Air Monitoring Supervisor 

Santa Barbara County Air Pollution Control District 

260 North San Antonio Road, Suite A 

Santa Barbara, California 93110-1315 

Dear Mr. Cordes: 

Thank you for your submission of Santa Barbara County Air Pollution Control District's 

(APCD's) 2013 Annual Air Monitoring Network Plan in July 2013. We have reviewed the 

submitted document based on the requirements set forth under 40 CFR 58. Based on the 

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

specifically identified below. 

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 not delegated approval authority to the regional offices. 

Accordingly, the first enclosure (A. Annual Monitoring Network Plan Items where EPA is Not 

Taking Action) provides a listing of specific items ofyour agency's annual monitoring network 

plan where EPA is not taking action. The second enclosure (B. Additional Items Requiring 

Attention) is a listing of additional items in the plan that EPA wishes to bring to your agency's 

attention. 

The third enclosure (C. Annual Monitoring Network Plan Checklist) is the checklist EPA used to 

review your plan for overall items that are required to be included in the annual network plan 

along with our assessment of whether the plan submitted by your agency addresses those 

requirements. 

The first two enclosures highlight a subset of the more extensive list of items reviewed in the 

third enclosure. All comments conveyed via this letter (and enclosures) should be addressed 

(through corrections within the plan, additional information being included, or discussion) in 

next year's annual monitoring network plan. 

on Papu 
p

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Air Quality Analysis Office 

Enclosures: 

A. Annual Monitoring Network Plan Items where EPA is Not Taking Action 

B. Additional Items Requiring Attention 

C. Annual Monitoring Network Plan Checklist 

cc: Terry Dressler, Director, Santa Barbara County Air Pollution Control District 

Gayle Sweigert, California Air Resources Board 
58.14( c). Information provided in the plan was insufficient for EPA to approve the 

following system modification listed in the plan per the applicable requirement: 

relocation of the Santa Ynez monitoring station. Therefore, we are not acting ori this item 

as part of this year's annual network plan. 

• EPA identified items in your agency's annual monitoring network plan where a 

requirement was not being met or iirl'ormation 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 the following items: 

Item Checklist Row Issue 

(Attachment A) 

Distance from trees 80 Not meeting requirement in one instance 

Scale of representativeness 17 Insufficient information to judge 

Designation of a primary 38 Insufficient information to judge in some 

monitor instances 

Distance of site from nearest 73 Insufficient information to judge in some 

road instances 

PM2.s collocation 37 Insufficient information to judge 

Additional information for each of these items may be found for the row listed il;l column 2, in 

the third enclosure (C. Annual Monitoring Network Plan Checklist). 
74 instead of099. Assuming this is a typo, please correct in next year's plan. 

o The S02, 1 monitor at Lompoc H Street is listed as TEl 431 with method code 

100 instead of060. Assuming this is a typo, please correct in next year's plan. 

o The CO, 3 monitor at Santa Barbara is listed as method code 593 instead of 093. 

Assuming this is a typo, please correct in next year's plan. 

o The CO, 1 monitor at Santa Maria listed as TAPI T300u with method code 067 

instead of093. Assuming this is a typo, please correct in next year's plan. 

• [Item 44] 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." The Plan states that "Santa Barbara County will schedule discussions with CARB to formalize an agreement to share responsibility for air monitoring network 

design within Santa Barbara County." For future plans, please confirm when an 

agreement has been made to share netWork design responsibilities for any MSAs in your 

jurisdiction and attach documentation. 

• [Item 46] Please identify each monitor type within the site tables for next year's plan. 

• [Items 65 & 66] We reconuilend considering the PM2.s network requirement for sites that 

represent area-wide air quality, and the requirement for a site at maximum concentration 

at neighborhood or larger scale during your next network assessment. 
C. ANNUAL MONITORING NETWORK PLAN CHECKLIST 

(Updated 11/26/20 13) 

Year: 2013 

Agency: Santa Barbara County APCD 

40 CFR 58.1 O(a){l) requires that each Annual Network Plan (ANP) include information regarding the following types of monitors: SLAMS 

monitoring stations including FRM, FEM, and ARM monitors that are part of SLAMS, NCore stations, STN stations, State speciation stations, SPM 

stations, and/or, in serious, severe and extreme ozone nonattainment areas, P AMS stations, and SPM monitoring stations. 

40 CFR 58.10(a)(l) further directs that, ''The plan shall include a statement of purposes for each monitor and evidence that siting and operation of 

each monitor meets the requirements of appendices A, C, D, and E of this part, where applicable." On this basis, review of the ANPs is based on the 

requirements listed in 58.10 along with those in Appendices A, C, D, and E. 

EPA Region 9 will not take action to approve or disapprove any item for which Part 58 grants approval authority to the Administrator rather than the 

Regional Administrators, but we will do a check to see if the required information is included and correct. The items requiring approval by the 

Administrator are: P AMS, NCore, and Speciation (STN/CSN). 

Please note that this checklist summarizes many of the requirements of 40 CFR Part 58, but does not substitute for those requirements, nor do its 

contents provide a binding determination of compliance with those requirements. The checklist is subject to revision in the future and we welcome 

comments on its contents and structure. 

Key: 

White = meets the requirement. 

Yellow = requirement is not met, or information is insufficient to make a determination. Action requested in next year's plan or outside tlie ANP 

process. (items listed in Enclosure A) 

·----- , =item requires attention in order to improve next year's plan (items listed in Enclosure B) 

1 
ANP requirement Citation Was the info Does the Notes 

within 40 submitted?1 If information 

CFR58 yes, page #s. provided3 meet 

Flag if the req?4 

incorrecf? 

1. Submit plan by July 151 58.10 (a)(l) Yes Yes 

2. Statement of purpose for each monitor 58.10 (a)(1) Yes, Table 1.3 Yes 

3. 30-day public comment I inspection period' 58.10 (a)(l), Yes Yes 

58.10 (a)(2) 

4. Modifications to SLAMS network- case when we are 58.10 (a)(2) Yes, pl5, 39 Yes 

not approving actual system modifications (i.e., we 58.10(e) 

will do it outside the ANP process6

) 

5. Modifications to SLAMS network- case when we are 58.10 (a)(2) Yes Insufficient to SBAPCD plans to move the Santa Ynez SLAMS site 

approving actual system modifications per 58.14(c) 58.10 (b)(5) judge to a new location to meet siting requirements within 

58.10(e) the next 18 months and installation of equipment has 

58.14 (c) begun at the new site. Please submit details of 

proposed move/modifications to EPA Region IX for 

approval showing that conditions of 40 CFR58.14( c) 

are met for the new site, and coordinate with EPA to 

discuss data collected at the site to date. 

Note that proposed modifications listed in ANP 

(other than as described above) do not require 

approval (i.e., modifications were made to replace 

FEMIFRM PMIO monitors to other FEMIFRM 

monitors which do not require approval). 

6. Does plan include documentation (e.g., attached NA NA No system modifications requiring approval were 

approval letter) for system modifications that have reported for the period since last ANP. 

been approved since last ANP approval? 

7. NCore site operational (by 1/1/2011) 58.10 (a)(3) NA NA No requirement 

8. Pb site for 0.5-1.0 tpy sources operational (by 58.10 (a)(4) NA NA -- No requirement 

1 Response op~ons: NA (Not Applicable), Yes, No, Incomplete, Incorrect. The responses "Incomplete" and "Incorrect" assume that some information has been provided. 2 To the best of our knowledge. 

3 Assuming the information is correct 4 Response options: NA (Not Applicable)- [reason], Yes, No, Insufficient to Judge. 

5 The affected state or local agency must document the process for obtaining public comment and include any comments received through the public notification process within 

their submitted plan. 

6 See 58.14(c) 

2 

I 

I 
ANP requirement Citation Was the info Does the Notes 

within 40 submitted?1 If information 

CFR58 yes, page #s. provided3 meet 

Flag if the req?4 

incorrecf? 

12/27/2011)_ 

9. N02 plan for area-wide and RA40 sites submitted by 58.10 (a)(5) NA NA No requirement 

711/2012 

10. N~ area-wide and RA40 sites operational by 58.10 (a)(5) NA NA 

1/1/2013 

11. N~ plan for near-road sites submitted b_y 7/1/2013 58.10 00(5)_ NA NA No requirement 

12. so2 sites operational (by 111/2013) 58.10 (a)(6) . Yes, p12-13 Yes 

and 58.13(d) 

13. AQS site identification number for each site 58.10 (b)(1) Yes Yes 

Pages: in detailed 

site information 

14. Location of each site: street address and geographic 58.10 (b)(2) Yes Yes 

coordinates Pages: in detailed 

site information 

15. Sampling and analysis method(s) for each measured 58.10 (b)(3) Yes Yes 

parameter Pages: in detailed 

site information 

16. Any proposals to remove or move a monitoring 58.10 (b)(5) Yes, p15, 39 Yes See #5 above. SBAPCD plans to move the Santa 

station within a period of 18 months following plan Ynez SLAMS site to a new location to meet siting 

submittal requirements within the next 18 months. 

17. Scale of representativeness for each monitor as 58.10(b)(6); Yes in most cases; Yes in most cases; Santa Barbara SLAMS site N02 monitor is listed as 

defmed in Appendix D AppD potentially insufficient to judge urban scale/ highest concentration. This combination 

incorrect for cases listed in is not typically suitable according to 40 CRF Part 58 

information in notes due to cases Appendix D, Table D-1. 

cases listed in notes that are potentially 

p9 incorrect or require Lompoc H St PM monitors are listed as 

justification as an Neighborhood Scale/Population Oriented sites. The 

exception nearest road has I OK daily traffic and the monitors 

·are 13m from road, and probe is 7m height. 

According to 40 CFR Part 58 Figure E-1, this 

distance should listed as micro or middle scale for 

certain pollutants. 

El Capitan PM-I 0 monitor is listed as a Regional 

Scale/Background Level site. The nearest road has 

50K daily traffic and the monitor is I OOm from road. 

According to 40 CFR Part 58 Figure E-1, this site 

·-- ---- ---- - ·--- L_ ___ --- - L__sbould be categorized as Neighborhood scale for 

3 
ANP requirement Citation Was the info Does the Notes 

within 40 submitted?1 H information 

CFR58 yes, page #s. provided3 meet 

Flag if the req?4 

incorrecf? 

certain pollutants. 

18. Identification of sites suitable and sites not suitable 58.10 (bX7) Yes,p 13,17 Yes Santa Barbara and Santa Maria have FEM samplers ! 

for comparison to the annual PM2.s NAAQS as for regulatory monitoring. Lompoc H Street and ' 

described in Part 58.30 Goleta do not meet FEM requiremen~. so are nonregulatory monitors. 

19. MSA, CBSA, CSA or other area represented by the 58.10 (b)(8) Yes,plO Yes Representative area for all sites is Santa Barbaramonitor Pages: in detailed Santa Maria MSA. 

site information 

20. Designation of any Pb monitors as either source- 58.10 (b)(9) N/A N/A No requirement 

oriented or non-source-oriented 

21. Any source-oriented Pb site for which a waiver hal! 58.10 (bX10) N/A N/A No requirement 

been granted by EPA RA 

22. Any Pb monitor for which a waiver has been 58.10 (b){ll) N/A N/A No requirement 

requested or granted by EPA RA for use ofPb-PM10 

in lieu ofPb-TSP 

23. Identification of required N02 monitors as either near- 58.10 (b)(12) N/A N/A 

road or area-wide 

24. Identification of any PM2.s FEMs and/or ARMs not 58.10 (b)(13) N/A . N/A 

eligible to be compared to the NAAQS (Note 1: must 58.11 (e) 

include required data assessment) (Note 2: Required 

SLAMS must monitor PM2•5 with NAAOScomparable monitor at the required sample 

frequency.) 

25. For SPMs listed as non-regulatory, note the start Date 58.20(c) N/A N/A 

ofFRMIFEM/ARM at SPM. If> 24 months, and 

monitor is eligible for comparison to the NAAQS per 

58.11 (e) and 58.30, the agency must supply 

information that App A, C orE requirements were not 

met 

26. Document how states and local agencies provide for 58.10 (c) Yes, pl7 Yes 

the review of changes to a PM2.s monitoring network 

that impact the location of a violating PM2.s monitor. 

27. Does the plan include a request for approval for and 58.11 (a) (2) N/A N/A 

alternative to appendix A requirements for SPMs 

opemting_ a FRMIFEM/ ARM which also meets 

4 
ANP requirement Citation Was the info Does the Notes· 

within 40 submitted?1 If information 

CFR58 yes, page #s. provided3 meet 

Flag if the req?4 

incorrecf? 

appendixE? 

28. Precision/ Accuracy reports submitted to AQS 58.16(a); Yes, p18 Yes 

AppA,l.3 

and 5.1.1 

29. Annual data certification submitted 58.15 Yes,p18 Yes ' 

App.A i 1.3 

30. Frequency of flow rate verification for manual PM AppA3.3.2 Yes Yes VAFB STS PMlO site table records the frequency of 

samplers audit Pages: in detailed flow rate verification is for automated PM samplers 

site information instead of manual samplers. Assuming this is a typo, 

please correct in next _year's plan. 

31. Frequency of flow rate verification for automated PM AppA3.2.3 Yes Yes 

analyzers audit Pages: in detailed 

site information 

32. Frequency of on~-point flow rate verification for Pb App A 3.3.4.1 N/A N/A 

samplers audit 

33. Frequency of one-point QC check (gaseous) App.A3.2.1 Yes Yes 

Pages: in detailed 

site information 

34. Date of last Annual Performance Evaluation App.A3.2.2 Yes Yes 

(gaseous) Pages: in detailed 

site information 

35. Dates of last two semi-annual flow rate audits for PM AppA, 3.2.4 Yes Yes 

monitors and3.3.3 Pages: in detailed 

site information 

36. Dates oflast two semi-annual flow rate audits for Pb App A 3.3.4.1 N/A N/A 

monitors 

37. PM2.s collocation AppA3.2.5 No N/A-PQAO SBAPCD is part of the ARB PQAO, and relies on 

requirement the entire PQAO network to satisfy collocation 

requirements. It is ARB's responsibility to show that 

this requirement is met. ARB is currently working 

on a network document that should address this. 

38. Designation of a primary monitor if there is more than Need to No Insufficient to Please specify which PM10 monitor is the primary 

one monitor for a pollutant at a site. determine judge monitor at El Capitan in next year's plan. 

collocation 

39. Distance between collocated monitors (Note: waiver App.A N/A N/A 

request or the date of previous waiver approval must 3.2.5.6 and 

be included if the distance deviates from 3.2.6.3 --- -- -- ----

5 
ANP requirement Citation Was the info Does the Notes 

within40 submitted?1 If information 

I CFR58 yes, page #s. provided3 meet 

Flag if the req?4 

incorrecf? 

requirement.) 

40. Manual PM10 method collocation met? (note: AppA3.3.1 Yes,p20 Yes 

continuous PM10 does not have this requirement) 

41. Pb collocation App A 3.3.4.3 N/A N/A 

42. PM1a-2.s collocation (note: only applies to Fresno and App A3.3.6 N/A N/A 

Phoenix NCore sites) 

43. Instrument/monitoring method code for each monitor: App C 2.4.1.2 Yes Yes for most cases; The N02, I monitor at Lompoc H Street is listed as 

is it reported properly? Is it reported correctly (i.e., Pages: in detailed Insufficient to TAPI 200e with method code 74 instead of099. 

appropriate method code for regulatory monitors)? site information judge or incorrect Assuming this is a typo, please correct in next year's 

in certain cases - plan. 

see Notes 

The S02, I monitor at Lompoc H Street is listed as 

TEl 431 with method code I 00 instead of 060. 

Assuming this is a typo, please correct in next year's 

plan. 

The CO, 3 monitor at Santa Barbara is listed as 

method code 593 instead of093.Assuming this is a 

typo, please correct in next year's plan. 

The CO, I monitor at Santa Maria listed as T API 

T300u with method code 067 instead of 093. 

Assuming this is a typo, please correct in next year's 

plan. 

44. For agencies that share monitoring responsibilities in AppD2(e) Yes, p4 Yes 

an MSA/CSA: does each affected State or local 

agency meet full monitoring requirements or is 

an agreement between the affected agencies and the 

EPA Regional Administrator in place? 

45. Start date for each monitor Required to Yes Yes 

determine if Pages: in detailed 

otherreq. site information 

(e.g., min# 

· and colloc) 

are met 

46. Instrument monitor type for each monitor Required to Yes, p7 Yes It would be helpful to identify each monitor type 

detennine if within the site tables for next year's plan. 

otherreq. - - -

6 
ANP requirement Citation Was 

t

he info 

·n oes the Notes 

within 40 

s

ubmitted?1 H information 

·CFR58 yes, page #s. provided3 meet Flag if the req?4 

incorrecf? 

(e.g., min# 

and colloc) 

are met 

47. Monitoring objective for each instrument AppD 1.1 Yes Yes 

58

.10 (bX6) Pages: in detailed 

site information 

48. Site type for each instrument AppD 1.1.1 Yes, p9 Yes 

49. Instrument parameter code for each instrument Required to Yes Yes 

determine if Pages: in detailed 

I otherreq. site information 

(e

.g., min# 

and colloc) 

are met 

50. Instrument parameter occurrence code for each Required to Yes Yes 

instrument determine if Pages: in detailed 

otherreq. site information 

(e.g., min# 

and colloc) 

are met 

51. Sampling season for ozone (note: date of waiver 58.10 (b)(4) Yes Yes All Year 

approval must be included if the sampling season App D, 

4

.l(i) Pages: in detailed 

deviates from requirement) site information 

52. Sampling schedule for PM

2.s 

- applies to year-round 58.10 (b)(4) Yes Yes 

and seasonal sampling schedules (note: date of waiver 58

.12(d) Pages: in detailed 

approval must be inc

luded if the sampling season . AppD4.7 

s

ite information 

deviates from requirement) EPA 

flowchart 

53. Sampling schedule for PM10 58.10 (b)(4) Yes Yes 1 :6 day 

required. I 

58.12(e) 

AppD4.6 

54. Sampling schedule for Pb 58

.10 (b)(4) N/A N/A 

58.12(b) 

AppD4.5 

55. Sampling schedule for PM1a-2

.s 58.10 (b)(4) N/A N/A 

58.12(f) 

AppD4.8 

56. Minimum# of monitors for 

0 3 [Note: should be App D, 4.1(a) Yes, p10-

11 Yes Two sites required 

7 
ANP requirement Citation Was the info Does the Notes 

within 40 submitted?1 H information 

CFR58 yes, page #s. provided3 meet 

Flag if the req?4 

incorrect2

? 

supported by MSA ID, MSA population, DV, # and 

monitors, and # required monitors] (see footnote) 7 TableD-2 

57. Identification of max. cone. 0 3 monitor(s) App D 4.1_@ Yes,p25 Yes 

58. Minimum monitoring requirements met for near-road AppD4.3.2 Yes,p12 Yes No sites are required per regulation. 

N02 (2014 start date) 

59. Minimum monitoring requirements met for area-wide AppD4.3.3 Yes,p12 Yes No sites are required per regulation. 

N02 

60. Minimum monitoring requirements met for RA-40 AppD4.3.4 Yes,.p12 Yes No sites are required per regulation. 

N02 

61. Minimum monitoring requirements met for so2 AppD4.4 Yes,p13 Yes 

[Note: Only monitors considered to be required 

SLAMs are eligible to be counted towards meeting 

minimum monitoring requirements.] 

62. Minimum monitoring requirements met for Pb [Note: AppD4.5 Yes,p14 Yes No sites are required per regulation. 

Only monitors considered to be required SLAMs are 58.13(a) 

eligible to be counted towards meeting minimum 

monitoring requirements.] 

63. Minimum # of moriitors for PM2.s [Note 1: should be AppD, Yes, p13-14 Yes No sites are required, but have 2 sites in operation 

supported by MSA ID, MSA population, DV, # 4.7.1(a) and (Santa Barbara and Santa Maria). 

monitors, and# required monitors] [Note 2: Only TableD-5 

monitors considered to be required SLAMs are 

eligible to be counted towards meeting minimum 

monitoring requirements.] 

64. Optional PM2.

5 Network Clarifications: Provide a list Need to N/A N/A 

of required sites if it does not include all SLAMS. assess several 

[Note: default will assume all SLAMS are considered requirements 

required sites.] 

65. Required PM2.

5 sites represent area-wide air quality AppD N/A N/A There are no required PM2.s sites per minimum 

4.7.l(b) monitoring requirements. Recommend considering 

this. requirement with the next network assessment. 

66. For PM2.s, is at least one site at neighborhood or AppD N/A N/A No sites are required; therefore this requirement is 

larger scale in an area of expected maximum 4.7.1(b)(l) not applicable. Recommend considering this 

concentration requirement with the next network assessment. 

67. If additioJ!al SLAMS PM2.s required, ~-~re a site in AppD N/A N/A There are no required PM2.s sites per minimum 

7 Only monitors considered to be required SLAMs are eligible to be counted towards meeting minimum monitoring requirements. In addition, ozone monitors that do not meet 

traffic count/distance requirements to be neighborhood scale ( 40 CFR 58 Appendix E, Table E-1) cannot be counted towards minimum monitoring requirements. 

8 

~ 
ANP requirement Citation Was the info Does the Notes 

within 40 submitted?1 H information 

CFR58 y~s, page #s. provided3 meet 

Flag if the req?4 

incorrecf? 

an area of poor air quality 4.7.l(b)(2) monitoring r~uirements. 

68. Minimum monitoring requirements for continuous AppD4.7.2 N/A N/A There are no required PM2.s sites per minimum 

PM2.s monitoring requirements. 

69. Requirements for PM2.s background and transport AppD4.7.3 N/A N/A- State level 

sites 

70. Are PM2.s Chemical Speciation requirements met for AppD4.7.4 N/A N/A ·There are no official CSN sites in Santa Barbara 

official STN sites? County. 

71. Minimum # of monitors for PM10 AppD,4.6 Yes,pl3 Yes Required sites = 0-1. 

(a) and Table 

D-4 . . 72. Minimum monitoring requirements met for PM11,.2.s AppD4.8 N/A N/A This requirement applies to NCore only and there are 

mass no NCore sites in Santa Barbara County. 

73. Distance of site from nearest road AppE6 Yes Yes in most cases - UCSB West Campus does not include nearest road 

Pages: in detailed insufficient to information. Please clarify in next year's plan. 

site information judge; see scale 

issues in 17 

74. Traffic count of nearest road AppE Yes Yes 

Pages: in detailed 

site information 

75. Groundcover AppE 3(a) Yes Yes 

I Pages: in detailed 

site information 

76. Probe height AppE2 Yes Yes 

Pages: in detailed 

site information 

77. Distance from supporting structure AppE2 Yes Yes 

Pages: in detailed 

site information 

78. Distance from obstructions on roof AppE4(b) Yes Yes 

Pages: in detailed 

site information 

79. Distance from obstructions not on roof AppE4(a) · Yes Yes 

Pages: in detailed 

site information 

80. Distance from trees AppES Yes No Santa Ynez site is currently Sm from trees. SBAPCD 

Pages: in detailed is looking into relocating the site in next 18 months 

site information (see_#4). ---- --- -----·--

9 
ANP requirement Citation Was the info 

within 40 submitted?1 If 

CFR58 yes, page #s. 

Flag if 

incorrecf? 

81. Distance to furnace or incinerator flue App E 3'(b) Yes 

Pages: in detailed 

site information 

82. Unrestricted airflow AppE,4(a) Yes 

and4(b) Pages: in detailed 

site information 

83. Probe material (if applicable) AppE9 Yes 

Pages: in detailed 

site information 

84. Residence time (if applicable) AppE9 Yes 

Pages: in detailed 

site information 

Public Comments on Annual Network Plan 

Were comments submitted to the S/Lff agency during the public comment period? No. 

If no, skip the remaining questions. 

If yes: 

• Were any of the comments substantive? 

o If yes, which ones? 

Does the 

information 

provided3 meet 

the req?4 

Yes 

Yes 

Yes 

Yes 

----

o Explain basis for determination if any comments were considered not substantive: 

• Did the agency respond to the substantive comments? 

o If yes, was the response adequate? 

Notes 

360 degrees at all sites for all monitors 

• Do the substantive comments require separate EPA response (i.e., agency response wasn't adequate)? 

• Are the sections of the annual network plan that received substantive comments approvable after consideration of comments? 

o If yes, provide rationale: 

I 

10