UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION 2
 

290 BROADWAY
 

NEW YORK, NY 10007-1866
 

JUN 1 4 2011 

Chief Monica Jacobs 

Chief Mark H. Garrow 

Chief Randy Hart 

St. Regis Mohawk Tribe 

412 State Route 37 

Akwesasne, New York 13655 

Dear Chief Monica Jacobs, 

Dear Chief Mark H. Garrow, 

Dear Chief Randy Hart: 

Thank you for your October 16, 2009 recommendations on air quality designations for the 

revised National Ambient Air Quality Standards for lead on behalf of St. Regis Mohawk Tribe. 

This letter is to notify you of the U.S. Environmental Protection Agency's (EPA's) preliminary 

decision to designate St. Regis Mohawk Tribe as unclassifiable/attainment, and to inform you of 

our approach for completing the designations for the revised lead standard. Reducing levels of 

lead pollution is an important part ofthe EPA's commitment to a clean, healthy environment. 

Lead exposure can cause a range of adverse health effects, most notably in children. Exposures 

to low levels of lead early in life have been linked to effects on IQ, learning, memory, and 

behavior. 

On October 15, 2008, the EPA substantially strengthened the health-based or "primary" National 

Ambient Air Quality Standard by lowerin~ it from 1.5 micrograms per cubic meter (llg/m3) - a 

level set in 1978 - to a level of 0.15 Ilg/m . This stronger standard provides increased protection 

against adverse health effects associated with exposure to lead in at-risk groups, including 

children. To provide increased protection against lead-related environmental and other welfare 

effects, the EPA revised the secondary National Ambient Air Quality Standard to be identical in 

all respects to the revised primary standards. The EPA also determined that the pre-existing 

ambient lead monitoring network was inadequate for determining whether many areas are 

meeting the revised lead standards and established new criteria for siting ambient lead monitors 

and new data collection requirements. Monitors meeting the new network siting requirements 

were to begin operation January 1,2010. 

Within two years of promulgating new or revised National Ambient Air Quality Standards, the 

Clean Air Act requires the EPA to complete the initial process of identifying or designating areas 

that meet or do not meet an air quality standard. If the Administrator has insufficient information 

to make these designations, the EPA has the authority to extend the designation process by up to 

one year. In light of the new monitoring network, the EPA is completing the lead designations in 

two rounds. In the first round, completed on November 16,2010, the EPA designated as 

"nonattainment" 16 areas as violating the 2008 Lead National Ambient Air Quality Standards 

based on data from the pre-201 0 monitoring network. For all other areas, the EPA extended the 

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deadline for designations by up to one year so that data from the newly deployed monitors can be 

considered in making appropriate designation decisions. Tribes were given an opportunity to 

update their recommendation letters for those remaining areas for our consideration in the second 

round of designations by December 15,2010. The EPA intends to complete the second round of 

lead designations no later than October 14, 2011. Therefore, this letter is the next step in the 

process for completing lead designations by October 14, 2011. 

Consistent with the Clean Air Act, and after carefully considering St. Regis Mohawk Tribe's 

October 16, 2009 recommendation letter and all the associated technical infonnation for the 2008 

Lead National Ambient Air Quality Standards, including the most recent air quality data from 

2008-2010, the EPA is proposing to designate St. Regis Mohawk Tribe as 

unclassifiable/attainment. The EPA uses this designation for initial designations to identify areas 

that have data indicating attainment, or where there is no evidence of a violation. 

If you have additional infonnation that the EPA should consider with respect to our proposed 

modification to your designation recommendation, please submit it to us by August 15, 2011. 

The EPA's preliminary designation decisions and supporting documentation will be made 

available to the general public for review. We will be accepting comments through August 15, 

2011. We will review any infonnation we receive from the St. Regis Mohawk Tribe and the 

general public by this date, and we plan to promulgate the second round of final designations by 

October 14,2011. 

We look forward to a continued dialogue with you and your staff as we work together to 

implement the 2008 Lead National Ambient Air Quality Standards. Should you have any 

questions, please do not hesitate to call me, or have your staff contact Raymond Werner of my 

staff at 212-637-3706. 

Sincerely, 

d(k'-¢

Judith A. Enck 

Regional Administrator 

cc:	 Mr. Ken Jock, Director 

Environment Division 

St. Regis Mohawk Tribe 

412 State Route 37 

Akwesasne, New York 13655 

Mr. Les Benedict, Assistant Director
 

Environment Division
 

St. Regis Mohawk Tribe
 

412 State Route 37
 

Akwesasne, NY 13655