www.ntaatribalair.org 

### N ational Tribal Air Association

928.523.0526 office P.O. Box 15004

928.523.1266 fax Flagstaff, AZ 86011

- 5004



### June 11, 2014 Executive Committee

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

Po a rch Creek Band of Indians

Region 5

Brandy Toft

Vice

- Chairperson

Leech Lake Band of Ojibwe

Bryan Hoover

Lac Du Flambeau Tribe

Region 6

Kelli e 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

O rutsararmuit 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 po licies 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

res pective jurisdictions.

On behalf of the N TAA , 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 Standa rds 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 u ranium milling

and mining op erations 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 po tentia l

impacts on Tribal communities , and subsequently provide comments to EPA

. Given the

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

affected T ribes, we strongl y 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 proc ess by giving the NTAA, member T ribes, and those Tribes indicated on

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

human health considerations embodied in the proposed rule.

Sincere ly,

Bill Thompson

Chairman, NTAA