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PRO 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 Recycled/Recyclable. Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% postconsumer)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