this dangerous 

pollution will improve the health and well being of our community, especially 

our children who are particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6287 

Name: M. Long 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. If we wish to cut the costs of health care we need to 

work towards having healthier citizens and having them not breathing in lead is 

a good step. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6286 

Name: P. Ryan 

Organization: 
202 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. C'mon guys, you are supposed to be on the peoples 

side! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6285 

Name: M. B. Mueller 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Please ensure that our air quality improves and is 

free from dangerous levels of lead. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6270 

Name: K. Walters 

Organization: 

Comment: I ***STRONGLY*** urge the EPA to enact rules to require 

monitoring at any facility that emits more than half a ton of airborne lead per 

year (.50 tpy). Monitoring this dangerous pollution will improve the health and 

well being of our community, especially our children who are particularly 

vulnerable to the risks posed by lead toxicity. PLEASE KEEP THE LEAD 

OUT OF OUR AIR!!! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6283 

Name: M. Garrigues-Cortely 

Organization: 
203 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Lead has long been known to be a toxin, and we 

need to have information in order to be able to protect public health. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6272 

Name: B. Bell 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Heavy metals such as lead and mercury are poison 

and cause irreparable damage to the nervous system.

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6281 

Name: P. Piedrahita 

Organization: 

Comment: As our world continues to support ever increasing human population 

numbers the strain on our resources will continue. This does not mean that we 

should sacrifice the quality of our lives by succumbing to ideas of inevitable 

contamination of our environment. We can in fact continue to grow sustainably 

without giving up such essential resources as clean healthy air. I strongly urge 

the EPA to enact rules to require monitoring at any facility that emits more than 

half a ton of airborne lead per year (.50 tpy). Monitoring this dangerous 

pollution will improve the health and well being of our community, especially 

our children who are particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6280 
204 

Name: S. Dixon 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Even a half ton of airborne lead is detrimental to 

your and my health. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6279 

Name: S. McAninch 

Organization: 

Comment: You need an EPA that stands up for clean air!!! Even your top execs 

and their grand children will choke to death if we keep on polluting the way we 

are. I strongly urge the EPA to enact rules to require monitoring at any facility 

that emits more than half a ton of airborne lead per year (.50 tpy). Monitoring 

this dangerous pollution will improve the health and well being of our 

community, especially our children who are particularly vulnerable to the risks 

posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6278 

Name: N. Egen 

Organization: 

Comment: No lead should ever be released into the atmosphere. Credo is 

suggesting that the EPA should be monitoring any facility that releases more 

than 0.5 tpy, that is 1000 lbs of airborne lead per year. This is ridiculous. You 

know, all a company has to do is to register with 10 names and then they can 

release 5 tons per year with impunity. Any company that is known to release 

lead as a byproduct of production should be monitored and a lead limit of 1 lb 

per year should be the maximum before the facility is closed down until they 

which time it can sequester all its lead emissions. We are far more important 

than battery companies, coal fired power plants and the like. 

Response: Responded to in preamble. 
205 

Comment ID: OAR-2006-0735-6277 

Name: N. Morell 

Organization: 

Comment: Lead in the air? Are you kidding me? What Bush has done to this 

country must be undone as soon as possible. I strongly urge the EPA to enact 

rules to require monitoring at any facility that emits more than half a ton of 

airborne lead per year (.50 tpy). Monitoring this dangerous pollution will 

improve the health and well being of our community, especially our children 

who are particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6276 

Name: N. Zorn 

Organization: 

Comment: Can there be a goal more important to the protection of our 

environment than the health of our children? Please reenact strong rules to 

monitor our factories and smelting plants for lead containing emissions. I 

strongly urge the EPA to enact rules to require monitoring at any facility that 

emits more than half a ton of airborne lead per year (.50 tpy). Monitoring this 

dangerous pollution will improve the health and well being of our community, 

especially our children who are particularly vulnerable to the risks posed by 

lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6275 

Name: M. Warfel 

Organization: 

Comment: Proceed with enhanced monitoring of Lead emissions. We need to 

know what is being released so that we can apply appropriate controls. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6274 
206 

Name: M. Swire 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6293 

Name: M. M. Mueller 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution allows for better regulation of this toxin 

and faster reaction times if the lead levels released exceed the set limits. As a 

result, we can use the information gathered from the monitoring to improve the 

health and well being of our community, especially our children who are 

particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6284 

Name: M. Mathews 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Coal-fired energy plants are dousing residents in 

ma 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6363 
207 

Name: T. Dimas 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. By the way, I don't buy the GOP party line that 

increased regulations send jobs over seas...we decimated the working class in 

this country, sending mass numbers jobs overseas during Deregulation eras of 

Reagan, and both Bush Administrations. We the people need protection from 

corporations who will ONLY do the right thing if forced to do so by regulations 

with teeth AND adequate enforcement to back it up. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6397 

Name: J. Martin 

Organization: 

Comment: The EPA is entrusted to keep our air clean and should be held to that 

responsibility. Please do your job. I strongly urge the EPA to enact rules to 

require monitoring at any facility that emits more than half a ton of airborne 

lead per year (.50 tpy). Monitoring this dangerous pollution will improve the 

health and well being of our community, especially our children who are 

particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6369 

Name: C. Geist 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Actually that amount is outrageous. To emit any 

lead into the air is dead wrong. 

Response: Responded to in preamble. 
208 

Comment ID: OAR-2006-0735-6368 

Name: D. Hiltz 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. what happens if we ignore this problem, do we 

really want to pass this to our kids and their kids

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6367 

Name: B. Cunningham 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits airborne lead. The science is in, and has been for years! Lead 

kills, lead mentally devastates children. It is time to stop this nonsense and stop 

destroying the only world we've got. Monitoring this dangerous pollution will 

improve the health and well being of our community, especially our children 

who are particularly vulnerable to the risks posed by lead toxicity. 

Response: Monitoring at all sources of Pb is both impractical (there are well 

over 100,000 facilities that emit some amount of Pb) and unjustifiable. Very 

small sources of Pb have no potential to exceed the Pb NAAQS which was 

established at a level that protects public health with a margin of safety. The 

emission threshold finalized in this rule is intended to identify sources of Pb 

that have the potential to exceed the Pb NAAQS. 

Comment ID: OAR-2006-0735-6366 

Name: T. Homburg 

Organization: 

Comment: *Thank you for protecting our health by strengthening rules to limit 

lead emissions to .50 tons per year for any one industrial source. Monitoring 

this dangerous pollution will improve the health and well being of our 

community, especially our children who are particularly vulnerable to the risks 

posed by lead toxicity. Keep up the good work! 
209 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6358 

Name: S. Brownrigg 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. STOP DAMAGING OUR PEOPLE AND OUR 

PLANET. WE ALL LIVE HERE!! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6364 

Name: A. Bila 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. It's time we used some money for our health. Get 

rid of mercury now. Thank you. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6308 

Name: A. Mizicko 

Organization: 

Comment: Geez. Are we still dealing with lead pollution?! Let's please keep our 

children safe even if it nibbles at the profits of corporate polluters. Keep 

standards for airborne lead pollution strict, please. 

Response: No response needed. 
210 

Comment ID: OAR-2006-0735-6362 

Name: S. Kirschner 

Organization: 

Comment: I write to support enactment of rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year. It is known that 

monitoring this dangerous pollution will improve the health and well being of 

our citizens, especially children, who are particularly vulnerable to the risks 

posed by lead toxicity. Time to once again assume leadership in 

PROTECTING our citizens and our environment, thus living up to your name 

and mandate. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6361 

Name: S. Bonner 

Organization: 

Comment: I'm writing to ask that the EPA require the monitoring of any factory 

that emits more than half a ton of airborne lead per year. Please don't let these 

corporations gamble with our health. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6398 

Name: J. Dobkin 

Organization: 

Comment: I am shocked by the levels of lead still present in our air. I strongly 

urge the EPA to enact rules to require monitoring at any facility that emits more 

than half a ton of airborne lead per year (.50 tpy). Monitoring this dangerous 

pollution will improve the health and well being of our community, especially 

our children who are particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6360 

Name: S. Millet 
211 

Organization: 

Comment: As a grandmother I strongly urge the EPA to enact rules to require 

monitoring at any facility that emits more than half a ton of airborne lead per 

year (.50 tpy). Monitoring this dangerous pollution will improve the health and 

well being of our community, especially our children who are particularly 

vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6359 

Name: S. Fouche 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. The Bush administration would have gladly 

eliminated the EPA, but settled for weakening it. We need to take back the 

original intent of the establishment of this agency. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6379 

Name: I. Hack 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Added comments... I have extraordinarily high 

levels of lead and mercury in my body. It's an issue I've been addressing for 

many years. How can it be okay for companies to allow dumping of toxic 

chemicals into our air and water? It's poisoning people slowly and as they 

become more toxic--more chronic diseases continue to grow. Would the 

owners of these big companies consider poisoning their children? The future of 

healthy children and adults depends on clean air. Look at the outrageously large 

increase in cancers in the U.S. This is part of why people are dying. Please 

listen to us and change your business practices--for the sake of all people. 
212 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6365 

Name: P. Torek 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. I work in a the field of detection and monitoring of 

metals. The technology in this field is very powerful and is becoming dirt 

cheap. When industry complains about the "burden" this imposes, don't take a 

ride in their Waaahmbulance. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6374 

Name: R. Schulte 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Please, as a citizen I strongly urge you to follow the 

guidelines that the agency itself supported with it's own analysis in 2008. 

Please, preserve the right of Americans to the justice of clean air. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6378 

Name: J. Blackwood 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 
213 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. I'm a long-time resident of Missouri so I have 

heard much about the ill-effects of lead on the children of our state. It's bad 

enough we are still trying to clean up polluted sites from mistakes made years 

ago in the tri-state mining area and SE Missouri. It's even worse that we might 

contribute more to the problem with new, unregulated sources of lead in the 

environment. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6377 

Name: J. Domingue 

Organization: 

Comment: I support monitoring airborne lead sources of more than half a ton of 

lead per year. This had been the EPA's own recommendation until the Bush 

Administration squashed it. I hope you will not allow corporate greed to allow 

public health to suffer. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6380 

Name: J. Goodwin 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Filtering this airborne poison will improve the health and well being of our 

community, especially our children who are particularly vulnerable to the risks 

posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6376 

Name: J. Archuleta 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 
214 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6381 

Name: C. Quinn 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. I am an endurance athlete that is careful about 

where I train and race due to deteriorating air quality. The earth's atmosphere 

must be cleaner to support it's growing population. The EPA must take action 

and ensure our air quality does not become like China's! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6382 

Name: A. Brutsche 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. All life deserves to be able to breathe clean air. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6384 

Name: M. Clark 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 
215 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Please consider the long term impacts our choices 

will have on our children and grandchildren. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6375 

Name: J. Bevsek 

Organization: 

Comment: Please enact strong monitoring rules for facilities that emit 

dangerous airborne lead, and protect our and our childrens' health against this 

toxic waste. Thank you. 

Response: No response needed. 

Comment ID: OAR-2006-0735-6383 

Name: J. Hoegler 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. The American public depends on your work to 

ensure air safety. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6395 

Name: P. Wong 

Organization: 

Comment: Lead intake damages children's brains. Yet the EPA has rolled back 

monitoring rules. I strongly urge the EPA to correct the odious mistake of the 

Bush administration by enacting rules to require monitoring at any facility that 

emits more than half a ton of airborne lead per year (.50 tpy). Monitoring this 
216 

dangerous pollution will improve the health and well being of our community, 

especially our children who are particularly vulnerable to the risks posed by 

lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6396 

Name: J. Boudart 

Organization: 

Comment: There is no known "least amount" of lead that is acceptable in 

human physiology. As soon as possible the acceptable amount should be 

brought down as low as possible. I strongly urge the EPA to enact rules to 

require monitoring at any facility that emits more than half a ton of airborne 

lead per year (.50 tpy). Monitoring this dangerous pollution will improve the 

health and well being of our community, especially our children who are 

particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6373 

Name: D. D. Booker 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. At the rate we are going, homo sapiens will no 

longer exist in their present form. We are on our way to being our own aliens. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6372 

Name: D. McRae 

Organization: 

Comment: Because it especially endangers the health of children, I strongly 

urge the EPA to enact rules to require monitoring at any facility that emits more 
217 

than half a ton of airborne lead per year (.50 tpy). Monitoring this dangerous 

pollution will improve the health and well being of our community, especially 

our children who are particularly vulnerable to the risks posed by lead toxicity. 

Please keep in mind that it is the measure of a society's moral health how we 

treat our most vulnerable members. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6371 

Name: D. Cheman 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. We have no greater birthright than clean air. No 

one or no entity should be allowed to destroy that right. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6357 

Name: R. Tantala 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. As GRANDMOTHER I'm especially concerned 

about this issue and so is my mother--GREAT-GRANDMOTHER of two--and 

my daughter. So please think about our kids when you enact these rules. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6339 

Name: L. Bevan 

Organization: 
218 

Comment: I have seen the effects of lead poisoning in Kellogg, Idaho and hope 

that nothing like it happens again. The children there had been poisoned and 

their IQs changed forever. I strongly urge the EPA to enact rules to require 

monitoring at any facility that emits more than half a ton of airborne lead per 

year (.50 tpy). Monitoring this dangerous pollution will improve the health and 

well being of our community, especially our children who are particularly 

vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6345 

Name: R. Luongo 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Surely this is one preventative health care measure 

we can take to save us millions in future health care bills. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6387 

Name: J. Long 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. The raise in auto immune diseases is increasing at a 

rapid rate because of this pollution and others. Illness are developing every day 

because of our over industrialization and the lack of concern for the health of 

people. Please regulate today for the sake of our civilization and that of our 

environment. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6392 
219 

Name: J. McElhatton 

Organization: 

Comment: As an RN I am acutely aware of the damaging effects of lead on 

children. These effects are long term, affecting children, their families and their 

communities, and are both costly and heart wrenching. More importantly, they 

can be prevented by reducing exposure of children to lead. I strongly urge the 

EPA to enact rules to require monitoring at any facility that emits more than 

half a ton of airborne lead per year (.50 tpy). 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6349 

Name: J. Murphy 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Even a thousand pounds in the air every year over 

the years sounds too dangerous to me. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6388 

Name: J. Neidich 

Organization: 

Comment: I am a pediatrician and I know first hand the destruction that lead 

can cause in children. I strongly urge the EPA to enact rules to require 

monitoring at any facility that emits more than half a ton of airborne lead per 

year (.50 tpy). Monitoring this dangerous pollution will improve the health and 

well being of our community, especially our children who are particularly 

vulnerable to the risks posed by lead toxicity. Children with lead poisoning 

have diminished capacity to learn, hyperactivity, and possibly permanent 

developmental delays. We need to protect children from this devastating toxin. 

Response: Responded to in preamble. 
220 

Comment ID: OAR-2006-0735-6348 

Name: J. Ascher 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). Lead 

is a very dangerous substance. Only close monitoring of its use and rapid 

responses to abuses in its mining, transport, and manufacturing processes are 

required to keep the general public safe. Monitoring this dangerous pollution 

will improve the health and well being of our community, especially our 

children who are particularly vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6347 

Name: D. I. Fearn 

Organization: 

Comment: I have a direct personal interest in pollution free air. I suffer from 

asthma and allergies. I strongly urge the EPA to enact rules to require 

monitoring at any facility that emits more than half a ton of airborne lead per 

year (.50 tpy). Monitoring this dangerous pollution will improve the health and 

well being of our community, especially our children who are particularly 

vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6370 

Name: D. Seals 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. We thank you for your time in re-considering such 

a measure which has such an impact on us all. 

Response: Responded to in preamble. 
221 

Comment ID: OAR-2006-0735-6346 

Name: D. Pray 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. It's simple, do you want to save babies lives by 

limiting toxic pollution? 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6393 

Name: K. Whitcomb 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Clean air is a basic human right. Thank you for 

your attention to this matter. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6344 

Name: N. Nathan 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. WHY ARE WE HAVING TO TELL YOU THIS? 

ISN'T THIS YOUR DUTY/JOB? 

Response: Responded to in preamble. 
222 

Comment ID: OAR-2006-0735-6343 

Name: S. Alex 

Organization: 

Comment: Will you please enact rules to require monitoring at any facility that 

emits more than half a ton of airborne lead per year (.50 tpy)? Monitoring this 

dangerous pollution will improve the health and well being of our community, 

especially our children who are particularly vulnerable to the risks posed by 

lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6342 

Name: M. Maloney 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Isn't the current level of autoimmune diseases in 

our culture cause for alarm? How can you possibly justify allowing more 

poison into our environment? Be the change we need, NOW! 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6391 

Name: H. Boschen 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. The reason we stopped using lead shot in the 

shotgun was because it poisoned birds. Can we not do the same for children? 

Response: Responded to in preamble. 
223 

Comment ID: OAR-2006-0735-6390 

Name: J. LaClaire 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. If EPA does not act on this, who will? You must be 

the watchdogs for the safety of our health. The horrific results of lead mining in 

Missouri and Oklahoma have left piles of waste that have been used in 

playgrounds, roads, other construction. This MUST not happen again. Please 

act courageously. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6340 

Name: H. James 

Organization: 

Comment: It's a no brainer, lead poisoning of children means non-viable adults. 

I strongly urge the EPA to enact rules to require monitoring at any facility that 

emits more than half a ton of airborne lead per year (.50 tpy). Monitoring this 

dangerous pollution will improve the health and well being of our community, 

especially our children who are particularly vulnerable to the risks posed by 

lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6389 

Name: J. Landon 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Whereas I want to support industry, the whole 

picture must be considered, including the quality of life and health of the 

citizenry. Please protect the public. 
224 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6402 

Name: R. Cerello 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. There can be no doubting the necessity of this 

action after too-long a wait, denial, lying and worse, no debate on this data, and 

no hesitating. Unless such obvious and desperately-needed legislation is swiftly 

enacted, its political points for you its sponsors and the benefits it could provide 

and would provide for citizens will both be compromised. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6403 

Name: D. McDowell 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. Don't sell the future for a little gain now. Protect 

our environment! Smart, Sustainable growth is what we need even if it means 

some sacrifices. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6356 

Name: R. Ovenshire 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 
225 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. What industry saves by polluting the air, costs the 

people who have to breathe it in poor health and death. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6386 

Name: J. Ott 

Organization: 

Comment: Though the following is a form letter, I firmly stand behind all the 

sentiments expressed: I strongly urge the EPA to enact rules to require 

monitoring at any facility that emits more than half a ton of airborne lead per 

year (.50 tpy). Monitoring this dangerous pollution will improve the health and 

well being of our community, especially our children who are particularly 

vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6385 

Name: J. Kind 

Organization: 

Comment: It is jaw-dropping, gut-wrenching to witness the dilution of clean air 

standards that has taken place over the last few years! The health implications 

of air pollution are so well documented that it is unconscionable to do anything 

less than strengthen the EPA's ability to monitor the industries responsible for 

violating air quality standards that threaten public health. It is contrary to the 

very existence of the EPA. I strongly urge the EPA to enact rules to require 

monitoring at any facility that emits more than half a ton of airborne lead per 

year (.50 tpy). Monitoring this dangerous pollution will improve the health and 

well being of our community, especially our children who are particularly 

vulnerable to the risks posed by lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6352 

Name: L. St. John 
226 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. After decades of science why must the government 

continue to be told that poisons are poisonous? 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6399 

Name: J. Kuntz 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. And guess what...in the long run it will save us 

money. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6353 

Name: R. Snook 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. We depend on you to protect our children from this 

hazard. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6351 

Name: J. Dryer 
227 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. The ability to monitor the levels of all heavy 

metals, especially lead into the air and water, should be required by the EPA, so 

that citizens may know whether an area near such facilities remain habitable. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6400 

Name: J. Kenney 

Organization: 

Comment: I urge the EPA to enact rules to require monitoring at any facility 

that emits more than half a ton of airborne lead per year (.50 tpy). Monitoring 

this dangerous pollution will improve the health and well being of our 

community, especially our children who are particularly vulnerable to the risks 

posed by lead toxicity. Our country must lead the way in correcting 

environmental hazards. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6350 

Name: J. and C. DeMayo 

Organization: 

Comment: Everyone knows that the science tells us that lead is lethal to public 

health. You must control the airborne lead that ends up in the air we breathe. I 

strongly urge the EPA to enact rules to require monitoring at any facility that 

emits more than half a ton of airborne lead per year (.50 tpy). Monitoring this 

dangerous pollution will improve the health and well being of our community, 

especially our children who are particularly vulnerable to the risks posed by 

lead toxicity. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6354 
228 

Name: R. Curry 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. It is important that we not allow pollution to cause 

potential health risks especially since we are likely headed for nationalized 

health care. The costs, both to productivity and otherwise could be devastating. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6355 

Name: M. Moran 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. This action will save lives. Thank you for your 

immediate attention to this important matter. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6401 

Name: J. G. Gilmore 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. As a grandparent whose grandchild suffered from 

exposure to lead poisoning, I strongly urge you to consider the future of our 

grandchildren and great grandchildren, no amount of money can replace our 

youth. Stop poisoning our children!! 

Response: Responded to in preamble. 
229 

Comment ID: OAR-2006-0735-6394 

Name: K. Noble 

Organization: 

Comment: I strongly urge the EPA to enact rules to require monitoring at any 

facility that emits more than half a ton of airborne lead per year (.50 tpy). 

Monitoring this dangerous pollution will improve the health and well being of 

our community, especially our children who are particularly vulnerable to the 

risks posed by lead toxicity. There is nothing more important to give our 

children and grandchildren than clean air and water! Don't leave them this mess 

to clean up too! 

Response: Responded to in preamble. 

 
230 

Comments on Monitoring at Airports 

Comment ID: OAR-2006-0735-5957 

Name: Chris Kunze 

Organization: The City of Long Beach Airport Department 

Comment: As an example of the need for more accurate data to determine a 

need for monitoring, although the Long Beach Airport (LGB) is listed as #6 on 

your list of airports proposed for specific Pb monitoring, the underlying airport 

operations data was based on the year 2002. Since 2002, general aviation 

operations activity at LGB has DECREASED by 20%, not at all reflected in 

EPA's estimates. Since 2002, AVGas (fuel used by GA prop aircraft) fuel sales 

has DECREASED by 49%. Current data should be available from all of the 

airports subject to potential monitoring under the EPA NPRM, which would 

allow for a much more accurate assessment of need. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5948 

Name: Ted Steichen 

Organization: American Petroleum Institute (API) 

Comment: Given the limited data on airport lead emissions used by EPA in 

developing the NAAQS and this NPRM, we recommend a careful review of the 

data, assumptions and methodology EPA used to estimate airport lead 

inventories. Specific recommendations include: 

· EPA should review and compare its estimation process against the Federal 

Aviation Administration (FAA) Emissions and Dispersion Modeling System 

(EDMS). 

· Operations data used to allocate lead to airports were estimated from the 

FAA’s Terminal Area Forecast (TAF) system for the year 2002. EPA/FAA 

should verify the accuracy of those estimates against actual 2002 activity. 

· EPA should improve/verify turboprop vs. nonturboprop aircraft data at 

airports. 

· EPA should verify values used for concentration of lead in fuel and retention 

of lead in engine and oil. 

· EPA should verify the categorization of local area or itinerant operation and 

the role it has in emission estimates inside/outside the landing and takeoff 

(LTO) cycle. 

· EPA indicates that it does not have LTO cycle data for 14,000+ airports and 
231 

the Technical Support Document2 (TSD) says EPA should collect and analyze 

this information. EPA should move forward on its own recommendation in the 

TSD and develop and verify methods to estimate LTO activity at these small 

facilities. 

Response: EPA has responded to these suggestions. Our latest analysis and 

information is presented in the memo to the Pb NAAQS docket titled 'Selection 

of Airports for the Airport Monitoring Study' and is further described in the 

document 'Calculating Piston-Engine Aircraft Airport Inventories for Lead and 

Other Criteria Pollutants for the 2008 National Emissions Inventory' available 

at: http://www.epa.gov/ttn/chief/net/2008inventory.html. Additional 

information is being collected by EPA and when available will be posted at: 

www.epa.gov/otaq/aviation.htm. 

Comment ID: OAR-2006-0735-5951 

Name: G. Vinson Hellwig 

Organization: The Michigan Department of Natural Resources and 

Environment (MDNRE) 

Comment: 3. Nationwide lead monitoring at airports is not justified at this time. 

The only empirical evidence offered by the EPA to demonstrate the need for 

lead monitoring at airports is the 0.1 pg/m3 three-month concentration recorded 

at an airport in Santa Monica, California. The MDNRE wishes to point out that 

a 0.1 pg/ma concentration is below the lead NAAQS of 0.15 ug/m3. Given that 

emissions at airports are spread over a very large area, applying a ratio to Santa 

Monica’s emissions and observed concentrations to develop an emission 

threshold for lead monitoring at airports across the nation is hardly persuasive. 

Due to the paucity of lead monitoring data at airports, the lack of appropriate 

data such as runway usage by plane type and terrain characteristics, as well as 

the logistical constraints caused by airports grounds having limited access, pilot 

projects should be carried out by the EPA at a handful of airports having the 

highest lead emissions before nationwide monitoring is required. This approach 

will allow the EPA to better characterize the problem while minimizing costs. 

Even if such a pilot study approach to lead monitoring is adopted, the EPA 

needs to develop specific siting requirements. Considerations should include: 

1) whether the required number of monitors per airport is based upon 

emissions, the number of runways, the airport’s total acreage or upon some 

other metric; 2) whether meteorological data collected at airports by the 

National Weather Service will be adequate despite different thresholds and 

integration times; and 3) what constitutes ambient air. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5951 
232 

Name: Avinash Kar 

Organization: Natural Resources Defense Council (NRDC) et al. 

Comment: The available evidence also supports the retention of the same 

monitoring threshold for airports which emit more than 0.5 tons per year of 

lead. Due to the continued use of leaded aviation gas, USEPA estimated that 

over 600 tons of lead were released from piston-engine powered aircraft in 

2002.5 Because piston-engine powered aircraft continue to be a significant 

presence at general aviation airports, these airports continue to be a source of 

lead emissions with the potential to result in lead concentrations in exceedence 

of the NAAQS. Although lead emissions from aircraft can be dispersed widely, 

evidence from studies suggests that the landing and take-off activities at general 

aviation airports increases pollutant levels in adjacent communities. In 

particular, spikes in particulate matter concentrations, which can carry the lead 

contamination, were associated with aircraft activity at a general aviation 

airport in Southern California. 6 In addition, due to their reduced size, general 

aviation airports are frequently in closer proximity to neighboring communities 

than larger airports, thereby exposing populations to potentially unsafe 

pollutant levels.7 All five of the studies EPA reviewed where lead was 

monitored downwind from airports found elevated lead concentrations and, 

where the monitoring was consistent with the NAAQS, the concentrations were 

significant.8 The latest and best available data on downwind pollution from 

these airports thus supports the decision to consider them point sources 

analogous to industrial facilities with the potential to cause downwind lead 

concentrations exceeding the NAAQS. As the EPA points out, there is no 

evidence to support a departure from the monitoring threshold for industrial 

sources. Therefore, EPA is justified in requiring monitors downwind of airports 

with estimated emissions exceeding 0.5 tons of lead per year. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5953 

Name: Sandra F. Veazey 

Organization: Florida Department of Environmental Protection 

Comment: Lead at airports is emitted by piston engine aircraft using leaded 

gasoline. Monitoring at airports will provide data for EPA but will not result in 

state actions to eliminate the source of the lead. lf the lead NAAQS is violated 

at airports a federal response will be required to change the lead content in the 

aviation fuel. Since the appropriate response to any violations would be a 

federally controlled change. monitoring at most airports will not serve to 

protect public health. Rather than requiring monitoring at many airports in each 

state. the division encourages EPA to develop its data by performing 

monitoring at a small number of airports throughout the country. 
233 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5955 

Name: Leslie Riegle 

Organization: American Association of Airport Executives (AAAE) 

Comment: Monitor Placement We would not discourage the EPA from its 

responsibility to monitor ambient air quality of the public. With that said, we 

would like to make certain that this testing is accurate; measuring only ambient 

air, as defined in 40 CFR Part 50.1 as “that portion of the atmosphere, external 

to buildings, to which the general public has access”. Placement of the monitors 

is perhaps the most critical element for an accurate assessment. Monitors placed 

directly at the end or sides of a runway where aircraft are taking off would not 

be indicative of “ambient air” in most, if not all, general aviation airports. There 

are many factors at each airport which could affect the accuracy of monitoring: 

wind speed, wind direction, relative humidity, ambient temperature and other 

meteorological effects, ‘‘urban background lead’’, and of course proximity to 

the general public, as previously mentioned. We would like assurance that local 

authorities are instructed by the EPA to work with airports to make certain all of 

these factors are taken into consideration. 

Response: The EPA has and will continue to work with monitoring agencies to 

help them identify proper locations. Due to the potential for additional 

complexity in siting monitors at airports, the EPA expects to work particularly 

close with monitoring agencies in ensuring proper siting of monitors at airports. 

Comment ID: OAR-2006-0735-5955 

Name: Leslie Riegle 

Organization: American Association of Airport Executives (AAAE) 

Comment: AAAE members would like to provide the EPA with as many 

current, valid data points as possible, but are unable to do so extensively, given 

the time constraint of the comment period. Despite this minimal time allotment, 

we hope to provide you with some useful clarification. We agree with EPA’s 

assessment, that data given by the state and local authorities should use more 

recent statistics than 2002. Many events including significant fuel price 

increases, and aircraft utilization decreases, have occurred since this time 

period. However, instead of the recommended three year period advised in 

EPA’s Technical Support Document (TSD) on page 6, we would recommend at 

least a five year average in order to derive any significant statistical data. Piston 

vs. Turbine GA Aircraft Activity The breakdown of piston vs. turbine aircraft is 

essential to generate meaningful statistics for EPA’s projected lead emissions 
234 

amount. Given the information provided to AAAE from our membership we 

estimate that 56% of all aircraft at general aviation facilities operate piston 

engine aircraft. The EPA on page 4 of the TSD, has used the 2005 GAATA 

Survey to estimate this amount, and has deduced that approximately 72% of all 

GA and Air Taxi Landing and Take-Off activities are from piston-engine 

aircraft which use avgas, and about 28% are turboprop and turbojet powered 

which use jet fuel. As you can see from our reported average number, this 

would appear to be an overstatement, perhaps due to increased piston aircraft 

activity in that particular year; thus, the need to take several years into account 

when deriving these averages. Avgas Usage/Sales Avgas usage (as determined 

in this case by sales) is also an essential data point. We would again state that 

using information from one particular year, in this case 2002, does not produce 

an accurate assessment. Usage/sales figures should have been averaged over 

several years, as demand can increase and decrease greatly from year to year. In 

fact, according to reports from our membership, avgas sales have dropped 

dramatically in the last few years. In one particular case, while avgas was 57% 

of the total fuel sold in 2002, this number was only 41% in 2008, indicating that 

the use of avgas has started to make up less of total fuel sold at that GA facility. 

Another airport reported that in 2002, the year that the EPA uses as its base for 

many of the calculations, avgas fuel sales were around 526,899 gallons. In year 

2009, it sold only 254,357 gallons. Meaning less than half the amount of avgas 

was sold last year than in 2002. On average, however, we found our airport 

members’ sales had dropped 35% since 2002. The EPA should recognize that 

avgas fuel sales have been dramatically declining since their studies were 

conducted. Aircraft Movements Similar to that of avgas figures, which should 

not be taken exclusively from one year, aircraft landing and take-off (LTO) 

activity data, referenced on Page 3 in the TSD, and derived from FAA’s 

Terminal Area Forecast (TAF) system, was also only sampled from the year 

2002. Though interlinked with avgas usage, merely taking one snapshot of the 

industry could lead to overestimation especially during such economic 

volatility. Much is the same for aircraft utilization as avgas figures; the demand 

has dropped significantly in the last few years, making this data point 

irrelevant. Landing and Take-Off (LTO) Cycle We are hopeful that local 

authorities or individual airports are able to provide the EPA with more 

accurate figures regarding taxi/idle-out, takeoff, climb-out, approach, and 

taxi/idle-in times. Also, we agree that this information varies greatly at each 

airport, and should be documented and taken into consideration by the EPA 

when monitoring is conducted. The membership believes that the 16 minute 

taxi-in/taxi-out time which was cited in EPA’s TSD on page 4, in accordance 

with EPA’s Procedures for Emission Inventory Preparation, Volume IV: 

Mobile Sources, 1992 is overestimated. AAAE membership stated that their 

figures would be approximately half of this (8 minutes). 

Response: EPA has elected to maintain airport lead inventories relevant to 

individual years of activity so that sources can be compared across categories 

within the National Emissions Inventory. In response to comments we are 

using a more recent year of activity data (e.g., 2008) in this final action which 
235 

reflects the decrease in activity of the general aviation fleet observed since 

2002. In evaluating the fraction of piston-engine activity at airports that may 

be subject to lead monitoring requirements EPA has acquired airport-specific 

information as described in the memo to the Pb NAAQS docket titled 'Selection 

of Airports for the Airport Monitoring Study.' Individual airport reporting 

time-in-mode data for piston-engine aircraft agree well with the national 

defaults we are using. EPA is continuing to accept additional airport-specific 

information. The methods we are using as well as contacts for additional 

questions and information are provided in the document titled 'Calculating 

Piston-Engine Aircraft Airport Inventories for Lead and Other Criteria 

Pollutants for the 2008 National Emissions Inventory' available at: 

http://www.epa.gov/ttn/chief/net/2008inventory.html. 

Comment ID: OAR-2006-0735-5955 

Name: Leslie Riegle 

Organization: American Association of Airport Executives (AAAE) 

Comment: The concern about the Santa Monica study is that it is just that; 

merely one study. Again, airports are greatly varied entities, and this limited 

study should not be generalized to the entire population of GA airports. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5946 

Name: Arthur N. Marin 

Organization: Northeast States for Coordinated Air Use Management 

(NESCAUM) 

Comment: NESCAUM agrees with the EPA proposal to change the lead 

emission threshold at which agencies are required to conduct lead monitoring 

for National Ambient Air Quality Standard (NAAQS) purposes near a source 

from 1.0 to 0.50 tons per year (tpy) (74 FR 69051). However, NESCAUM 

believes that this threshold, while appropriate for traditional lead sources as 

noted at 74 FR 69052 (e.g., lead smelters, metallurgical operations, battery 

manufacturing), is not appropriate for NAAQS monitoring purposes at general 

aviation airports. The airport study cited by EPA in the Federal Register (74 FR 

69054) does not support the need for lowering the monitoring threshold for 

general aviation airports. That study indicates that neither the Santa Monica nor 

the Van Nuys airports showed lead concentrations higher than the Los Angeles 

basin average of 0.018 μg/m3 at sites beyond the airport property. We strongly 

recommend that the monitoring threshold for general aviation airport lead 

monitoring remain at 1.0 tpy. Based on the draft 2008 National Emissions 
236 

Inventory,1 this threshold would require monitoring at the eight largest general 

aviation airports (i.e., in California, Florida, Colorado, New York, Oklahoma, 

and Arizona). Based on these data, EPA can reassess the need for additional 

lead monitoring at smaller general aviation airports in a future rulemaking. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5957 

Name: Chris Kunze 

Organization: The City of Long Beach Airport Department 

Comment: We support EPA's efforts to reasonably deal with lead (Pb) 

emissions, including those attributed to general aviation piston aircraft. We also 

feel that the effort should be based on accurate information and assumptions, 

and that the efforts should be responsible in terms of health impact assessment 

and economic realities. Upon reading the EPA's Notice of Proposed 

Rulemaking (NPRM) and its Technical Support Document, it appears as 

though a different approach based on current information and state-of-the-art 

emission generation/dispersion modeling would provide accurate information, 

without the need to implement costly and time consuming Pb air quality 

monitoring at 55 listed airports. This is especially true given the fact that lead 

emissions attributed to general aviation (GA) activity appears to be on the long 

term decline, and that aircraft manufacturers and other involved user groups 

appear to be willing to work with EPA and other federal agencies toward 

reasonable solutions. This different approach would involve the EPA 

continuing to identify lead emissions through state-of-the-art modeling, current 

operations data from high activity airports, and collection of other site specific 

readily available information which would add to the accuracy of area-specific 

emission estimates. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6064 

Name: Myra C. Reece 

Organization: South Carolina Department of Health and Environmental 

Control 

Comment: The department strongly questions EPA's conclusion in section iv of 

the preamble and disagrees that lead emissions related to the use of leaded 

aviation fuel during landing and takeoff (LTO) activity should be treated the 

same as an industrial lead source. The nature of the emissions - sporadic, at 

different rates, locations and altitudes, with mixing enhanced by the propulsion 

and movement of the individual sources and distributed over three dimensions 
237 

in a relatively large volume - is unlike any other potential course. The 

calculation provided to support the contention, unlike the universe of data 

mined for the estimate of facility impacts is based on one example which may 

or may not be representative of impacts related to general aviation activity. 

There is no evidence that an equivalent search of the monitoring data available 

in EPA's AQS (or other sources) for lead monitors in the vicinity of general 

aviation activity was conducted. It appears that EPA is requiring nation-wide 

ambient monitoring based on one very limited study at an airport in California 

rather than conducting intensive research utilizing the many opportunities that 

it has available to do this. The inclusion of general aviation facilities as sources 

that require monitoring or waivers incurs significant additional costs on stats 

and local air agencies for data collection and analysis, inventory improvement 

and quality assurance evaluation, modeling, monitoring and reporting for not 

only the fifty-five airports identified, but for all airports that may approach the 

threshold. The Department does not believe there is sufficient data available to 

justify the treatment of airports in the same manner as industrial sources. One 

example (a single study in Santa Monica, CA airport citing concentrations at 

the runway blast fence) is insufficient. It is inappropriate to treat the limited 

available resources when there are a significant number of identified and well 

characterized sources that more clearly need the new monitoring. Airports are 

different and those differences need to be better understood before broad 

application of a threshold developed from industrial source/monitor pairs is 

applied. Furthermore, if violation were to occur, resolving general aviation 

operation impacts on areas in close proximity to airports would require 

federally-driven changes, not the implementation of local controls. Minimizing 

meaningless SIP obligations will reduce unnecessary resource demands on our 

agencies and will allow the focus to be on emissions reductions that will allow 

areas to quickly achieve the 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5957 

Name: Chris Kunze 

Organization: The City of Long Beach Airport Department 

Comment: Airport "site specifics", rather than just "number of operations", are 

relevant to any emissions impact assessment. For LGB as an example, GA 

aircraft, depending on meteorological conditions and airport business 

origin/destination location, have 10 runway direction choices (either direction 

on 5 different runways). This reality creates a much different dispersion of any 

aircraft emission than that which would be the case at a single runway airport. 

For example, LGB's two most commonly used GA runways are separated by 

nearly 3,000 feet, resulting in a much greater dispersion of emissions, which 

can and should be reflected in impact modeling. As an example of site specific 

factors, the City of Long Beach certified an EIR/HHRA (Human Health Risk 
238 

Assessment) in June of 2007, based on newer 2005 baseline data and site 

geography than that currently used by EPA. We used EDMS modeling (used by 

EPA and FAA), which concluded that no areas around LGB showed Pb 

exposure in excess of NAAQs standards. This is consistent with local 

SCAQMD-monitored air quality, including a monitor approximately 1 mile 

from the Airport, which showed NO exceedence of federal or State standards 

for Pb over a monitoring period of 1995 - 2004. The HHRA also determined 

that multiple pathway sources (such as soil) "are unlikely to represent a 

significant human health risk". This was supplemented by 2006 on-Airport soil 

studies which indicated that the lead content was below California Total 

Threshold Limit Concentrations and Soluble Threshold Limit Concentrations, 

and below California Human Health Screening Levels for Residential Land 

Use. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5957 

Name: Chris Kunze 

Organization: The City of Long Beach Airport Department 

Comment: We agree with EPA's Technical Support Document, which 

recommends more recent data, and use of multiple vs. single year data, due to 

industry/airport dynamics, and also agree with its suggestion that local 

authorities might be able to provide more accurate "times-in-mode". For 

example, the 16 minute taxi to/from time-in-mode used by EPA is likely twice 

the actual time in taxi mode at LGB, based on the multiple runways and 

location of origin/destination on-Airport locations. 4) Any advanced modeling 

to determine air quality impacts of GA should give consideration to dispersion 

and receptor locations. For example, airports have sensitive receptors at 

different locations - some close, some not. Runway length is also a factor, with 

longer runways allowing for higher approach/departure altitudes over sensitive 

receptors than would short runways. Ambient wind speed/direction, humidity, 

and temperatures in some cases would be relevant to accurate, site specific 

modeling. Reference was made to EPA Pb monitoring at Santa Monica Airport, 

however it is our understanding that the results showed no actionable levels 

outside of the Airport's boundaries, for this one runway airport located adjacent 

to major freeways (which can also create background readings for many air 

quality constituents). 5) Other modeling updates for EPA's consideration would 

be assumptions regarding GA activity categorization, between piston and 

turbo-prop/turbo-jet aircraft. It is our understanding that current usage is more 

dispersed towards turbo-prop/turbo-jet than the 72% piston engine allocation 

made in the EPA modeling. Again, more current data acquisition would provide 

more realistic modeling and impact assessment. 

Response: Responded to in preamble. 
239 

Comment ID: OAR-2006-0735-5957 

Name: Chris Kunze 

Organization: The City of Long Beach Airport Department 

Comment: Based on the above observations, we do not believe that a mandate 

to actually monitor Pb emissions at the 55 listed airports is appropriate at this 

time, and that EPA use of current information and updated air quality modeling 

protocols would provide useable information for determining responsible 

policy and regulatory actions. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5963 

Name: James L. Kavanaugh 

Organization: Missouri Department of Natural Resources (MODNR) 

Comment: Spirit of St. Louis Airport in Chesterfield, Missouri (near St. Louis) 

has been identified in EPA's analysis (U.S . Environmental Protection Agency 

(2008), Lead Emissions from the Use of Leaded Aviation Gasoline in the 

United States, EPAa20-R-08-020) as the airport in Missouri with the highest 

estimated lead emissions, slightly less than 0.5 tpy. We have reviewed 

information on operations at this airport, including type of aircraft, fuel sales, 

and landing/takeoff (LTO) data and have found that the percentage of aircraft 

using leaded fuel is considerably lower than assumed in EPA's analysis where 

72% of LTOs used LL100 fuel. The overall total fuel sales at the airport from 

2002-06 illustrate a 5.6°lo maximum percentage of aviation gasoline (Avgas or 

LL100) sold. Along with the maximum landing and takeoff data in the last six 

years for general aviation and air taxi (160,341 in 2004), estimated lead 

emissions from operations at this facility are 0~07 tpy. The calculation 

provided below is based on EPA's Lead Emissions from the Use of Leaded 

Aviation Gasoline in the United States: Technical Support Document. 160,341 

Total LTO * (0.056 Avgas LTO/ Total LT0) * 7.34 lb Pb / Avgas LTO '" (0.95 

lb Pb emitted / lb Pb in Avgas) / (1000 g / kg) = 62.61 kg Pb/year = 0.07 Tons 

Pb/year This result suggests that lead monitoring at airports in Missouri would 

produce extremely limited benefit when compared to other sources of lead in 

Missouri. 

Response: Monitoring agencies are encouraged to use the most recent and 

accurate estimates of Pb emissions when determining the applicability of these 

monitoring requirements. 
240 

Comment ID: OAR-2006-0735-6025 

Name: Michael Villegas 

Organization: Ventura County Air Pollution Control District (VCAPCD) 

Comment: EPA's proposed revisions to appendix D to Part 58 do not provide 

for a similar mechanism to demonstrate that actual emissions from airports are 

less than 0.50 tpy. EPA should provide state and local monitoring agencies with 

a mechanism similar to proposed paragraph 4.5(a) (ii), for such a 

demonstration. 

Response: Duplicate comment. 

Comment ID: OAR-2006-0735-6025 

Name: Michael Villegas 

Organization: Ventura County Air Pollution Control District (VCAPCD) 

Comment: EPA's proposed revisions to Appendix D to Part 58 do not provide a 

mechanism to demonstrate that actual emissions from airports are less than 0.50 

tpy. EPA should provide state and local agencies with a mechanism similar to 

proposed paragraph 4.5(a) (ii), for such a demonstration. 

Response: The monitoring requirements do identify that the emission estimate 

should be based on "either the most recent National Emission Inventory ( 

http://www.epa.gov/ttn/chief/eiinformation.html ) or other scientifically 

justifiable methods and data (such as improved emissions factors or 

site-specific data)." EPA has worked with the monitoring agencies directly and 

through guidance to inform them that they do not need to seek a waiver if they 

can demonstrate, to the Regional Administrators satisfaction, that improved 

emission estimates indicate emissions are less than 0.50 tpy. In these cases, 

monitoring agencies need only document the improved emission estimates in 

their monitoring plans (which are subject to Regional Administrator approval). 

Comment ID: OAR-2006-0735-6025 

Name: Michael Villegas 

Organization: Ventura County Air Pollution Control District (VCAPCD) 

Comment: VCAPCD has reviewed the 2002 and 2005 NEI and found that it is 

not suitable to accurately determine lead emissions from airports in Ventura 

County. In our case, the NEI lead emissions from airports are on an aggregated 

county-wide basis. Aircraft activity at our largest airport (potentially subject to 

monitoring) has decreased steadily from 197,911 operations in 2002 to 153,233 

operations in 2008. VCAPCD staff has calculated lead emissions from piston 
241 

driven aircraft from each of our airports; for 2008 we have determined that the 

lead emissions from Ventura County airports are substantially less that 

emissions in the NEI. Our calculations demonstrate that the one airport 

identified in EPA's technical support document - Camarillo Airport - as 

emitting more than 0.5 tpy emits approximately 0.34 tpy, based upon 2008 

aircraft activity . VCAPCD staff used FAA operations data for Camarillo 

Airport, with airport-specific aircraft population based on the proportion of 

based aircraft from FAA form 5 010 -1 Airport Master Records to determine 

operations by general aircraft category (piston single engine, piston twin 

engine, helicopter, turboprop and jet aircraft) . Aircraft operations were 

distributed to specific aircraft models based on information from the Ventura 

County deputy director of airports. Piston single engine operations are further 

distinguished between full Landing and Take-Off cycles (LTOs) consisting of 

all five operational modes (75% of operations) and Touch and Go cycles 

(TGOs) without a taxi/idle mode associated with landing/takeoff practice at the 

flight schools (25% of operations), as suggested by a local airport association. 

Aircraft operations and airport-specific time-in-mode operating profiles based 

on the local mixing height instead of the national default were used in FAA 

EDMS model version 5.1 to develop our own estimate of 2007 emissions and 

fuel consumption by aircraft operating mode. Aviation gasoline consumption 

for piston aircraft was used to estimate lead (Pb) emissions. A similar process 

was used for 2008 using EDMS model version 5 .1 .2 . This methodology is 

consistent with EPA's recent guidance for calculating aircraft emissions . 

VCAPCD has recently provided data to EPA documenting Ventura County's 

2008 lead emissions from our local airports . Furthermore, we understand that 

EPA is currently updating the emission inventory for aircraft emissions . 

Response: Monitoring agencies are encouraged to use the most accurate and 

current emissions estimates when determining the applicability of the Pb 

monitoring requirements. 

Comment ID: OAR-2006-0735-5956 

Name: Mark R. Vickery 

Organization: Texas Commission on Environmental Quality (TCEQ) 

Comment: Monitoring Near Airports The analysis presented in the proposed 

rule for establishing a lead emissions threshold for ambient air monitoring for 

airports is inappropriate because children do not have practical access to soil or 

interior surfaces as close to the piston engine run-up, hold-short, and take-off 

areas of a taxiway—runway pair as the monitor near the blast fence has at the 

Santa Monica airport (East Tarmac Site #3, proposed rule reference: Fine, 

Philip (2007)). Having children riding in aircraft taxiing, landing, or taking off 

from an airport does not present the practical possibility of significant lead 

exposure from lead deposited in soil on the airport property. For airports 

without practical access to areas closer than the distance of the Residence Site 
242 

#2 from the end of the runway and the piston engine run-up and hold—short 

areas of a runway, it would be appropriate to use the data from Residence Site 

#2 to establish the annual lead emissions threshold for an airport. Using the 

methodology in the proposed rule, the three- month lead average at Residence 

Site #2 is close to 0.03 micrograms per cubic meter (pg/mg). Taking the ratio of 

the 0.03 ug/mg to the 0.15 pg/ms level of the standard demonstrates that the 

Santa Monica airport, which has 0.4 tons per year of lead emissions, would 

have to have approximately 2.0 tons per year of lead emissions to produce an 

ambient air lead concentration equal to the NAAQS at Residence Site #2. For 

this reason, it would be inappropriate to lower the annual lead emissions 

monitoring threshold at airports below l.0 tons of per year for any airport 

without practical access for children to an area within the distance of Residence 

Site #2 to the run-up, hold—short, and take-off areas of a taxiway- runway pair 

at the airport. Because of the lack of information on piston—engine aircraft 

landing and take-off operations at some airports, it would be helpful if the EPA 

developed a methodology for using the annual amount of leaded aviation 

gasoline sales at an airport to calculate the annual lead emissions from the 

airport. An alternative would be to develop a methodology for using the ratio of 

the leaded aviation gasoline to turbine engine fuel sold at an airport together 

with the total number of landings and take-off operations at the airport to 

calculate the annual lead emissions from the airport. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5943 

Name: Barbara Kwetz 

Organization: Massachusetts Department of Environmental Protection 

(MassDEP) 

Comment: MassDEP has submitted the calculations comparing EPA's 

assumptions and MA actual activity data, along with the supporting 

documentation of GA/AQ operations and piston engine fraction, to EPA staff 

and has requested that the activity data and lead emissions in EPA's 2008 NEI 

database be revised to reflect the MAQ actual airport data. Since the MassDEP 

lead emission estimates for these airports are below the 0.50 tpy, MassDEP also 

has requested that these MA airports be removed from EPA's list of airports that 

exceed the proposed 0.5 tpy lead emissions threshold for source-oriented 

monitoring. 

Response: The EPA appreciates the additional information provided and has 

updated our emission estimates accordingly. However, we do note that the 

information provided on one airport indicates that the twin engine usage at that 

airport is much greater than that assumed in the default calculations. When this 

new information is used (in addition to the other information provided for this 

airport) we estimate that the emissions from that airport are above 0.50 tpy. 
243 

Comment ID: OAR-2006-0735-5942 

Name: B. Keith Overcash 

Organization: North Carolina Department of Environment and Natural 

Resources (NCDENR) 

Comment: NCDAQ believes that EPA should address the lead emissions from 

airports by adopting fuel standards that eliminate lead on an appropriate 

timetable. Otherwise, if a state monitors a violation at an airport, the state has 

limited authority to require emissions reductions. Therefore, a national 

approach is needed to reduce the lead emissions from airports. If the EPA finds 

it necessary to monitor for lead at airports, the NCDAQ supports the 

recommendation by the NACAA that the EPA develop a small short-term 

airport monitoring study of 10 to 20 general aviation airports emitting more 

than 0.5 tpy prior to the deployment of a full airport monitoring program. The 

State and local agencies need more guidance on how to determine sound 

monitor siting criteria as well as to evaluate what the threshold for lead 

emissions should be at airports. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6100 

Name: David J. Shaw 

Organization: New York State Department of Environmental Conservation 

(NYSDEC) 

Comment: The Department does not agree with the proposal to require lead 

monitoring at general aviation airports that are estimated to have lead emissions 

of less than 1.0 ton per year. Other airport monitoring studies not mentioned in 

this proposal have not found significant lead emissions in the communities 

surrounding the facilities. Since it is possible that the largest general aviation 

airports do emit enough lead to be a concern, the EPA should require 

monitoring for general aviation airports that emit more than 1.0 tpy lead. It is 

important to remember that airport emissions are not from a single emission 

point but along a line as planes take off and land. Emissions are further 

dispersed by the propellers. The maximum ground level concentration from this 

scenario will be lower than would happen if the same emissions were emitted 

from a stack. New York believes that choosing a higher threshold will result in 

monitoring at enough airports to determine whether or not general aviation 

airports cause elevated lead concentrations in neighboring communities. The 

EPA does not have enough information to justify monitoring at airports with 

emissions over 0.5 tpy. Since it may be that the largest general aviation sources 

could have an impact on neighborhood emissions, the EPA should require lead 
244 

monitoring for general aviation airports with annual lead emissions over 1.0 

tpy. This higher threshold will provide the necessary monitoring data that will 

be used to determine if the largest general aviation airports are significant 

sources of lead. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5944 

Name: Dick Valentinetti 

Organization: National Association of Clean Air Agencies (NACAA) 

Comment: Due to the limited number of studies that have evaluated ambient 

lead sampling methodologies and concentrations from airports, which EPA 

notes in its proposal,3 NACAA strongly urges EPA develop a small pilot 

airport monitoring study of general aviation airports emitting more than 1 tpy of 

lead prior to the deployment of a full airport monitoring program. This is 

necessary in order to determine sound sampling siting criteria and evaluate 

whether the 0.5 tpy threshold should be applicable to airports. Working with 

NACAA, lessons learned in the smaller, more focused networks could be used 

to build a more cost effective, scientifically sound national airport monitoring 

network. Requirements for lead monitoring near smaller airports should take 

effect two years after the promulgation of the final rule. This would allow 

sufficient time to evaluate pilot monitoring projects and determine the best way 

to address ambient lead concentrations near airports. 

Response: Responded to in preamble. 
245 

Comments on Non-Source-Oriented Monitoring 

Comment ID: OAR-2006-0735-5951 

Name: Avinash Kar 

Organization: Natural Resources Defense Council (NRDC) et al. 

Comment: However, the inclusion of lead monitoring in the NCore network 

does not sufficiently address all of the original objectives of the 

population-based monitoring that EPA seeks to replace with the proposal on the 

NCore network. EPA required population-based monitoring to achieve three 

objectives: 1) to measure neighborhood scale lead concentrations in urban areas 

impacted by resuspended dust from non-inventoried sources such as roadways, 

closed industrial sources which previously were significant sources of lead, 

hazardous waste sites, construction and demolition projects, or other fugitive 

dust sources of lead; 2) to assist in determining nonattainment boundaries; and 

3) to help in better characterizing population exposure to ambient air related 

lead. 74 Fed. Reg. at 69055. EPA suggests in its proposal that the NCore 

network can help achieve these objectives and that of supporting the 

development of long-term trends at typical concentration sites. Id. at 69056. 

However, the NCore network is ill-equipped to achieve the first and second 

objectives. The spatial heterogeneity of current day and past emissions and lead 

contamination reservoirs in soils due to legacy pollution means that the these 

monitors will not be sufficient to capture all areas of elevated lead 

concentrations. In particular, the potential for re-suspension of lead 

contaminated soils to result in an ongoing public health threat will not be 

adequately addressed and monitored through the inclusion of lead in the NCore 

monitoring network because the NCore network monitoring locations To 

Protect Public Health With an Adequate Margin of Safety, EPA Should Revise 

the Proposed Language at Subsection 4.5(a) to 40 C.F.R. Part 58, Appendix D 

to Provide More Guidance to States on the Kinds of Sources Which Are 

Expected to Or Have Been Shown to Contribute to” NAAQS Violations. The 

re-suspension of lead contaminated soils has been found in multiple studies to 

be a major contributor to airborne lead concentrations. Moreover, higher 

airborne lead concentrations were measured near areas impacted by historic 

lead pollution such as near roadways and previous industrial activities. 9 10 11 

The proposed rule recognizes the potential threat posed by these sources and 

refers to them as non-inventoried sources,” stating that “[s]ome sources of lead 

which are not in the current NEI that could result in ambient lead concentrations 

in excess of the lead NAAQS have been identified. 74 Fed. Reg. at 69055. 

Research, such as the study conducted by Young et al. (2002), where 

contaminated soils were analyzed for their potential to contribute to airborne 

lead concentrations have demonstrated the potential for these areas to result in 

concentrations that could exceed the NAAQS.12 However, the proposed 

monitoring rule is not sufficient to ensure that monitoring of these sites is 

included in state monitoring plans. The monitoring rule should be revised to 
246 

provide specific guidance to states on the development of monitoring plans that 

include non- inventoried sources such as areas heavily impacted by historic 

lead emissions. Community level studies have demonstrated that these areas 

include those near roadways that received heavy traffic before the phase out of 

leaded gasoline and closed industrial facilities. Guidance could require for 

instance the review of relevant databases (such as those listing superfund and 

brownfield sites or other assessments of contaminated sites) and studies 

(including academic and community level surveys) to identify those areas with 

documented lead contamination, and particular vigilance for sites likely to pose 

a thread of airborne lead 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5942 

Name: B. Keith Overcash 

Organization: North Carolina Department of Environment and Natural 

Resources (NCDENR) 

Comment: NCDAQ supports requiring lead monitoring at NCore sites rather 

than the separate non-source-oriented monitoring locations. Using the NCore 

sites provides efficient use of EPA and state resources and provides data on 

background levels of lead most cost effectively. In requiring lead monitoring at 

NCore sites, the EPA should also allow flexibility so that agencies with 

multiple monitoring sites in an MSA could have an option us using a site in the 

MSA other than the NCore site for lead monitoring if it was more suitable site 

for lead monitoring or it allowed agencies to use their resources more 

effectively. With regards to establishing a population threshold for requiring 

lead monitoring at NCore sites, the EPA should only consider requiring all 

NCore sties to monitor for lead if the EPA can afford to pay for the lead 

monitoring at all NCore sites. In addition, the NCDAQ urges the EPA to 

evaluate the lead data obtained at the NCore sites after five years and provide a 

means to reduce lead monitoring at NCore sites, if the data supports it, back to 

the original NCore design plan of one lead monitor per region at the NCore site 

in the largest metropolitan area in the region. There are more pressing demands 

for our limited funding than maintaining lead monitors indefinitely that 

consistently measure levels that are less than 50 percent of the standard. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5951 

Name: Avinash Kar 
247 

Organization: Natural Resources Defense Council (NRDC) et al. 

Comment: EPA Should Require Lead Monitoring at All NCore Sites to Gather 

Data on Multi-Pollutant Exposures Across the Country, Including Lead, But 

Must Create Other Mechanisms to Meet the Other Objectives of 

Population-Based Monitoring and to Protect Public Health With an Adequate 

Margin of Safety. We support the inclusion of lead in the proposed NCore 

monitoring network because including lead in the network will provide 

valuable data on multi-pollutant exposures in cities and towns across the 

county. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5944 

Name: Dick Valentinetti 

Organization: National Association of Clean Air Agencies (NACAA) 

Comment: NACAA supports the agency’s proposal to conduct 

non-source-oriented lead monitoring using the NCore network. The 

Association recommends that EPA require monitoring only at NCore sites 

located in larger urban areas, i.e., CBSAs with a population greater than 

500,000. Doing so would allow states to use their limited resources to focus 

non-source-oriented monitoring and control strategies in the most sensitive 

areas. In addition to using the NCore network, EPA should consider 

supplementing non-source oriented monitoring of lead by incorporating data 

from other federal programs that conduct lead sampling. For example, both the 

National Air Toxics Trends Stations (NATTS) and Chemical Speciation 

Network (CSN) collect samples that are analyzed for lead; however the lead 

sampling data extracted does not utilize a Federal Reference Method (FRM) or 

Federal Equivalent Method (FEM) for lead. State and local agencies should be 

permitted to use NATTS and CSN data for attainment designations in the event 

that the data show concentrations less than 80% of the NAAQS and the relevant 

NCore site is unaffected by nearby sources. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5946 

Name: Arthur N. Marin 

Organization: Northeast States for Coordinated Air Use Management 

(NESCAUM) 
248 

Comment: The NESCAUM states urge EPA to exclude rural NCore sites from 

its proposal to require lead monitoring at all NCore sites (74 FR 69055). The 

proposed inclusion of the rural sites is inconsistent with the monitoring goal 

and would be a waste of state resources. To better address EPA’s intended goal 

for the monitoring network, we recommend that the siting of urban 

community-scale lead monitoring not be constrained to NCore sites, but be 

allowed to be located at other appropriate monitoring sites such as National Air 

Toxics Trend Stations (NATTS), which tend to be sited in “hot-spot” areas for 

other pollutants. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5963 

Name: James L. Kavanaugh 

Organization: Missouri Department of Natural Resources (MODNR) 

Comment: We support the use of NCore sites for long-term monitoring of 

airborne lead concentrations, especially in urban environments. However, we 

suggest that, for this purpose, high volume PM10 sampling with analysis by 

inductively coupled plasma/mass spectrometry (ICP/MS) should be approved 

as an appropriate method in addition to low volume P1VI10 sampling or high 

volume total suspended particulate sampling. Specifically, the Blair Street 

station in St. Louis has been designated as an NCore site. Lead (and other 

metallic species) concentrations have been measured at that site by high volume 

PM 10 with ICP/MS analysis for several years as a part of the National Air 

Toxics Trends Sites (NATTS) program, and these measurements are expected 

to continue. There is no technical reason why that measurement cannot 

continue to provide, data on long-term trends in urban ambient lead 

concentrations in that area and fulfill the requirements of the NCore program as 

well as of the NATTS program. 

Response: Currently, there are no high-volume PM10 samplers approved as 

either an FRM or FEM for Pb sampling. EPA does not currently have any plans 

to pursue the development of an approved FRM or FEM for high-volume PM10 

Pb sampling. However, monitoring agencies may seek the approval of an FEM 

under the provisions outlined in 40 CFR part 53 Subpart A. 

Comment ID: OAR-2006-0735-6066 

Name: N. S. Rapp 

Organization: 
249 

Comment: EPA's proposal to rely on the Wore network for non-source-oriented 

lead NAAQS monitoring should be supplemented with additional monitors 

sited specifically to measure ambient lead levels in urban areas. Because the 

NCore monitoring locations are not chosen on the basis of potential lead 

exposure, the network is unlikely to adequately characterize historic lead 

contamination that can be resuspended in urban areas. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5964 

Name: James Brook 

Organization: Maine Department of Environmental Protection (ME DEP) 

Comment: Maine supports lowering the source-oriented monitoring threshold 

and revising the non-source oriented requirements to include an option of 

monitoring at NCore sites . However, we believe the option should exist for 

states to monitor at NCore sites that are located in larger urban areas, i.e. 

CBSA's with a population greater than 500,000 but not at all NCore sites. The 

requirement to monitor at all NCore sites places a greater burden on those states 

that have rural NCore sites and are likely to have extremely low concentrations 

which may result in a lot of nondetects. If these sites are the only required 

monitors in rural states than they are also required to conduct collocated 

monitoring at that location which will result in precision data that may not be 

useful in precision calculations because of the very low concentrations . This 

effort would be a waste of state resources . We would prefer to see the 

monitoring location requirement be left up to the states and EPA regional 

offices to determine whether a CBSA based or NCore option be implemented . 

Maine would also encourage EPA to consider other lead data that is being 

collected by federal programs and review some of those programs to ensure that 

the data is being collected to meet the current EPA requirements. The 

IMPROVE program collects lead data at a lot of the rural sites around the 

country but the current methods do not always follow the current requirements 

for lead data collection and analysis. EPA should consider reviewing some of 

those program requirements and incorporate changes so that the data collected 

can be used to determine compliance with the NAAQS . 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5930 

Name: Judith Zwicker 
250 

Organization: JZ Consulting 

Comment: EPA's proposal to rely on the NCore network for 

non-source-oriented lead NAAQS monitoring should be supplemented with 

additional monitors sited specifically to measure ambient lead levels in urban 

areas. Because the NCore monitoring locations are not chosen on the basis of 

potential lead exposure, the network is unlikely to adequately characterize 

historic lead contamination that can be resuspended in urban areas. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6100 

Name: David J. Shaw 

Organization: New York State Department of Environmental Conservation 

(NYSDEC) 

Comment: In many CBSAs the tentatively approved NCore monitoring 

location is probably well suited for this objective. In other CBSAs, however, 

there may be additional factors that would make another location better in that it 

would serve an equally large population but it may be in an area that is expected 

to have higher ambient lead concentrations. For instance, in New York City, the 

urban National Air Toxics Trends (NATTs) site is located in an area that is 

likely to have higher lead concentrations than the tentatively approved NCore 

site. The EPA Regional office should have the latitude to approve alternate sites 

if there is evidence that another location is better suited. There is no need to 

require lead monitoring at the rural NCore monitors. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5926 

Name: John H. Melby, Jr. 

Organization: Bureau of Air Management, Wisconsin Department of Natural 

Resources 

Comment: The Department supports the removal of population-oriented 

monitoring, as proposed in the original rule. Examination of existing air toxics 

monitoring suggests that population-oriented monitoring in Milwaukee and 

Madison, Wisconsin’s largest urban areas is unnecessary (See Figure 1). 

Wisconsin supports population-oriented sites located at urban NCore locations 

to protect public health. The Department objects to requiring monitoring at 

rural NCore sites. We question whether the costs to operate the monitor 
251 

outweigh the benefits of monitoring at rural NCore sites, where concentrations 

will be extremely low. See the data for Mayville in Figure 1, Wisconsin’s rural 

NCore site through 2009. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5941 

Name: Catharine Fitzsimmons 

Organization: Iowa Department of Natural Resources (IDNR) 

Comment: EPA should require lead monitoring at all NCore monitoring sites. 

States should be encouraged to expand the suite of metals analyized from this 

analysis to include other toxic metals such as manganese. 

Response: Responded to in preamble. 

 
252 

Comments on Monitoring Deployment Schedule 

Comment ID: OAR-2006-0735-5946 

Name: Arthur N. Marin 

Organization: Northeast States for Coordinated Air Use Management 

(NESCAUM) 

Comment: It is critical that EPA recognize that the delay in issuing this NPR, 

and the consequent delay in finalizing this rule until late spring 2010, makes it 

impractical for states to include the new monitoring requirements in their 

network plans, which are due June 30, 2010. This delay also makes it unlikely if 

not impossible for states to implement the additional monitoring requirements 

by the December 30, 2010 deadline. States are experiencing significant staff 

cuts and resource constraints in the face of mounting new federal monitoring 

and other requirements related to multiple NAAQS revisions. EPA must find a 

workable and practical solution that allows adequate time for states to comply 

with new monitoring requirements, including additional time for 

implementation, using existing networks as appropriate, and providing 

technical and financial assistance. Given the expanded role that EPA is 

envisioning for the various monitoring networks and its desire for research data 

to augment future regulatory decisions, we urge EPA to engage in higher level 

strategic discussions with the states on these issues. Such discussions could 

result in recommendations on how to more efficiently deploy and use 

monitoring networks. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5956 

Name: Mark R. Vickery 

Organization: Texas Commission on Environmental Quality (TCEQ) 

Comment: Timeline for Deploying New Monitors A one—year timeline for 

deploying monitors to NCore sites is reasonable for NCore sites that are already 

established, If new equipment procurement is involved, a deadline shorter than 

one year after federal funding is provided is not reasonable for NCore sites, For 

point-source oriented ambient air lead monitors, a one-year deadline for 

installation is not reasonable. Obtaining a model-ready emissions inventory for 

each plant, performing dispersion modeling to determine the area of maximum 

ambient air impact, procuring new monitoring equipment, obtaining EPA 

regional office approval of each site, and negotiating a site use agreement, 

contracting site preparation, and obtaining electrical service can each require 

more time than expected. An l8—month timeline would be more reasonable. lf 
253 

a monitor for an airport needs to be sited on the airport, there is another 

complication. Federal Aviation Administration approval of a new installation 

on an airport can add six months or more to the process of establishing a site. In 

addition, the data gathering for emissions modeling for airports may require 

additional months of work, so a more appropriate timeline for airport impact 

monitors would be 20—to—24 months. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5953 

Name: Sandra F. Veazey 

Organization: Florida Department of Environmental Protection 

Comment: The requirements mentioned above which would mandate the 

completion of the plan for lead monitoring by June 30, 2010 which is, oddly, 

one day before the annual monitoring plan for all other pollutants is due. It also 

would only leave 2 weeks to complete the plan after the rule is effective, 

assuming that could be the case just 90 days after comments are due. This time 

is insufficient for effective planning. Additionally, the requirement to have the 

source monitoring operational due date set to be December 30. 2010 is 

insufficient for the amount of work associated with this proposal. 

Response: We regret that an error was created when the Federal Register 

printed the proposed rule. The preamble correctly indicated the correct dates (6 

months following the publication of the final rule for the plan, and 1 year from 

the date of the final rule for monitors to begin operation). However, dates were 

inserted into the regulatory text based off the date of the proposed rule, not the 

date of the final rule. 

Comment ID: OAR-2006-0735-5941 

Name: Catharine Fitzsimmons 

Organization: Iowa Department of Natural Resources (IDNR) 

Comment: Any new source-oriented monitors required under the provisions of 

this rule should be installed over a two year period, with the first tier of 

source-oriented monitors operational by January of 2012, and the second tier of 

monitors by January 2013. This will allow States adequate time to refine 

emissions estimates by use of stack tests, to model the refined estimates, and to 

attempt to locate monitoring sites in the "hot spots" indentified by the 

modeling. 
254 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6025 

Name: Michael Villegas 

Organization: Ventura County Air Pollution Control District (VCAPCD) 

Comment: It is likely that source-oriented lead monitoring sites will be new 

monitoring sites, not operated at existing SLAMS sites. We note that the 

current rule allowed a period of over seven months, from the date of the rule's 

final issuance, to submit a network plan for establishing source-oriented lead 

monitoring sites for sources emitting greater than 1 .0 tpy. EPA's current 

proposal provides 6 months from the date comments were requested on the 

proposed rule in which to develop and submit a network monitoring plan that 

identifies the location of source-oriented lead monitoring sites. 

Response: This final rule allows for 6 months from the date the final revisions 

are published to submit their plan, and 1 year to begin operation of newly 

required sites. 

Comment ID: OAR-2006-0735-6064 

Name: Myra C. Reece 

Organization: South Carolina Department of Health and Environmental 

Control 

Comment: In addition, the department has noticed an inconsistency between 

the proposed language for 40 CFR Part 58.10 and the language in the preamble 

concerning submission of the amended plan and establishment of 

source-oriented samplers near stationary sources with annual emissions 

between 0.5 and 1.0 tpy of lead. 

Response: We regret that an error was created when the Federal Register 

printed the proposed rule. The preamble correctly indicated the correct dates (6 

months following the publication of the final rule for the plan, and 1 year from 

the date of the final rule for monitors to begin operation). However, dates were 

inserted into the regulatory text based off the date of the proposed rule, not the 

date of the final rule. 

Comment ID: OAR-2006-0735-5944 
255 

Name: Dick Valentinetti 

Organization: National Association of Clean Air Agencies (NACAA) 

Comment: NACAA recommends the alternative option, which would give state 

and local agencies adequate time to adjust their resources and ensure that new 

monitors are properly sited and supported. This phased approach would ease 

the burden of finding and developing sites, as state and local agencies are 

already under pressure to develop other networks such as ozone, NO2, and 

SO2. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5950 

Name: Laurel L. Kroack 

Organization: Illinois Environmental Protection Agency 

Comment: EPA Should Require Installation of New Source-Oriented Monitors 

for Sites Between 0.5 and 1 ton per year Over Two Years Rather than One. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5942 

Name: B. Keith Overcash 

Organization: North Carolina Department of Environment and Natural 

Resources (NCDENR) 

Comment: The NCDAQ urges the EPA to reconsider its timeline for deploying 

new source-oriented monitors for sources emitting between 0.50 and 1.0 tpy. It 

is inefficient and hence more costly to have agencies amend their monitoring 

plans in the middle of the cycle. States should be required to include the new 

lead monitoring requirements in the monitoring plans that are due after the rule 

becomes effective and no sooner than July 1, 2011, and start up operation of the 

new monitors on January 1 of the year after the monitoring plan is submitted 

but not before January 1, 2012. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-6100 

Name: David J. Shaw 
256 

Organization: New York State Department of Environmental Conservation 

(NYSDEC) 

Comment: Due to the timing of the implementation regulation, monitoring 

agencies will need a full year to include the new lead monitors in the annual 

monitoring network plan. Monitoring Agencies are required to submit their 

annual monitoring network plans on July 1st each year. The schedule to include 

the lead monitors can only be accommodated if the final lead implementation 

plan is published at least four months before the submittal deadline for the 

annual network plan. It is likely that the final implementation plan will not be 

published until July 2010. This means that the earliest plan which will include 

the lead monitors would be submitted in 2011. The EPA may need to allow 

additional time for the deployment of the monitors for sources that emit 

between 0.5 and 1.0 tons of lead per year. Emission inventories that have been 

used to identify sources at levels from 1.0 to 0.50 tons of lead per year are 

highly suspect and would need to be verified prior to instituting any monitoring 

plan. Monitoring Agencies will be expected to install an estimated 140 new 

monitors at locations that are not likely to have established monitoring 

locations. Establishing new monitors as stand-alone single parameter 

monitoring sites is the most expensive and labor intensive way to establish a 

network. The EPA will need to provide adequate resources for the additional 

monitors and the Monitoring Agencies will need additional time to find suitable 

locations and to purchase and evaluate the new sampling equipment. Since 

Federal monitoring resources are distributed annually, it will take additional 

time after the Federal resources are received before Monitoring Agencies will 

be able to begin the operation of the new monitors. It is likely that in most 

monitoring jurisdictions, specific sources will be ranked as more likely to 

contribute to high ambient lead concentrations than others. It is appropriate to 

permit the Monitoring Agencies and the Regional EPA offices to discuss the 

priority by which monitors should be installed. It is likely that the sources that 

are lower on the priority list could be eligible for monitoring waivers so there 

would be no need to rush into installing monitors at low priority locations. The 

Department agrees that the sources that have the highest potential to contribute 

to significant lead concentrations in populated areas should have their monitors 

installed as soon as possible. The factors to be considered when prioritizing the 

list include the nature and potential quantity of the emission, the proximity and 

size of the local population, and the topography and the meteorology in the 

receptor area. The Department agrees that a 2 year deployment schedule with 

the airport monitoring staged in the second year is the preferable schedule. This 

additional time will permit the state and local agencies to verify the emissions 

data from the 

Response: Responded to in preamble. 
257 

Comment ID: OAR-2006-0735-5949 

Name: Teresa Marks 

Organization: Arkansas Department of Environmental Quality (ADEQ) 

Comment: Lowering the lead monitoring threshold from one ton per year 

(tpy) to 1⁄2 tpy will result in a significant increase in the state resources required 

to monitor additional locations that are not necessarily likely to violate the 

National Ambient Air Quality Standards (NAAQS). This is due to EPA’s use 

of “worst-case” assumptions as a basis for determining an appropriate 

threshold. ADEQ has sited a total of one point-source oriented monitor as a 

result of the current requirement to assess facilities that have reported actual 

emissions over the one ton per year requirement to assess facilities that have 

reported actual emissions over the one ton per year threshold. Point source 

modeling has been submitted in support of monitoring requirement waivers for 

several other potentially affected facilities. From this effort, it is apparent that 

most sources emitting less than one tpy of lead would be candidates for a 

waiver. A few facilities might not be able to meet the modeling waiver criteria 

but, due to; variability in the physical conditions at selected sites, the 

unreliability of comparing modeled outcomes to monitored results, etc. would 

not necessarily result in monitored violations. Since the monitoring waiver 

test is to show that modeled emissions do not result in an exceedence of half of 

the level the standard, there is already a low likelihood that new monitoring 

data would identify NAAQS violations. 

If EPA does lower the threshold to 1⁄2 tpy, ADEQ supports a staged deployment 

schedule as proposed by EPA. EPA should review any preliminary results from 

monitors deployed under the existing rule in an effort to determine whether its 

assumptions regarding the need for additional monitoring at facilities with 

lower emissions are validated. EPA should consider a longer deployment 

schedule that would be tied to the suggested review of newly acquired data 

from currently monitored sites. 

Response: The monitoring waiver provisions will also apply to emission 

sources emitting 0.50 tpy or greater but less than 1 tpy. If a monitoring agency 

can demonstrate that a facility will not cause Pb concentrations to equal or 

exceed 50% of the Pb NAAQS, they may request a monitoring waiver. As 

such, the only burden to states for those facilities will be the costs of performing 

the modeling and requesting the waiver. As discussed in the preamble to the 

final rule, we believe that some facilities emitting 0.50 tpy or greater may cause 

or contribute to an exceedence of the Pb NAAQS. However, we agree with the 

commenter that many facilities emitting emitting 0.50 tpy or greater but less 

than 1 tpy of Pb will likely be eligible for a monitoring waiver. 

 
258 

Comments on Other Aspects of Lead Monitoring 

Comment ID: OAR-2006-0735-5926 

Name: John H. Melby, Jr. 

Organization: Bureau of Air Management, Wisconsin Department of Natural 

Resources 

Comment: The Department encourages EPA to reconsider the use of high 

volume PM10 samplers for PM10-lead as is used in the NATTS program. 

Including this as an acceptable method leverages toxics monitoring data and 

maximizes use of resources. Technical notes from EPA staff mention that the 

specifications for these instruments are not as tight as the low volume samplers; 

however, when considered as an entire measurement system, the method has 

several attributes that balance its performance and this uses the same sampling 

technology as TSP-lead: 

Response: Currently, there are no high-volume PM10 samplers approved as 

either an FRM or FEM for Pb sampling. EPA does not currently have any plans 

to pursue the development of an approved FRM or FEM for high-volume PM10 

Pb sampling. However, monitoring agencies may seek the approval of an FEM 

under the provisions outlined in 40 CFR part 53 Subpart A. 

Comment ID: OAR-2006-0735-5926 

Name: John H. Melby, Jr. 

Organization: Bureau of Air Management, Wisconsin Department of Natural 

Resources 

Comment: The Department is concerned about the availability of adequate 

resources to implement and operate the proposed Lead monitoring network. 

EPA must provide states funding, not only to set up the additional sites required 

by this rule, but also to support operational costs. Wisconsin has a single 

source-oriented site, which is quite expensive to operate because it is a single 

pollutant site that is distant from other monitoring sites in our network and it 

requires a collocated monitor. The analytical costs alone will exceed 

$9000/year. Wisconsin will have great difficulty absorbing the operational 

costs in an already stretched budget for criteria pollutant monitoring. 

Response: EPA notes that fiscal year 2010 STAG funding has been made 

available for the purpose of supporting new lead monitoring equipment 

purchases related to this final rule. EPA also notes that additional 2011 STAG 

funding was proposed to support "core" programs which can include activities 
259 

such as ambient monitoring. EPA will work with the Regional Offices, 

NACAA, and monitoring agencies to develop a plan for allocating these funds 

to the new monitoring needs related to this final rule as well as recent NAAQS 

revisions. 

Comment ID: OAR-2006-0735-6404 

Name: D. and I . Reese 

Organization: 

Comment: "We all breathe the same air" 

Response: No response needed. 

Comment ID: OAR-2006-0735-5926 

Name: John H. Melby, Jr. 

Organization: Bureau of Air Management, Wisconsin Department of Natural 

Resources 

Comment: The Department questions EPA’s assumption that urban NCore sites 

are likely to have low volume PM10 monitors at these sites to support other 

monitoring requirements. Because of the costs associated with operating these 

more manual instruments and the associated costs of laboratory analysis, 

monitoring agencies will more likely operate automated instruments for fine 

and coarse particles at NCore sites that have the advantage of near real-time 

data reporting and lower operational costs. Incorporating this assumption into 

the cost estimates for lead may effectively discourage some monitoring 

organizations from moving toward more automated methods for PM2.5, PM10, 

and PMCoarse. 

Response: As noted in the preamble to the proposed rule, we recognize that 

some NCore sites will not have the necessary sampler to perform Pb-PM10 

sampling. These monitoring agencies will need to purchase, install and operate 

an additional sampler to perform Pb sampling. 

Comment ID: OAR-2006-0735-6559 

Name: R. Fahrner 

Organization: 
260 

Comment: No comment in document. 

Response: No response needed. 

Comment ID: OAR-2006-0735-5945 

Name: Christina Ritter 

Organization: 

Comment: Because healthy air is important for all human and environmental 

health, I further urge EPA to attach specific conditions to the issuance of 

waivers of the source-oriented monitoring requirements for lead and to provide 

more guidance to states concerning the kinds of sources that are expected to 

contribute to exceedances of the lead air standard. The conditions for obtaining 

waivers should be sufficiently strict to limit their use and states should be 

advised how to conduct an adequate monitoring program so that their states 

demonstrably meet the standards for healthy air. For example, site-specific data 

rather than generic, unreliable emissions estimates should be used to evaluate 

the impact of a source's emissions on ambient air lead concentrations. 

Response: The EPA did not propose changes to the existing waiver provisions. 

As such, this comment is not germane to this rule making. 

Comment ID: OAR-2006-0735-5928 

Name: J. Morian 

Organization: 

Comment: I also ask that the EPA be required to attach specific conditions to 

any waivers of the source-oriented monitoring requirements for lead, and that 

these be sufficiently strict to limit their use. 

Response: The EPA did not propose changes to the existing waiver provisions. 

As such, this comment is not germane to this rule making. 

Comment ID: OAR-2006-0735-5929 

Name: Anonymous 

Organization: 

Comment: It is our gravest responsibility to enforce clean and respectful use of 

resources for the protection of all, today and for the generations to come. 
261 

Response: No response needed. 

Comment ID: OAR-2006-0735-5944 

Name: Dick Valentinetti 

Organization: National Association of Clean Air Agencies (NACAA) 

Comment: NACAA urges EPA to update the National Monitoring Strategy 

with NACAA collaboration and input that incorporates this new direction along 

with the different philosophies and funding issues involved. For example, if, as 

described above, EPA supplemented nonsource- oriented monitoring of lead by 

incorporating data from other federal programs that conduct lead sampling, 

significant cost savings could be realized without disrupting the ability to track 

ambient lead concentrations. 

Response: The EPA is attempting to leverage existing networks as much as 

possible. This final rule replaces the existing non-source-oriented monitoring 

requirement with a requirement to measure Pb at urban NCore in order to make 

additional use of PM10 samples that will be taken as part of the PMc 

requirement. 

Comment ID: OAR-2006-0735-5944 

Name: Dick Valentinetti 

Organization: National Association of Clean Air Agencies (NACAA) 

Comment: As state and local agencies work to implement new monitoring 

requirements, it is imperative that monitoring activities be fully funded. This 

includes not only the costs of equipment, but also staff and operation and 

maintenance costs. The National Monitoring Strategy developed by EPA and 

NACAA should also be updated to incorporate changes to the monitoring 

network and ensure that economically sustainable monitoring strategies are 

implemented. EPA estimates that its proposed revisions to the lead monitoring 

requirements would raise the level of new monitors from approximately 212 

monitors to up to 352 monitors. This represents an increase of more than 50%, 

and will require a concomitant increase in staff and maintenance resources of 

state and local agencies. NACAA estimates that each new sampling site will 

require an additional .60 to .65 of a full time equivalent (FTE) to adequately 

locate, develop, operate, and maintain; these costs are not addressed in EPA’s 

estimates. In order to fulfill their new monitoring obligations, state and local 

agencies must receive full funding, including funding for necessary increases in 

staff and operation and maintenance costs. NACAA strongly urges EPA to 

fully fund the monitoring program. New federal funding should be provided 
262 

under Clean Air Act §103, rather than §105, which requires matching funds 

from already strapped state and local budgets. Given the new monitoring 

requirements in the lead, nitrogen dioxide (NO2), and sulfur dioxide (SO2) 

proposals, state and local agencies are looking at a significant overall increase 

in monitoring activities, which must be fully funded in order to ensure full 

implementation of the new requirements. 

Response: EPA notes that fiscal year 2010 STAG funding has been made 

available for the purpose of supporting new lead monitoring equipment 

purchases related to this final rule. EPA also notes that additional 2011 STAG 

funding was proposed to support "core" programs which can include activities 

such as ambient monitoring. EPA will work with the Regional Offices, 

NACAA, and monitoring agencies to develop a plan for allocating these funds 

to the new monitoring needs related to this final rule as well as recent NAAQS 

revisions. 

Comment ID: OAR-2006-0735-6574 

Name: A. Servatius 

Organization: 

Comment: I appreciate your agency's efforts to curtail the world's worst coal 

mining, mountaintop removal . This strip mining continues to decapitate 

America's oldest mountains, clearcut lush forests, destroy diverse wildlife 

habitat, pollute headwater streams, poison drinking water and threaten local 

communities . Already several hundred mountains have been leveled 

throughout Appalachia . Recently, blasting began on Coal River Mountain, 

which has the highest peaks ever slated for mining in West Virginia . Massey 

Energy's mining operation would destroy over 6,000 acres of the mountain, 

wipe out 10 square miles of lush forests, create 18 valley fills, devastate the 

Clear Fork watershed and ruin the lives of local residents who are fighting 

valiantly to defend their homes . If mountaintop removal is allowed to proceed, 

one of the best opportunities for clean energy alternatives will be destroyed as 

well . A leveled mountain would mean the loss of elevation to power a wind 

farm supported by local citizens that could provide electricity for 70,000 

homes, create 700 long-term green jobs and generate $1 .7 million in annual 

county tax revenue . In addition, Massey is detonating dynamite within 100 

yards of the largest coal sludge impoundment in the country . If the blasts 

breach the Brushy Fork retention pond, more than eight billion gallons of toxic 

coal slurry will spill out, endangering the lives of hundreds of people 

downstream who would have little or no time to evacuate . To date, West 

Virginia Governor Manchin has rejected the pleas of local residents to save 

Coal River Mountain by supporting the wind project . Other state and federal 

officials have also turned a deaf ear. Without a doubt, the Obama 
263 

administration is the last, best hope to save Coal River Mountain and protect the 

people who live in its shadow . Coal River Mountain may well represent the 

fork in the road when it comes to fulfilling the Obama administration's vision 

for America's energy future . The choice is between forging a path toward a 

clean energy economy or continuing on with "business as usual" that would 

reduce another Appalachian peak into a pile of rubble . Please direct the EPA to 

intervene immediately to stop the blasting of Coal River Mountain . 

Response: This comment is not germane to this current rulemaking. No 

response is needed. 

Comment ID: OAR-2006-0735-5944 

Name: Dick Valentinetti 

Organization: National Association of Clean Air Agencies (NACAA) 

Comment: NACAA also requests that EPA provide clarity regarding the 

discontinuation of source oriented monitors. The final rule should clearly set 

out the conditions under which monitoring at a specific source is no longer 

required. NACAA recommends that monitoring be discontinued under the 

following conditions: if, utilizing sampling and analysis methodologies that 

provide scientifically valid results, three years of data from a relevant monitor 

show ambient lead concentrations below 50% of the NAAQS, that monitor 

should be discontinued. If only FRM/FEM methods are allowed, the threshold 

of ambient lead concentrations should be raised from 50% to 70% of the 

NAAQS. 

Response: The EPA did not propose changes to the existing waiver provisions. 

As such, this comment is not germane to this rule making. However, we note 

that the existing rules allow monitoring agencies to request a waiver if historic 

data indicates that the design value is less than 50% of the NAAQS. As such, a 

monitoring agency may request to shut down a site if after three years of 

monitoring, the maximum 3-month rolling average Pb concentration is less 

than 0.075 ug/m3 . 

Comment ID: OAR-2006-0735-5944 

Name: Dick Valentinetti 

Organization: National Association of Clean Air Agencies (NACAA) 

Comment: As they develop plans for siting new source-oriented monitors, state 

and local agencies must be permitted the flexibility to determine the best 

location for the monitors, according to applicable science. In making these 
264 

determinations, the agencies must be able to consider such variables as 

potential exposures and access to locations with adequate siting. In order to 

ensure that monitors are placed in the most beneficial locations, NACAA 

encourages a process whereby EPA Regions work with state and local agencies 

in siting new source-oriented monitors. 

Response: The existing monitoring requirements allowed monitoring agencies 

to consider logistics and the potential for population exposure when siting 

source oriented monitors. We have made clarifying edits to that language to 

make it more clear what was intended. 

Comment ID: OAR-2006-0735-5931 

Name: P. Zimmerman 

Organization: 

Comment: Because healthy air is important for all human and environmental 

health, I further urge EPA to attach specific conditions to the issuance of 

waivers of the source-oriented monitoring requirements for lead and to provide 

more guidance to states concerning the kinds of sources that are expected to 

contribute to exceedances of the lead air standard. The conditions for obtaining 

waivers should be sufficiently strict to limit their use and states should be 

advised how to conduct an adequate monitoring program so that their states 

demonstrably meet the standards for healthy air. 

Response: The EPA did not propose changes to the existing waiver provisions. 

As such, this comment is not germane to this rule making. 

Comment ID: OAR-2006-0735-5941 

Name: Catharine Fitzsimmons 

Organization: Iowa Department of Natural Resources (IDNR) 

Comment: EPA should work with States to evaluate the costs associated with 

the additional emissions assessment, ambient impact assessment, monitoring 

equipment purchases, and operation and maintenance of monitors required to 

implement this rulemaking, and provide these funds to States in a timely 

manner so that they can begin work on this effort. In view of the tight budgets 

faced by Iowa and most other States, we recommend that these funds be 

allocated as 103 grants to States, so that State matching funds will not be 

required. 

Response: EPA notes that fiscal year 2010 STAG funding has been made 
265 

available for the purpose of supporting new lead monitoring equipment 

purchases related to this final rule. EPA also notes that additional 2011 STAG 

funding was proposed to support "core" programs which can include activities 

such as ambient monitoring. EPA will work with the Regional Offices, 

NACAA, and monitoring agencies to develop a plan for allocating these funds 

to the new monitoring needs related to this final rule as well as recent NAAQS 

revisions. 

Comment ID: OAR-2006-0735-5932 

Name: C. Boschert 

Organization: 

Comment: Because healthy air is important for all human and environmental 

health, I further urge EPA to attach specific conditions to the issuance of 

waivers of the source-oriented monitoring requirements for lead and to provide 

more guidance to states concerning the kinds of sources that are expected to 

contribute to exceedances of the lead air standard. The conditions for obtaining 

waivers should be sufficiently strict to limit their use and states should be 

advised how to conduct an adequate monitoring program so that their states 

demonstrably meet the standards for healthy air. For example, site-specific data 

rather than generic, unreliable emissions estimates should be used to evaluate 

the impact of a source's emissions on ambient air lead concentrations. I support 

expansion of the lead monitoring network because the existing monitoring 

network for lead is 

Response: The EPA did not propose changes to the existing waiver provisions. 

As such, this comment is not germane to this rule making. 

Comment ID: OAR-2006-0735-6568 

Name: D. Madvig 

Organization: 

Comment: Please get the lead out! 

Response: No response needed. 

Comment ID: OAR-2006-0735-5937 

Name: L. Limberg 
266 

Organization: 

Comment: We must strengthen air quality standards. We truly need not poison 

our people in the name of better commerce and industry. Please manage your 

integrity consistent with what is morally & ethically right. 

Response: No response needed. 

Comment ID: OAR-2006-0735-5938 

Name: D. A. McDaniel 

Organization: 

Comment: Because healthy air is important for all human and environmental 

health, I further urge EPA to attach specific conditions to the issuance of 

waivers of the source-oriented monitoring requirements for lead and to provide 

more guidance to states concerning the kinds of sources that are expected to 

contribute to exceedances of the lead air standard. The conditions for obtaining 

waivers should be sufficiently strict to limit their use and states should be 

advised how to conduct an adequate monitoring program so that their states 

demonstrably meet the standards for healthy air. For example, site-specific data 

rather than generic, unreliable emissions estimates should be used to evaluate 

the impact of a source's emissions on ambient air lead concentrations. 

Response: Responded to in preamble. 

Comment ID: OAR-2006-0735-5940 

Name: Gail Wechsler 

Organization: Jewish Community Relations Council 

Comment: Because healthy air is important for all human and environmental 

health, JCRC further urges EPA to attach specific conditions to the issuance of 

waivers of the source-oriented monitoring requirements for lead. The 

conditions for obtaining waivers should be sufficiently strict to limit their use 

and states should be advised how to conduct an adequate monitoring program 

so that their states demonstrably meet the standards for healthy air. For 

example, site-specific data rather than generic, unreliable emissions estimates 

should be used to evaluate the impact of a source’s emissions on ambient air 

lead concentrations. 

Response: The EPA did not propose changes to the existing waiver provisions. 

As such, this comment is not germane to this rule making. 
267 

Comment ID: OAR-2006-0735-5941 

Name: Catharine Fitzsimmons 

Organization: Iowa Department of Natural Resources (IDNR) 

Comment: We do not think it is appropriate nor consistent with previous 

practice to require a 50% margin of safety for all assessment tools used to 

establish NAAQS compliance for the purposes of placing air monitors. 

Response: The EPA did not propose changes to the existing waiver provisions. 

As such, this comment is not germane to this rule making. 

Comment ID: OAR-2006-0735-6562 

Name: R. Myers 

Organization: 

Comment: No comment contained in documents. 

Response: No response needed. 

Comment ID: OAR-2006-0735-5941 

Name: Catharine Fitzsimmons 

Organization: Iowa Department of Natural Resources (IDNR) 

Comment: To the extent that the purpose of the emissions thresholds in the 

permitting and monitoring rules are the same, i.e., we urge EPA to require an 

ambient impact analysis in cases where the NAAQS is likely to be threatened, 

we urge EPA to set them at the same level. 

Response: The final rule did not propose changes to the permitting 

requirements, and as such, this comment is not germane to this rule making. 

Comment ID: OAR-2006-0735-5942 

Name: B. Keith Overcash 

Organization: North Carolina Department of Environment and Natural 

Resources (NCDENR) 

Comment: Like many states, North Carolina is in poor financial condition due 
268 

to the current economic situation. For North Carolina, the estimated costs of 

deploying a lead monitoring network at both National Core (NCore) sites is 

estimated to be approximately $10,000, assuming we use the existing 

low-volume PM 10 monitors, with an annual operating cost of $60,000. This 

cost is significantly less than the cost that the state would have incurred in the 

original lead monitoring network where separate community-wide monitoring 

sites were required in Metropolitan Statistical Areas greater than 500,000 

people, but it is still an additional burden during a difficult time. In addition to 

expected costs associated with the proposed lead monitoring network, the 

NCDAQ also has to determine how to fund the additional monitoring 

requirements proposed in the ozone monitoring rule and the monitoring that 

will be required for the new Nitrogen Dioxide (NO2) National Ambient Air 

Quality Standard (NAAQS) and the proposed Sulfur Dioxide (SO2) rule. 

Furthermore, the NCDAQ is expending resources to implement and enforce the 

area source maximum achievable control technology (MACT) and generally 

available control technology (GACT) regulations, as well as the expected 

resources that will be needed for the climate change regulations that are on the 

horizon. The various new requirements and shrinking funds are placing the 

NCDAQ in a position where we will not be able to fund all of EPA's new 

requirements. The proposed changes to the community-wide monitoring 

requirements will help. EPA needs to fully fund the cost of analyzing the 

required lead samples. These funds need to be in the form of Section 103 grant 

monies rather than Section 105 grant monies. In the financial situation that 

many states fine themselves in at this time, some may not have the funds to 

match additional Section 105 grant monies. 

Response: EPA notes that fiscal year 2010 STAG funding has been made 

available for the purpose of supporting new lead monitoring equipment 

purchases related to this final rule. EPA also notes that additional 2011 STAG 

funding was proposed to support "core" programs which can include activities 

such as ambient monitoring. EPA will work with the Regional Offices, 

NACAA, and monitoring agencies to develop a plan for allocating these funds 

to the new monitoring needs related to this final rule as well as recent NAAQS 

revisions. 

Comment ID: OAR-2006-0735-5930 

Name: Judith Zwicker 

Organization: JZ Consulting 

Comment: Because healthy air is important for all human and environmental 

health, I further urge EPA to attach specific conditions to the issuance of 

waivers of the source-oriented monitoring requirements for lead and to provide 

more guidance to states concerning the kinds of sources that are expected to 

contribute to exceedances of the lead air standard. The conditions for obtaining 
269 

waivers should be sufficiently strict to limit their use and states should be 

advised how to conduct an adequate monitoring program so that their states 

demonstrably meet the standards for healthy air. For example, site-specific data 

rather than generic, unreliable emissions estimates should be used to evaluate 

the impact of a source’s emissions on ambient air lead concentrations. 

Response: The EPA did not propose changes to the existing waiver provisions. 

As such, this comment is not germane to this rule making. 

Comment ID: OAR-2006-0735-6143 

Name: K. Maser 

Organization: 

Comment: I strongly urge the EPA to do its job: protect our children and our 

adults too from air polluted by lead. This should be a no brainer!....... 

Response: No response needed. 

Comment ID: OAR-2006-0735-6213 

Name: J. Erdman, Ph.D. 

Organization: 

Comment: Some four decades ago, I and several colleagues documented the 

reason for horses killed in pasturage next to a haul-route in the Viburnum Lead 

Belt of Missouri. http://en.wikipedia.org/wiki/Lead_Belt Lead poisoning from 

lead dust blew off uncovered trucks, a practice since corrected. Analysis of the 

branches of juniper trees growing along the road revealed high lead values. 

Those and other findings were published in the Proceedings of the 4th Annual 

Conference on Trace Substances in Environmental Health, 1971. "Roadside 

effects on trace-metal content in some rocks, soils, and plants of Missouri, " by 

Connor, Erdman, Sims and Ebens. 

Response: No response needed. 

Comment ID: OAR-2006-0735-5960 

Name: Russ Murray 

Organization: Ohio Cast Metals Association (OCMA) 
270 

Comment: 3. Use of NEI Emissions Data OCMA is concerned that the use of 

the emissions information contained in the 2002 and 2005 National Emissions 

Inventory (NEI) is no longer representative because many metal casters have 

indicated significantly lower emissions than those reported in the 2002 and 

2005 NEI due to the type of scrap available, implementation of scrap 

management plans and improved emission estimation methodologies. Most 

foundries have implemented scrap management plans with scrap specifications 

designed to eliminate or minimize the amount of lead that is charged in the 

furnaces. This practice is necessary to maintain the quality of cast metal 

products as well as for environmental and workplace exposure considerations. 

In several recent air emission rulemakings applicable to foundries, EPA has 

cited data that demonstrates significant reductions in hazardous air pollutants 

over the past two decades. EPA has taken credit for these reductions as part of 

its overall program to reduce hazardous air pollutant emissions from industry 

sources like foundries. EPA’s Sector Strategies Program has also reported 

significant reductions in hazardous air pollutant emissions from the metal 

casting industry in its 2006 Performance Report. According to this report that 

relies upon Toxic Release Inventory (TRI) data, foundries have reduced 

hazardous air pollutant emissions by 58 percent from 1994 to 2003 (this 

includes reductions of lead emissions). Given the above, it is unlikely that this 

trend and the industry’s current practices that reduce lead emissions are 

accurately reflected in the 2002 and 2005 NEI database. 

Response: Monitoring agencies are encouraged to use the most recent and 

accurate estimates of Pb emissions when determining the applicability of these 

monitoring requirements. 

Comment ID: OAR-2006-0735-5961 

Name: Jerry Call 

Organization: American Foundry Society (AFS) 

Comment: This comment is a duplicate of comment id 5957. 

Response: 

Comment ID: OAR-2006-0735-5964 

Name: James Brook 

Organization: Maine Department of Environmental Protection (ME DEP) 

Comment: Maine also encourages EPA to fully fund the lead monitoring 

program. Adding a monitoring program that has been discontinued for the past 
271 

12 years due to the low concentrations will require additional investments in 

monitors and analytical costs as well as staff to operate the program. New 

funding for this program should be provided under the 103 grants rather than 

the 105 grant which will require matching funds from the states . 

Response: EPA notes that fiscal year 2010 STAG funding has been made 

available for the purpose of supporting new lead monitoring equipment 

purchases related to this final rule. EPA also notes that additional 2011 STAG 

funding was proposed to support "core" programs which can include activities 

such as ambient monitoring. EPA will work with the Regional Offices, 

NACAA, and monitoring agencies to develop a plan for allocating these funds 

to the new monitoring needs related to this final rule as well as recent NAAQS 

revisions. 

Comment ID: OAR-2006-0735-6045 

Name: K. Townsend 

Organization: 

Comment: With all the potential links to ADHD, low IQ and other problems in 

children (that, by the way, do not go away once they grow up), we really can't 

afford to take chances with lead emissions. Any preventable lead emissions 

should be curbed, at least as well as they were before the 2008 legislation. 

Response: No response needed. 

Comment ID: OAR-2006-0735-6305 

Name: J. Bressler 

Organization: 

Comment: We are seeing more and more people with breathing issues that are 

now becoming almost an epidemic. The lackadaisical actions taken by the EPA 

during the past administration have only added to the dangers we all face every 

time we take a breath outside. It is now time for the EPA to take a real stand and 

do its job: PROTECTING THE ENVIRONMEN, not the coffers of big energy! 

Response: No response needed. 

Comment ID: OAR-2006-0735-6037 

Name: T. Birch 
272 

Organization: 

Comment: Perhaps Congress forgot why the EPA was created in the first place. 

Why don't you remind them? And what are you going to do when your 

'monitoring' illuminates abuses? Fine them? Or force them to shut down that 

specific program? Prosecute for negligence and endangerment? You guys 

better get serious, and angrier at Big Industry. THAT is what you originally 

were told to do, anyway. And whether Congress is currently cooperative or not, 

the EPA should continually remind them of the mission statement, as set forth 

due to enacting legislation, and our ever evolving industrial society and their 

harmful toys. Justice, Tranquility, and the General Welfare, people: It's 

Constitutional. Thank you, whoever is reading this.

Response: No response needed. 

Comment ID: OAR-2006-0735-6140 

Name: G. Smolinsky 

Organization: 

Comment: Airborne lead is toxic and can cause a host of medical problems, 

especially in children who are more susceptible to the harmful effects of lead 

exposure. Some of the problems it causes include lower IQ, behavioral 

problems, brain damage, kidney damage and cardiovascular injury 

Response: No response needed. 

Comment ID: OAR-2006-0735-6313 

Name: C. Dolan 

Organization: 

Comment: Are you kidding? It's lead. It makes people stupid. Monitor it. 

Response: No response needed. 

Comment ID: OAR-2006-0735-5957 

Name: Jerry Call 

Organization: American Foundry Society (AFS) 

Comment: The Metal Casting Industry Has Significantly Reduced Lead 
273 

Emissions A document in the docket for the November 12, 2008 rule provides a 

summary of stationary source lead emissions data that is based on the 2002 

National Emissions Inventory (NEI). As part of the administrative record for 

this proposed action, EPA also referenced the 2005 NEI data. AFS is concerned 

that these data may be misleading and do not necessarily represent the foundry 

industry’s current and historic practices to reduce lead emissions. In fact, many 

AFS member foundries have indicated that their current lead emissions are 

significantly lower than the levels reported in the 2002 and 2005 NEI data bases 

due to reductions that have occurred since the time of reporting or due to 

improved estimation and measurement techniques for lead emissions. The 

primary source of lead at a foundry is generally from the tramp lead found in the 

scrap metal used as the raw materials for furnaces. Lead is considered an 

unwanted contaminant in the feedstock. Most foundries have implemented 

scrap management plans with scrap specifications designed to eliminate or 

minimize the amount of lead that is charged in the furnaces. This practice is 

necessary to maintain the quality of cast metal products as well as for 

environmental and workplace exposure considerations. In addition, many 

foundries have air pollution control devices in place that are designed to capture 

particulate matter (that may contain lead) from melting furnaces. These efforts 

have significantly reduced lead emissions from foundries. Even EPA has 

recognized the progress of the metal casting industry in reducing emissions of 

hazardous air pollutants such as lead. In several recent air emission rulemakings 

applicable to foundries, EPA has cited data that demonstrates significant 

reductions in hazardous air pollutants over the past two decades. EPA has taken 

credit for these reductions as part of its overall program to reduce hazardous air 

pollutant emissions from industry sources like foundries. EPA’s Sector 

Strategies Program has also reported significant reductions in hazardous air 

pollutant emissions from the metal casting industry in its 2006 Performance 

Report. According to this report that relies upon Toxic Release Inventory (TRI) 

data, foundries have reduced hazardous air pollutant emissions by 58 percent 

from 1994 to 2003 (this includes reductions of lead emissions). A very large 

percentage of this reduction occurred more recently during the past ten years. 

These significant reductions in hazardous air pollutant emissions coupled with 

the recent implementation of new hazardous air pollutant regulations suggest a 

continuing trend of further reductions of lead emissions for foundries. It is, 

therefore, unlikely that this trend and the industry’s current practices that 

reduce lead emissions are accurately reflected in the 2002 and 2005 NEI 

database. 

Response: Monitoring agencies are encouraged to use the most recent and 

accurate estimates of Pb emissions when determining the applicability of these 

monitoring requirements. 

Comment ID: OAR-2006-0735-5985 
274 

Name: L. Massman-Johnson 

Organization: 

Comment: When doctors in an ER triage an extreme case they act immediately 

and decisively on ONLY the most serious and immanently life-threatening 

issues. Nothing else matters until the patient is stabilized. We are approaching a 

triage decision for Global Warming on Earth. Life as we know it is bleeding 

out. But we can see exactly where to act – stop the mega-polluters. YOU just 

need the courage to do it. The United States has created the vast majority of the 

historical greenhouse gas emissions, and even today is just barely eclipsed by 

China's total annual output. But China has 4 times the population of the US, 

which effectively means each US citizen STILL generates about 4 times the 

pollution as the Chinese. The United States and China together create some 

40% of current emissions worldwide, and it is painful and ironic that for yet 

ANOTHER year neither of us will ratify Kyoto. We can't control China, so 

what is the best place for US decision-makers to focus triage efforts to stop the 

life-threatening hemorrhage that we created? The obvious target is the 

mega-polluters. If we know half of US emissions can be plugged at just a few 

sources, it is a moral imperative that we act on that. Life as we know it is 

bleeding out. But we can see exactly where to act – stop the mega-polluters. 

YOU just need the courage to do it. 

Response: No response needed. 

Comment ID: OAR-2006-0735-6437 

Name: M. Toor 

Organization: 

Comment: I don't think I have to tell you why this is a critical issue, please 

protect the citizens of this country! 

Response: No response needed. 

Comment ID: OAR-2006-0735-5989 

Name: M. Ankelman 

Organization: 

Comment: It's your duty to put public health before private wealth. 

Response: No response needed. 
275 

Comment ID: OAR-2006-0735-6319 

Name: O. Tegland 

Organization: 

Comment: Why was the EPA formed? Because industry has proven capable of 

self-monitoring? Because corporate law puts people before profit? Please. 

Sound regulation, wise scrutiny. 

Response: No response needed. 

Comment ID: OAR-2006-0735-6146 

Name: L. Day 

Organization: 

Comment: Please enact strong roles to protect us from lead in the air. I live in 

Houston, and I hate the idea that industry can decide how many toxins they can 

dump in the air we breathe around here. Our environment -- and our lives -- 

depend on strong Federal rules & enforcement. 

Response: No response needed. 

Comment ID: OAR-2006-0735-6466 

Name: C. Mathews 

Organization: 

Comment: I don't know all the reasons behind the change from half a ton to 1 

ton a year of lead requiring EPA monitoring, but I would assume they were 

economic. It seems to me that business should monitor its own pollution and the 

only job of the EPA would be to verify that monitoring periodically through soil 

samples in the area, smoke exhaust stack checks at random and testing local 

stream and other ground water for contamination at most. Scheduled routine 

testing is the job of business in my mind and the EPA should just conduct 

random and unannounced tests to verify good stewardship. As long as the EPA 

is operating within the limits of its power as given by congress, I think its job is 

simply to do the most with the least amount of expense. 

Response: As discussed in the preambles to the proposal and the final rule, the 

EPA is lowering the emission threshold to better identify sources that have the 

potential to exceed the Pb NAAQS. Under the CAA, the EPA has the authority 

to require State and local monitoring agencies to conduct necessary monitoring 
276 

to determine compliance with the Pb NAAQS. Depending on state rules, 

monitoring agencies may be able to delegate this monitoring to the private 

industry, and/or recoup the costs associated with monitoring through permitting 

and operating fees. 

Comment ID: OAR-2006-0735-6498 

Name: C. Watkinson 

Organization: 

Comment: Lead in our air can't be good. 

Response: No response needed. 

Comment ID: OAR-2006-0735-6148 

Name: C. Ulbrich 

Organization: 

Comment: We must put the needs of the many over the profits of a few. Lead is 

a known toxin, and our country is an a major health crisis, with ballooning rates 

of all diseases. Pollution kills 

Response: No response needed. 

Comment ID: OAR-2006-0735-6493 

Name: B. Cunningham 

Organization: 

Comment: I believe the EPA should do everything in it's power to protect the 

living citizens of the United States from harmful chemicals. 

Response: No response needed. 

Comment ID: OAR-2006-0735-6023 

Name: A. Marsot 

Organization: 
277 

Comment: Letter did not contain any comments. 

Response: No response needed. 

Comment ID: OAR-2006-0735-6341 

Name: R. Berka 

Organization: 

Comment: 2000 years after the Romans poisoned themselves with lead, we still 

haven't learned. 

Response: No response needed. 

Comment ID: OAR-2006-0735-6016 

Name: E. Landels 

Organization: 

Comment: Not doing everything we can to reign in polluted air that will harm 

our children and their future potentials is suicidal. As a country, we need to stop 

prioritizing corporate America's short-term goals and start looking more 

towards the nation's long-term interests. 

Response: No response needed. 

Comment ID: OAR-2006-0735-5984 

Name: L. Squiers 

Organization: 

Comment: Why are we being poisoned by corporations? Why don't our 

regulatory agencies actually regulate these polluters and stop corrupt practices? 

Response: No response needed. 

Comment ID: OAR-2006-0735-5951 

Name: G. Vinson Hellwig 

Organization: The Michigan Department of Natural Resources and 
278 

Environment (MDNRE) 

Comment: The EPA has also been slow in granting Federal Equivalent Method 

(FEM) status to many of the long-established laboratory procedures that have 

been used by states to analyze lead. As a result, many states such as Michigan 

are stockpiling filters collected at 1 T/y sources for later analysis. It is 

incumbent upon the EPA to address and approve the many FEM requests made 

by states before issuing another lead monitoring mandate. 

Response: The EPA has approved 3 new generic FEM for use by monitoring 

agencies. Furthermore, a national contract has been finalized which will allow 

monitoring agencies to purchase Pb analysis from this contract if the 

monitoring agency so chooses. 

Comment ID: OAR-2006-0735-5946 

Name: Arthur N. Marin 

Organization: Northeast States for Coordinated Air Use Management 

(NESCAUM) 

Comment: The NESCAUM states are concerned about the quality of the 

national inventories used by EPA as the basis for its decisions on lead 

monitoring. The airport inventory’s emission factors and activity data have not 

been reviewed by the states for many years and may be significantly outdated. 

Some data points are highly suspect. For example, a small airport in the 

Hamptons (New York) was attributed with 154,000 landings and takeoffs. This 

number is more than 75% of the total flights in and out of Kennedy 

International Airport in New York City. The lead inventory for electric 

generating units (EGUs) is also of concern. Our understanding is that this 

inventory was developed based on a 1998 Utility Report to Congress.2 Several 

data points in this inventory have been changed without consultation with the 

states and are also highly suspect. Prior to finalizing this rule, EPA must 

undertake a robust and detailed evaluation and review of the airport and EGU 

lead inventories. This should include quality assurance, quality control, and 

comprehensive state review. 

Response: The EPA has been working with States to improve the emission 

inventories, and will continue to do so as monitoring agencies work to 

implement these new requirements. 

Comment ID: OAR-2006-0735-5946 

Name: Arthur N. Marin 
279 

Organization: Northeast States for Coordinated Air Use Management 

(NESCAUM) 

Comment: The NESCAUM states recommend that EPA allow modeling to be 

used in conjunction with monitoring data to better determine nonattainment 

areas. The intent is to ensure that areas can be designated nonattainment in 

those cases where robust monitoring data are lacking. 

Response: These regulatory revisions deal with monitoring requirements, and 

do not affect other NAAQS implementation issues such as the use of modeling 

data to determine nonattainment areas. As such, this question is not germane to 

this rule making. 

Comment ID: OAR-2006-0735-5946 

Name: Arthur N. Marin 

Organization: Northeast States for Coordinated Air Use Management 

(NESCAUM) 

Comment: NESCAUM encourages EPA to develop and implement a national 

lead reduction strategy that addresses all sources of environmental lead, 

including but not limited to aviation gasoline, consumer products, metals 

recycling, steel production, lead acid battery disposal, tire weights, fishing 

sinkers and weighted lures, paint, lead shot, and diesel lube oil. Such an 

approach would greatly speed the process for minimizing lead exposure 

nationwide. 

Response: No response needed. 

Comment ID: OAR-2006-0735-5947 

Name: Therese M. Cirone 

Organization: RSR Corporation (RSR) 

Comment: The five-year span before such a waiver must be renewed appears 

too long in light of the stated goals of the current rulemaking. RSR believes that 

a yearly testing program to support the continuation of any such waiver would 

be desirable. We encourage EPA to revise the above-quoted subsection in 

Appendix D to provide that lead emission sources, such as secondary lead 

smelters, perform annual testing of lead emissions from process sources and 

"sanitary" source (for example, bag houses and high-efficiency 

particulate-absorbing (HEPA) filters controlling emissions from buildings) to 

confirm that the 0.5 TPY limit is not exceeded before a previously authorized 

waiver may continue in effect. The absence of an annual check- up opens the 
280 

door to undiscovered, ongoing NAAQS exceedances, counter to the purposes 

of EPA’s revised monitoring proposal. 

Response: The EPA did not propose changes to the existing waiver provisions. 

As such, this comment is not germane to this rule making. 

Comment ID: OAR-2006-0735-5949 

Name: Teresa Marks 

Organization: Arkansas Department of Environmental Quality (ADEQ) 

Comment: Due to current constrains on staff and fiscal resources, ADEQ is 

reluctant to require additional monitoring unless the arguments for doing so are 

pervasive. EPA should assure support in the form of 103 grant funds for any 

additional monitoring effort that would be required by these revisions to the 

rule. 

Response: EPA notes that fiscal year 2010 STAG funding has been made 

available for the purpose of supporting new lead monitoring equipment 

purchases related to this final rule. EPA also notes that additional 2011 STAG 

funding was proposed to support "core" programs which can include activities 

such as ambient monitoring. EPA will work with the Regional Offices, 

NACAA, and monitoring agencies to develop a plan for allocating these funds 

to the new monitoring needs related to this final rule as well as recent NAAQS 

revisions. 

Comment ID: OAR-2006-0735-5950 

Name: Laurel L. Kroack 

Organization: Illinois Environmental Protection Agency 

Comment: EPA Needs to Provide State and Local Agencies Flexibility in 

Implementing Lead Monitoring Requirements, 

Response: The EPA has attempted to include as much flexibility as possible in 

these Pb monitoring requirements. 

Comment ID: OAR-2006-0735-5950 

Name: Laurel L. Kroack 

Organization: Illinois Environmental Protection Agency 
281 

Comment: EPA Must Fully Fund the Monitoring Program and Support 

Economically Sustainable Monitoring Strategies, 

Response: EPA notes that fiscal year 2010 STAG funding has been made 

available for the purpose of supporting new lead monitoring equipment 

purchases related to this final rule. EPA also notes that additional 2011 STAG 

funding was proposed to support "core" programs which can include activities 

such as ambient monitoring. EPA will work with the Regional Offices, 

NACAA, and monitoring agencies to develop a plan for allocating these funds 

to the new monitoring needs related to this final rule as well as recent NAAQS 

revisions. 

Comment ID: OAR-2006-0735-5957 

Name: Jerry Call 

Organization: American Foundry Society (AFS) 

Comment: EPA Must Use the Best Data Available for Locating Ambient Lead 

Monitors In making determinations for locating source-oriented lead monitors, 

EPA should rely on the best data available. Specifically, this would be the best 

data available that are more representative of the foundry industry’s current 

practices and actual lead emissions, rather than rely on the 2002 and 2005 NEI 

lead emissions data. Accordingly, facilities potentially subject to the proposed 

revised monitoring requirements should be allowed to present data that would 

accurately reflect current practices at the foundry and actual lead emissions. 

Ideally, these data could include emissions testing results, where available. 

Other options for demonstrating potential lead emissions could include the 

amount of lead found in scrap supplies, recent emissions factors that reflect 

current practices implemented to reduce lead emissions, bag house dust 

analysis, or historical data that may reflect the trend of lead emission 

reductions. The most critical factor is to use data that are representative of the 

foundry’s current practices that are designed to, and have resulted in, reductions 

of lead emissions. 

Response: Monitoring agencies are encouraged to use the most recent and 

accurate estimates of Pb emissions when determining the applicability of these 

monitoring requirements. 

Comment ID: OAR-2006-0735-6271 

Name: N. Orr 

Organization: 
282 

Comment: EPA such toxins should be regulated to the maximum extent under 

the law. It's a perversion of justice that these companies are not monitored. 

Regulatory agencies have become a joke. 

Response: No response needed. 

Comment ID: OAR-2006-0735-6061 

Name: T. Martinez 

Organization: 

Comment: EPA: please use strict regulation on those companies emitting lead 

into America's air. We need it now, with no delay. 

Response: No response needed. 

Comment ID: OAR-2006-0735-6226 

Name: S. Connor 

Organization: 

Comment: We need to find a way to put the health and well being of human 

beings and the planet that sustains life above economics. If we fail to make that 

shift in our priorities, life on earth will deteriorate and economic profit will lose 

its value anyway. We simply must make this shift. 

Response: No response needed. 

Comment ID: OAR-2006-0735-6064 

Name: Myra C. Reece 

Organization: South Carolina Department of Health and Environmental 

Control 

Comment: For the past three decades, the Department has assumed primary 

responsibility of implementing the Clean Air Act (CAA) for the State of South 

Carolina as it relates to the National Ambient A' Quality Standards (NAAQS). 

States are charged with carrying out requirements of the CAA and with 

developing State Implementation Plans (SIPS) that outline how air pollution 

will be controlled to meet the NAAQS. The SIP process has become 

burdensome, complicated, and costly, and EPA has not provided the funding to 

state and local air agencies that is needed to develop and implement new 
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requirement . We urge EPA to agencies face. The Department is already 

under-funded for existing mandates and continues t face acute fiscal difficulties 

that severely strain our resources. Continuing reductions on funding are 

necessitated a critical evaluation of our current air quality program. Difficult 

options are being considered in order to focus our limited resources on the 

operation and maintenance of an air quality monitoring program that both 

objectively and accurately documents the ambient air quality and provides the 

necessary oversight needed to protect the public health for all of our urban and 

rural populations, as w 11 as any sensitive ecosystems that could be negatively 

impacted. The Department cannot continue to absorb unfunded costs associated 

with this and other network expansions, such as the near roadway nitrogen 

oxide monitoring network. Without additional funding, the Department will 

find it impossible to m t these additional 

Response: EPA notes that fiscal year 2010 STAG funding has been made 

available for the purpose of supporting new lead monitoring equipment 

purchases related to this final rule. EPA also notes that additional 2011 STAG 

funding was proposed to support "core" programs which can include activities 

such as ambient monitoring. EPA will work with the Regional Offices, 

NACAA, and monitoring agencies to develop a plan for allocating these funds 

to the new monitoring needs related to this final rule as well as recent NAAQS 

revisions. 

Comment ID: OAR-2006-0735-5953 

Name: Sandra F. Veazey 

Organization: Florida Department of Environmental Protection 

Comment: Whatever monitoring is required. the division requests that EPA 

provide §l03 grant funds for the capital costs associated with the lead 

monitoring increases. This proposal will require the division to establish 13 

additional lead sites. This expense has not been part of our fiscal planning and 

comes at a time when increases in funding are unlikely to come from state 

sources. In addition to the capital cost for these monitors. their operation will 

require additional funding. The division requests that EPA provide additional 

105 grant funds for 

Response: EPA notes that fiscal year 2010 STAG funding has been made 

available for the purpose of supporting new lead monitoring equipment 

purchases related to this final rule. EPA also notes that additional 2011 STAG 

funding was proposed to support "core" programs which can include activities 

such as ambient monitoring. EPA will work with the Regional Offices, 

NACAA, and monitoring agencies to develop a plan for allocating these funds 

to the new monitoring needs related to this final rule as well as recent NAAQS 

revisions. 
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Comment ID: OAR-2006-0735-5954 

Name: Mary Munn 

Organization: Fond du Lac Reservation 

Comment: The costs of the additional ambient air lead monitoring should be 

borne by the facilities that produce the emissions.

Response: Historically, the responsibility to monitor ambient air has been 

placed on the states, and not on private industry. States and local monitoring 

agencies may be able to pass the expense of monitoring on to private industry 

through various fees or permitting requirements, however, that is not for the 

EPA to decide. 

Comment ID: OAR-2006-0735-5951 

Name: Avinash Kar 

Organization: Natural Resources Defense Council (NRDC) et al. 

Comment: When performed with robust lead emissions data, modeling can help 

agencies evaluate the impact of factors such as meteorology and terrain on 

ambient lead concentrations. However, poorly rated emission factors or other 

unreliable lead emissions estimates should not be used in modeling for waiver 

requests. The EPA has previously acknowledged in the context of waivers “the 

possibility that faulty or uncertain modeling demonstrations or past monitoring 

programs would be the basis for not monitoring sources that are the most likely 

to cause NAAQS violations.” Proposed Rule for National Ambient Air Quality 

Standards for Lead, 73 Fed. Reg. 29184, 29263 (May 20, 2008). Given this 

acknowledgement and the range of reliability in lead emissions estimates, EPA 

must place further limitations on the grant of waivers in order to protect public 

health with an adequate margin of safety. EPA should limit the use of lead 

emissions estimates in modeling for waiver requests to site specific emissions 

data or independently verified lead emissions estimates in light of its statement 

that many NEI lead emission estimates can be improved with site specific data. 

73 Fed. Reg. at 67026. Without these limitations to prevent the use of unreliable 

lead emission estimates, monitoring requirements may inappropriately be 

waived for sources that contribute to a maximum ambient air lead concentration 

of over 50 percent of the NAAQS. In addition, although the EPA has stated that 

the “purposes of the monitoring network would be undermined if multiple 

sources in a single area were able to receive waivers, with the result that no 

monitor was required even though Pb concentrations in the area were in excess 

of 50 percent of the standard,” 73 Fed. Reg. at 67027, it has not added any 

limitations in the waiver provision to ensure that this will not occur. Instead, in 

the preamble to the final rule, EPA states that it “expects that Regional 
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Administrators, in deciding whether to grant waivers, will take into account 

whether other waivers have been granted or sought for sources in the same area, 

and whether the cumulative emissions of the sources in the area warrant at least 

one monitor being sited.” 73 Fed. Reg. at 67027 (emphasis added). EPA should 

also add language to the waiver provision to ensure that lead concentrations 

from multiple sources adding up to more than 50% of the NAAQS are 

adequately captured, especially given EPA’s proposal to dispense with 

population-based monitors in urban areas. In light of that proposal, it is even 

more important to ensure that waivers do not prevent urban areas from being 

adequately monitored. The other limitations on waivers suggested above will 

also help achieve this objective by strengthening health-protections in the 

Response: The EPA did not propose changes to the existing waiver provisions. 

As such, this comment is not germane to this rule making. 

Comment ID: OAR-2006-0735-5951 

Name: G. Vinson Hellwig 

Organization: The Michigan Department of Natural Resources and 

Environment (MDNRE) 

Comment: 1. Any new monitoring mandate must be accompanied by a 

requisite level of new funding. Given EPA's recent proposed revisions to the 

ambient air monitoring requirements for nitrogen dioxide, sulfur dioxide, ozone 

and school air toxics, it is unlikely that the MDNRE will be able to conduct the 

air monitoring laid out in this proposal for lead unless the EPA provides 100 

percent funding. This new funding should be in the form of a Section 103 grant 

so as not to require a state match. The MDNRE simply does not have surplus 

resources available to continue to establish new sites in these financially 

constrained times. 

Response: EPA notes that fiscal year 2010 STAG funding has been made 

available for the purpose of supporting new lead monitoring equipment 

purchases related to this final rule. EPA also notes that additional 2011 STAG 

funding was proposed to support "core" programs which can include activities 

such as ambient monitoring. EPA will work with the Regional Offices, 

NACAA, and monitoring agencies to develop a plan for allocating these funds 

to the new monitoring needs related to this final rule as well as recent NAAQS 

revisions.