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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 1

1 CONGRESS STREET, SUITE 1100

BOSTON, MASSACHUSETTS 02114-2023

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Honorable James H. Douglas

Governor of Vermont

Pavilion Offce Building

Montpelier, VT 05609-0101

Dear Governor Douglas:

I am writing you today to provide you with guidance on the process for designating areas

under the 2008 revised National Ambient Air Quality Standard (NAAQS) for Lead. In order to

ensure that public health and welfare are protected, the U.S. Environmental Protection Agency

(EPA) revised the lead NAAQS on October 15 2008 (73 FR 66964; November 12, 2008). The

new primary lead standard was lowered from the 1.5 micrograms per cubic meter (ug/m ) level

set in 1978, to a level of 0. 15 ug/m . This new standard is based on the most recent scientific

studies and provides protection against adverse health effects associated with exposure to lead.

To provide increased protection against lead-related welfare effects, EP A revised the secondary

standard to be identical in all respects to the revised primary standard.

The next step in implementing the revised lead NAAQS is for States to recommend to

EP A an air quality designation for their State. The process for designations, following

promulgation of a new or revised NAAQS, is contained in Section 107(d)(l) of the Clean Air

Act (Act). This section of the Act provides a process for each Governor to recommend

attainment, nonattainment, or unclassifiable designations, with appropriate boundaries, to the

EP A and requires that these recommendations be submitted to EP A within one year of a

promulgation of a new or revised NAAQS. Therefore, we ask that your state provide

designation recommendations for all areas by October 15 2009.

Under section 107 (d)( 1) of the Act, EP A may make modifications to the recommended

designations and boundaries as it deems necessary. EP A wil notify the states, by no later than

120 days prior to promulgating the designations, of our response to state s recommendations.

This wil provide an opportunity for the State to comment on any modification that EP 

proposes to their recommendation.

We are including an enclosure to this letter, which provides guidance to State, and local

air pollution control agencies and Tribes on the timeline and process for designating areas under

the revised lead standard. We plan to announce our intended designations as early as possible

but no later than 120 days prior to promulgating initial designations.

Under section 107(d)(1)(B) of the Act, EPA is required to issue final designations within

two years of finalizing a NAAQS; however, EPA has the discretion to extend the deadline up to

one year if there is insuffcient information to make designations. As part of the rule establishing

Toll Free -1-888-372-7341

Internet Address (URL) - http://www,epa.gov/regio

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the new lead NAAQS , EP A created new monitoring requirements that call for the establishment

of new lead monitors that wil begin collecting data for areas in New England by 2011. EPA

intends to complete initial designations by no later than October 15, 2010, where data is

sufficient from the existing monitoring network or where no additional data is expected to be

available for a state. Remaining areas, using information from the expanded lead monitoring

network, wil be designated by no later than October 15, 2011. States wil have an opportunity 

update their recommendations for these remaining areas by October 15, 2010.

Establishing area designations is a key step in the process of providing the health

protection that the Act is intended to provide. Areas that are designated as not attaining the lead

NAAQS wil be required to adopt plans to reduce ambient concentrations of lead. We wil keep

your State informed of any additional guidance and other support activities. Should you have

any questions regarding this matter, please do not hesitate to contact me. Your air quality

management officials may wish to contact Bob McConnell of our Air Quality Planning Unit at

617 -918- 1046.

Sincerely,

M;t L-' '-

Ira W. Leighton

Acting Regional Administrator

Enclosure

cc: Justin Johnson, VT DEC

Richard Valentinetti, VT DEC

Harold Garabedian, VT DEC