UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 2 290 BROADWAY NEWYORK, NY 10007-1866



## JUN 1 4 2011

ChiefMonica Jacobs ChiefMark 

### H. Garrow ChiefRandy Hart St. Regis MohawkTribe 412 State Route 37 Akwesasne, New York 13655

Dear ChiefMonicaJacobs, Dear ChiefMark 

### H. Garrow, Dear ChiefRandy Hart:

Thank you for your October 16, 2009 recommendations onair quality designations for the revised National Ambient Air Quality Standards for lead on behalfofSt. Regis Mohawk Tribe. This letter is to notify you ofthe U.S. Environmental Protection Agency's (EPA's) preliminary decision to designate St. Regis MohawkTribe 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 importantpart ofthe EPA's commitmentto a clean, healthy environment. Lead exposure can cause a range ofadverse health effects, mostnotably in children. Exposures to lowlevels oflead 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 AmbientAir Quality Standard by**lowerin~** it from 1.5 microgramsper cubic meter (llg/m3)

- a level set in 1978

- to a level of0.15 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 increasedprotection against lead-related environmental and other welfare effects, the EPA revised the secondaryNational 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 criteriafor siting ambient lead monitors and newdatacollectionrequirements. Monitors meeting the new network siting requirements
were to begin operation January 1,2010.

Within two years ofpromulgating new or revised National Ambient Air Quality Standards, the Clean Air Act requires the EPA to complete the initial process ofidentifying ordesignating areas that meet or do notmeet an air quality standard. Ifthe Administrator has insufficient information to make these designations, the EPA has the authorityto extend the designationprocess by up to
one year. In light ofthe new monitoring network, the EPA is completing the lead designations in two rounds. In the first round, completed onNovember 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-2010 monitoring network. For all other areas, the EPA extended the

InternetAddress (URL). http://www.eps.gov Recycled/Recyclable.Printed with V&gll1ablll 011 Bend Inltaon Recycilld Paper (Minimum 50% Poslconsumer content)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 ofdesignations 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 CleanAir Act, and after carefully considering St. Regis Mohawk Tribe's October 16, 2009 recommendation letter and all the associated technical infonnationfor the 2008 Lead National Ambient Air Quality Standards, including the mostrecent air quality datafrom 2008-2010, the EPA is proposing to designate St. Regis Mohawk Tribe as unclassifiable/attainment. TheEPA uses this designation for initial designations to identify areas that have data indicating attainment, or where there is no evidence ofa violation.

Ifyou have additional infonnation that the EPA should consider with respect to ourproposed modification to your designation recommendation, please submit it to us by August 15, 2011. The EPA'spreliminary 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 infonnationwe receive from the St. Regis MohawkTribe and the general public by this date, and we planto promulgate the second round offinal designations by October 14,2011.

We look forward to a continued dialogue with you and your staffas we work together to implement the 2008 LeadNational Ambient Air Quality Standards. Should you have any questions, please do not hesitate to call me, or have your staffcontact Raymond Werner ofmy staffat 212-637-3706.
Sincerely,

# d(k'-¢ Judith A. Enck Regional Administrator

cc: Mr. Ken Jock, Director Environment Division St. Regis MohawkTribe 412 State Route 37 Akwesasne, New York 13655

Mr. Les Benedict, Assistant Director Environment Division St. Regis MohawkTribe 412 State Route 37 Akwesasne, NY 13655