www.ntaatribalair.org National Tribal Air Association

928.523.0526 office P.O. Box 15004

928.523.1266 fax Flagstaff, AZ 86011-5004

Executive Committee June 11, 2014

Region 1

Bill Thompson

Chairperson

Penobscot Nation

Region 2

Angela Benedict-Dunn

Secretary

Saint Regis Mohawk Tribe

Region 4

Katie Tiger

Eastern Band of Cherokee Indians

Ralph McCullers

Poarch Creek Band of Indians

Region 5

Brandy Toft

Vice-Chairperson

Leech Lake Band of Ojibwe

Bryan Hoover

Lac Du Flambeau Tribe

Region 6

Kellie Poolaw

Pawnee Nation of Oklahoma

Tammy Belone

Pueblo of Jemez

Region 7

Joseph Painter

Winnebago Tribe of Nebraska

Matthew Malimanek

Santee Sioux Nation of Nebraska

Region 8

Randy Ashley

Confederated Salish & Kootenai 

Tribes

Linda Weeks Reddoor

Fort Peck Assiniboine-Sioux Tribes

Region 10

Kevin Greenleaf

Kootenai Tribe of Idaho

Twa-le Swan

Spokane Tribe

Alaska

Rosalie Kalistook

Treasurer

Orutsararmuit Native Council

Sue Flensburg

Bristol Bay Native Association

June 13, 2014

Reid J. Rosnick

Office of Radiation and Indoor Air

Radiation Protection Division

U.S. Environmental Protection Agency 

Via email to rosnick.reid@epa.gov

Dear Mr. Rosnick,

The National Tribal Air Association (NTAA) is an autonomous organization with 80 

principal member Tribes. The organization’s mission is to advance air quality 

management policies and programs, consistent with the needs, interests, and unique legal 

status of Indian Tribes. As such, the NTAA uses its resources to support the efforts of all 

federally recognized Tribes in protecting and improving the air quality within their 

respective jurisdictions. 

On behalf of the NTAA, I am writing to request that EPA extend the public comment 

period for the proposed rule issued in the Federal Register on May 2, 2014, which would 

revise Subpart W of 40 CFR Part 61, “National Emission Standards for Operating 

Uranium Mill Tailings”. Specifically, the NTAA is requesting the maximum comment 

extension period of 120 days. 

This rule addresses both conventional uranium milling operations as well as future 

extraction activities, namely in-situ leach/recovery (ISL) sites. Domestic uranium milling 

and mining operations to date have left in their wake a disturbing legacy of environmental 

injustice in Indian Country. As a national organization whose mission it is to advance air 

quality management and policies for federally recognized Tribes, it is only prudent that

NTAA thoroughly evaluate the consequences of the proposed rule, including the potential

impacts on Tribal communities, and subsequently provide comments to EPA. Given the 

serious complexity of the proposed rule, as well as the wide ranging implications for 

affected Tribes, we strongly request that you grant the aforementioned extension. 

For our part, NTAA was only made aware of the proposed rule within the last two weeks. 

The public comment extension will help to promote a just and equitable public 

participation process by giving the NTAA, member Tribes, and those Tribes indicated on 

EPA’s consultation list adequate time to examine the complex science and the associated 

human health considerations embodied in the proposed rule.

Sincerely,

Bill Thompson 

Chairman, NTAA