UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX 

75 Hawthorne Street 

San Francisco, CA 94105 

March 1, 2013

Mr. Larry Greene

Air Pollution Control Officer

Sacramento Metropolitan Air Quality Management District

777 12th Street

Sacramento, California 95814

Dear Mr. Greene:

Thank you for your submission of the Sacramento Metropolitan Air Quality Management 

District’s (SMAQMD’s) Annual Monitoring Network Plan in July 2012. Based on the 

information provided in the plan, EPA approves all portions of the network plan except those

specifically identified below. 

Annual network plans are important documents for regulatory purposes (e.g., State 

Implementation Plans, designations and redesignations) and public information, in addition to 

the myriad uses by the air districts. EPA is revising the review process for annual network plans 

to specifically check and document the comprehensive set of items that are required to be 

included in the annual network plans per 40 CFR 58.10 in a consistent manner. We have created 

a checklist that lists all these items and have included it as Attachment A. While the items in the 

checklist are required by EPA regulations, we acknowledge that we have not specifically 

requested some of this information in previous annual network plan reviews. We recognize that 

your plan may not have all the items that we have currently identified and hope to work with you 

on the inclusion of these items in future plans. To facilitate these changes, EPA has provided 

detailed feedback in the checklist where information should be included or revised in next year’s 

plan.

Please note that we cannot approve portions of the annual network plan for which the 

information in the plan is insufficient to judge whether the requirement has been met, or for 

which the information, as described, does not meet the requirements as specified in 40 CFR 

58.10 and the associated appendices. EPA Region 9 also cannot approve portions of the plan for 

which the EPA Administrator has approval authority. Accordingly, we are not acting on the 

specific portions of your agency’s annual network plan listed in Attachment B.

In addition to the checklist and list of specific plan elements where EPA Region 9 is not taking 

action, enclosed are additional detailed comments on the plan (Attachment C). All of the 

comments in Attachments A, B, and C should be addressed in next year’s network plan. If you 
have any questions regarding this letter or the enclosed comments, please feel free to contact me 

at (415) 972-3851 or Kate Hoag at (415) 972-3970.

Sincerely,

/s/

Matthew Lakin, Manager

Air Quality Analysis Office

Enclosures:

A. Annual Air Monitoring Network Plan Checklist

B. Elements where EPA is Not Taking Action

C. Additional Detailed Comments

cc: Brigette Tollstrup, SMAQMD

John Ching, SMAQMD

Karen Magliano, CARB
Attachment B: Annual Air Monitoring Network Plan Items where EPA is Not Taking 

Action

We are not acting on the portions of annual network plans where either EPA Region 9 lacks the 

authority to approve specific items of the plan, or EPA has determined that a requirement is 

either not met or information in the plan is insufficient to judge whether the requirement has 

been met.

 NCore, PAMS, STN, and the plan for NO2 monitoring require EPA Administrator 

approval. Per 40 CFR 58.11(c), NCore, PAMS, and STN network design and changes are 

subject to approval of the EPA Administrator and per 40 CFR 58.10(a)(5) plans for 

establishing NO2 monitoring sites are submitted to the EPA Administrator for action.

Therefore, we are not acting on these items.

 System modifications (e.g., site closures or moves) are subject to approval per 40 CFR 

58.14(c). Information provided in the plan was insufficient for EPA to approve the 

system modifications listed in the plan per the applicable requirement. Therefore, we are 

not acting on the following items as part of this year’s annual network plan:

o Discontinue non-required speciated VOC measurement at Elk-Grove-Bruceville 

Rd PAMS site (fulfilled at Folsom and Sac-Del Paso Manor)

o Del Paso Manor: PM10-Pb

o Del Paso Manor: Replace non-FEM PM2.5 with FEM PM2.5, move non-FEM 

PM2.5 to Sloughhouse Rd

o Del Paso Manor: Shut down nephelometer from special study

o Evaluating closing Sacramento – Goldenland Court, redundant for PAMS and not 

the highest for any criteria pollutant. Would still meet min monitoring req

o North Highlands-Blackfoot way: evaluating shutting down PM10, changing to 

seasonal for O3, CO

o Sacramento Health Dept – Stockton Blvd: will submit a request to terminate 

PM10 TEOM (unuseable due to wintertime negative bias) and PM2.5 FRM 

(redundant w Sacramento-T Street)

o Replace E-BAM at sloughhouse SPM with non-FEM BAM from Del Paso Manor

 EPA identified items in you agency’s annual network plan where a requirement was not 

being met or information in the plan was insufficient to judge whether the requirement 

was being met based on 40 CFR 58.10 and the associated appendices. Therefore, we are 

not acting on of the following items:

Item Checklist Row 

(Attachment A)

Issue

Instrument parameter code for 

each instrument for PM10

FRM/FEM

42 Not meeting requirement 

Sampling Schedule for PM2.5 45 Insufficient information to judge
Sampling Schedule for PM10 46 Insufficient information to judge

PM2.5 expected maximum 

concentration site identified as 

population exposure

55 Insufficient information to judge

Site type for each instrument 41 Insufficient information to judge

Monitoring objective for each 

instrument

40 Insufficient information to judge

Distance from obstructions not 

on roof

68 Insufficient information to judge in some 

instances

Date of last Annual 

Performance Evaluation 

(gaseous)

29 Insufficient information to judge in some 

instances

Dates of last two semi-annual 

flow rate audits for PM 

monitors

30 Insufficient information to judge in some 

instances

Dates of last two semi-annual 

flow rate audits for Pb 

monitors

31 Insufficient information to judge in some 

instances

Scale of representativeness for 

each monitor

16 Insufficient information to judge in some 

instances

Instrument/monitoring method 

code for each monitor

37 Insufficient information to judge in some 

instances

Sampling Schedule for PM10-2.5 48 Insufficient information to judge

Additional information for each of these items is in included in Attachment A.
Attachment C: Additional Detailed Comments

 Per 40 CFR 58 Appendix D, section (2)(e), the EPA Regional Administrator and state or 

local agencies ... “may divide the overall MSA/CSA monitoring responsibilities and 

requirements among the various agencies to achieve an effective network design. Full 

monitoring requirements apply separately to each affected State or local agency in the 

absence of an agreement between the affected agencies and the EPA Regional 

Administrator.” For future plans, please state if an agreement has been made to share 

network design responsibilities for any MSAs in your jurisdiction and attach 

documentation.

 When providing future plans for public comment, please include information (your 

agency’s submittal and EPA’s approval) pertaining to any modifications that were 

approved in the data year covered by the plan (e.g. 2012 changes for the plan submitted 

in 2012.)

 The plan notes that the requirement for an area-wide NO2 site per 40 CFR 58.10(a)(5) is 

met by one of the NO2 sites required for the PAMS network (page 14). In future plans, 

please clarify which of the two PAMS NO2 sites is meeting this requirement.

 The site description on page 53 lists the Sacramento-T Street site as middle scale for all 

pollutants. Please clarify why this is the case, or change the site description and spatial 

scales as appropriate.

 Sacramento-Goldenland Court and Sacramento Health Dept-Stockton Blvd sites both 

have two PM10 monitors. Please include the distance between the PM10 monitors in the 

detailed site table, even if the monitor type for one is not “QA collocated”.

 Please update the description in the table on page 11 for the Sloughhouse Rd site to 

match the information in the detailed site table on page 49.

 The PM2.5 speciation monitor at the Sacramento-T Street site is listed as an SPM 

(Appendix B, page 55), but EPA’s website lists this as a CSN site. Please clarify this in 

your 2013 network plan.