UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX 

75 Hawthorne Street 

San Francisco, CA 94105 

April 18, 2013

Dr. Matt Miyasato, Deputy Executive Officer 

Science and Technology Advancement 

South Coast Air Quality Management District 

21865 Copley Drive 

Diamond Bar, California 91765-4178 

Dear Dr. Miyasato:

Thank you for your submission of the South Coast Air Quality Management District’s 2012

Annual Air Quality 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 either in a resubmitted 2012 network 

plan or 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 Meredith Kurpius at 

(415) 947-4534.

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: Jason Low, South Coast Air Quality Management District

Rene Burmudez, South Coast Air Quality Management District

Karen Magliano, California Air Resources Board
1

Attachment A: Annual Air Monitoring Network Plan Checklist

Year: 2012

Agency: South Coast AQMD

40 CFR 58.10(a)(1) 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, PAMS stations, and SPM monitoring stations.

40 CFR 58.10(a)(1) 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: PAMS, NCore, Speciation (STN/CSN), and NO2 requirements including near road, area-wide, and RA40.

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 and no action requested

Yellow = does not meet or cannot judge the requirement – action requested in next year’s plan or outside the ANP process

Green = meets the requirement but action requested to improve next year’s plan
2

ANP requirement Citation 

within 40 

CFR 58

Was the info 

submitted?1If 

yes, page #s. 

Flag if 

incorrect2?

Does the 

information 

provided3 meet 

the req?

4

Notes 

1. Submit plan by July 1st 58.10 (a)(1) Yes – submitted 

7/13/2012 per 

cover letter and 

email.

Yes – network plan 

was submitted, 

although it was 12 

days late.

2. Statement of purpose for each monitor 58.10 (a)(1) Yes with some 

incorrect 

information

Pages 19-20 

(Tables 3-4)

Incorrect: Some 

information does 

not match detailed 

site reports

Yes Tables 3-4 have a heading that indicates that the 

information includes “Monitoring Purpose.” The 

information that is given is actually site type. The 

site type could be used with the monitoring 

objective to define the Statement of Purpose but 

the current network plan conflates these various 

terms, which have specific CFR definitions (see 

EPA’s May 2012 ANP memo).

Note: Detailed site reports list “monitor objective” 

which should really be “site type”

3. 30-day public comment / inspection period558.10 (a)(1), 

58.10 (a)(2)

Yes

Page 1

Yes

4. Modifications to SLAMS network – case when we are 

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

will do it outside the ANP process6)

58.10 (a)(2)

58.10(e)

Yes

Pages 10-13

Yes Does not constitute approval of changes

5. Modifications to SLAMS network – case when we are 

approving actual system modifications per 58.14(c)

58.10 (a)(2)

58.10 (b)(5)

58.10(e)

58.14 (c)

N/A N/A Not judging modifications per 58.14 since not 

enough information was provided.

6. Does plan include documentation (e.g., attached 

approval letter) for system modifications that have 

been approved since last ANP approval?

Yes

Page 1

Yes No new sites or sites closed in 2012 so no 

documentation for system modification needed.

7. NCore site operational (by 1/1/2011) 58.10 (a)(3) Yes

Page 9

Yes

 

1 Response options: 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)
3

ANP requirement Citation 

within 40 

CFR 58

Was the info 

submitted?1If 

yes, page #s. 

Flag if 

incorrect2?

Does the 

information 

provided3 meet 

the req?

4

Notes 

8. Pb site for 0.5-1.0 tpy sources operational (by 

12/27/2011)

58.10 (a)(4) Incomplete

Page 5

Incomplete It’s not clear which requirements the particular 

sites are meeting (e.g., area-wide, > 1tpy, 0.5-1 

tpy) so the information is insufficient to judge the 

requirement.

9. NO2 plan for area-wide and RA40 sites submitted by 

7/1/2012

58.10 (a)(5) No N/A – HQ approval EPA did not request RA40 sites prior to ANP due 

date.

10. NO2 plan for near-road sites submitted by 7/1/2012 58.10 (a)(5) No – incomplete

Pages 10-12

N/A – HQ approval Information was not detailed enough to approve 

the required NO2 near-road sites. A separate plan, 

outside the ANP process will be required to fulfill 

this req.

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

Page 17 (Table 1)

Plus App B – under 

“Detailed Site 

Information”

Yes

12. Location of each site: street address and geographic 

coordinates

58.10 (b)(2) Yes

App B – under 

“Detailed Site 

Information”

Yes

13. Sampling and analysis method(s) for each measured 

parameter

58.10 (b)(3) Yes for most cases. 

There are few cases 

where incorrect or 

incomplete 

information was 

provided in the 

detailed site tables 

– these are listed in 

the notes.

App B – under 

“Detailed Site 

Information”

Yes -Lake Elsinore: Start date listed for analysis 

method for NO2.

-Reseda: Analysis method for PM2.5 non-FEM 

BAM should be "beta attenuation" - see Riverside 

– Magnolia

-W. LA: There is a TSP sampler that is listed as 

"Tisch" for instrument/manufacturer/model and 

ICPMS for analysis method - is this Pb? It is not 

clear what pollutant is being measured due to the 

incomplete pollutant description and sampling and 

analysis method information.

14. Operating schedule for each monitor (see items 44-48) 58.10 (b)(4) Yes

App B – under 

“Detailed Site 

Information”

Insufficient to 

judge for PM2.5 

and PM10

See items 45 and 46 of this checklist.

15. Any proposals to remove or move a monitoring 58.10 (b)(5) Yes Yes App B has 18 month timeframe
4

ANP requirement Citation 

within 40 

CFR 58

Was the info 

submitted?1If 

yes, page #s. 

Flag if 

incorrect2?

Does the 

information 

provided3 meet 

the req?

4

Notes 

station within a period of 18 months following plan 

submittal

Page 10;

App B – under

“Detailed Site 

Information”

16. Scale of representativeness for each monitor as 

defined in Appendix D

58.10(b)(6); 

App D

Yes in most cases. 

Incomplete 

information for the 

sites listed in the 

notes.

Page 18 (Table 2);

App B – under 

“Detailed Site 

Information”

Yes in most cases. 

There some cases 

listed in the notes 

where the 

information 

provided is 

insufficient to 

judge the 

requirement.

-LAX Hastings: Middle scale is listed for O3 but 

middle scale is not typically an appropriate scale 

for O3 (see 40 CFR 58, App. D, Section 4.1(c)). 

-Long Beach (North): See LAX Hastings for O3.

PM10 listed as middle scale in detailed site sheet 

but micro-scale in Table 2. PM2.5 manual monitor 

listed as neighborhood scale but PM2.5 FEM 

BAM listed as middle scale for the same site –

these should be the same scale.

Perris: Neighborhood scale is listed for ozone. 

Traffic counts and distance are given for arterial 

road - which is closest - but not for fwy 215 which 

is also very close. Scale for ozone may not be 

appropriate given distance to fwy 215, which has 

79,617 AADT. Distance to fwy 215 would have to 

be >100m.

-Pico Rivera: ANP says traffic count is given for 

arterial road but not for San Gabriel Pkwy. Given 

proximity to San Gabriel Pkwy., distance and 

traffic count are needed to judge appropriateness 

of ozone scale.

-Pomona: see comment for LAX Hastings.

-Riverside: NO2 listed as US in Table 2 but NS in 

App. B.

-Rubidoux: Are the non-NCore CO and NO2

instruments closer to the road? If both CO 

instruments have same source mix then they 

should have the same scale.

-W. LA: The TSP pollutant analyzed by ICPMS 

appears to be Pb but scale for Pb is not given in 

Table 2.

17. Identification of sites suitable and sites not suitable 58.10 (b)(7) Yes for most cases. Yes for most cases. -Anaheim: Even when FEM BAMS are co-located 
5

ANP requirement Citation 

within 40 

CFR 58

Was the info 

submitted?1If 

yes, page #s. 

Flag if 

incorrect2?

Does the 

information 

provided3 meet 

the req?

4

Notes 

for comparison to the annual PM2.5 NAAQS as 

described in Part 58.30

In correct 

information for the 

sites listed in the 

notes.

Page 7;

App B – under 

“Detailed Site 

Information”

Incorrect 

information should 

be corrected.

with a primary manual sampler, these data could 

potentially be used for comparison to the annual 

NAAQS if the primary monitor is down since 

FEM BAM data would be automatically 

substituted. Recommend changing App B tables to 

Yes for FEM BAMS with a footnote indicating 

that regulatory data is collected by the manual 

sampler unless the manual sampler has missing 

data. Also, suggest N/A for SASS samplers.

-Azusa: suggest “N/A” instead of “no” for VOC.

-Banning: suggest “N/A” instead of “no” for nonFEM BAM.

-Burbank: See Anaheim note and also note 

incorrect FRM frequency listed.

-Lake Elsinore: see Banning.

-Long Beach (North): See Anaheim

-South Long Beach: See Anaheim

-LA Main: See Anaheim. Also suggest NA for 

PM10 rather than “no.”

-Rubidoux: suggest “N/A” instead of “no” for 

PM10 BAM.

-W. LA: suggest “N/A” instead of “no” for TSP.

18. MSA, CBSA, CSA or other area represented by the 

monitor

58.10 (b)(8) Yes for most cases. 

There are a few 

instances of 

incomplete 

information listed 

in the notes.

Yes for most cases. 

Incomplete 

information should 

be completed.

-ATSF: Identify area as MSA (vs. CSA or other 

type of area) – see Anaheim for example.

-Closet World (Quemetco): same as ATSF.

-Long Beach (North): same as ATSF.

-Rehrig: same as ATSF

-Uddeholm: same as ATSF

-Upland: same as ATSF

19. Designation of any Pb monitors as either sourceoriented or non-source-oriented58.10 (b)(9) No Insufficient to 

judge

It’s not clear which requirements the particular 

sites are meeting (e.g., area-wide, > 1tpy, 0.5-1 

tpy).

20. Any source-oriented Pb site for which a waiver has 

been granted by EPA RA

58.10 (b)(10) NA NA

21. Any Pb monitor for which a waiver has been 

requested or granted by EPA RA for us of Pb-PM10 

58.10 (b)(11) NA NA
6

ANP requirement Citation 

within 40 

CFR 58

Was the info 

submitted?1If 

yes, page #s. 

Flag if 

incorrect2?

Does the 

information 

provided3 meet 

the req?

4

Notes 

in lieu of Pb-TSP

22. Document how states and local agencies provide for 

the review of changes to a PM2.5 monitoring network 

that impact the location of a violating PM2.5 monitor.

58.10 (c) No Insufficient to 

judge

This information was not provided.

23. Precision/Accuracy reports submitted to AQS 58.16(a);

App A, 1.3 

and 5.1.1

No Insufficient to 

judge

This information was not provided.

24. Annual data certification submitted 58.15

App. A 1.3

No Insufficient to 

judge

This information was not provided.

25. Frequency of flow rate verification for manual PM 

samplers audit

App A 3.3.2 Yes for most cases. 

Incorrect 

information for one 

site (see notes).

App B – under 

“Detailed Site 

Information”

Yes for most sites. 

Correct incorrect 

information.

-Lake Elsinore: PM10 TEOM should be NA for 

this.

26. Frequency of flow rate verification for automated PM 

analyzers audit

App A 3.2.3 Yes Yes

27. Frequency of one-point flow rate verification for Pb

samplers audit

App A 

3.3.4.1

Yes for some 

cases, incomplete 

for cases listed in 

the notes.

App B – under 

“Detailed Site 

Information”

Yes for cases 

where information 

was complete. 

Insufficient to 

judge for 

incomplete 

information.

-Closet World (Quemetco): the frequency of the 

flow rate verification was not provided. For ATSF 

this information was given under “manual PM 

samplers”.

-South Long Beach: see Closet World.

-Rehrig: see Closet World.

-Van Nuys Airport: See Closet World.

28. Frequency of one-point QC check (gaseous) App. A 3.2.1 Yes

App B – under 

“Detailed Site 

Information”

Yes

29. Date of last Annual Performance Evaluation (gaseous) App. A 3.2.2 Yes Yes

30. Dates of last two semi-annual flow rate audits for PM 

monitors

App A, 3.2.4 

and 3.3.3

Yes for most cases. 

Incomplete 

information given 

for cases listed in 

notes.

App B – under 

Yes for cases 

where information 

was complete. 

Insufficient to 

judge for 

incomplete 

Note that flow audits > 7 mos. apart (e.g., 

Anaheim, Banning, Big Bear, Burbank, Compton, 

Crestline, Indio, etc.) will not be accepted by AQS 

as valid and could therefore impact certification 

documentation (i.e., P/A reports)
7

ANP requirement Citation 

within 40 

CFR 58

Was the info 

submitted?1If 

yes, page #s. 

Flag if 

incorrect2?

Does the 

information 

provided3 meet 

the req?

4

Notes 

“Detailed Site 

Information”

information. -Mira Loma: Flow rate audits given as NA for 3 

PM2.5 instruments - one of these started in 2012 

but the others started in 2005 and should have 2 

audit dates.

-Riverside: Why is one date for PM10 given as 

NA?

-W. LA: Not sure if TSP monitor is for PM or Pb 

but either way, the information is not given.

31. Dates of last two semi-annual flow rate audits for Pb

monitors

App A 

3.3.4.1

Yes for most cases. 

Incomplete /

incorrect 

information given 

for cases listed in 

notes.

App B – under 

“Detailed Site 

Information”

Yes for cases 

where information 

was complete. 

Insufficient to 

judge for 

incomplete 

information.

Note that flow audits > 7 mos. apart (e.g., South 

Long Beach) will not be accepted by AQS as valid 

and could therefore impact certification 

documentation (i.e., P/A reports)

-Rehrig (Exide): listed as scheduled but with a 

start date of 11/07, there should have been 

previous flow audits.

-Van Nuys Airport: dates of semi-annual flow 

audits not given.

-W. LA: Not sure if TSP monitor is for PM or Pb 

but either way, the information is not given.

32. PM2.5 co-location App A 3.2.5 Incomplete

Page 15

Insufficient to 

judge

See Attachment B of the 2012 ANP memo. There 

are 20 FRMs and 3 co-located monitors according 

to Table 3 (meets 15% co-location) but method 

code is needed to determine if they are all the same 

method code. There are no FEMs designated as 

primary monitors.

Each MSA should have one continuous monitor 

co-located with an FRM – App. B tables indicate 

that multiple continuous monitors are co-located 

with FRMs but this should be reflected in the colocation tables.

Co-located sites should also be verified in the ANP 

of meeting the requirement that 80% of the colocated monitors are located at sites with PM2.5 

concentrations within 20% of NAAQS?
8

ANP requirement Citation 

within 40 

CFR 58

Was the info 

submitted?1If 

yes, page #s. 

Flag if 

incorrect2?

Does the 

information 

provided3 meet 

the req?

4

Notes 

33. Distance between co-located monitors App. A 

3.2.5.6

Yes for most cases. 

Incomplete / 

incorrect 

information given 

for cases listed in 

notes.

App B – under 

“Detailed Site 

Information”

Yes for cases 

where information 

was complete. 

Insufficient to 

judge for cases 

listed in notes.

-Long Beach (North): The PM10 monitors have 

different co-location distances even though they 

are presumably co-located with each other. PM2.5 

monitors have a co-location distance of 46m - is 

that correct?

-South Long Beach: PM2.5 monitors list a colocation distance of 1.5 m, which is only allowed 

if flow rates are <200 lpm – please note if this is 

the case.

-Palm Springs – the PM10 SSI has a c-location 

distance listed as 2.1 m but the PM10 TEOM has a 

co-location distance listed as NA, even though 

they are presumably co-located.

-Rehrig: Distances between the 3 Pb TSP monitors 

should be given.

-Rubidoux: Co-located monitors are listed as 1 m 

(FEMs) and 1.5 m (FRMs) apart which is only ok 

with flow rates <200 l/m.

34. Manual PM10 method co-location met? (note: 

continuous PM10 does not have this requirement)

App A 3.3.1 Yes

Page 3

Yes 21 manual monitors = 3.15 co-located monitors. 

SCAQMD has 4.

35. Pb co-location App A 

3.3.4.3

Yes for # 

N for highest site

Page 4

Yes for #; 

insufficient to 

judge for highest 

site.

15 sites = 2.25 sites. SCAQMD has 4. It is not 

identified which is highest site so it cannot be 

determined if that part of the requirement is met.

36. PM10-2.5 co-location (note: only applies to Fresno 

and Phoenix NCore sites)

App A 3.3.6 NA NA

37. Instrument/monitoring method code for each monitor: 

is it reported properly? Is it reported correctly (i.e., 

appropriate method code for regulatory monitors)?

App C 2.4.1.2 Incomplete 

information in 

almost all cases.

App B – under 

“Detailed Site 

Information”

Insufficient to 

judge.

Method code not provided for most monitors. For 

example:

-Anaheim: CO, NO2, O3, PM10 manual, 

speciation, and PM2.5 manual

-ATSF: Pb

-Azusa: PM10-SSI, PM2.5 RAAS. Could put 

"multiple" for metals, carbonyls, etc.

-Banning: NO2, O3, PM10

-Big Bear: PM2.5 FRM

-Burbank: PM10-SSI, PM2.5 RAAS, and PAMs 
9

ANP requirement Citation 

within 40 

CFR 58

Was the info 

submitted?1If 

yes, page #s. 

Flag if 

incorrect2?

Does the 

information 

provided3 meet 

the req?

4

Notes 

and toxics. Also note that pollutant type for cont. 

PM10 (method code 079) is listed as “TEOM” –

add “PM10” to title for pollutant.

-Closet World (Quemetco): Pb

-Compton: all pollutants

-Costa Mesa: all pollutants

-Crestline: ozone and PM10

-Fontana: all pollutants

-Glendora: O3, NO2, CO

-Indio: O3 and all PM except the PM-10 TEOM

-La Habra: all pollutants

-Lake Elsinore: O3, NO2, CO

-LAX Hastings: all pollutants

-stopped listing missing method codes at LAX 

Hastings.

38. Start date for each monitor Required to 

determine if 

other req. 

(e.g., min # 

and co-lo) are 

met

Yes

App B – under 

“Detailed Site 

Information”

Yes -Long Beach (North): Start dates missing for PM 

instruments, ARB Toxics 910, and PM2.5 FEM 

BAM.

39. Instrument monitor type for each monitor Required to 

determine if 

other req. 

(e.g., min # 

and co-lo) are 

met

Incorrect

App B – under 

“Detailed Site 

Information”

Insufficient to 

judge

App B “Detailed Site Information” has a no field 

for ‘monitor type’ but monitor type information is 

given under the field of ‘site type’.

See 2012 ANP memo, Attachment D

40. Monitoring objective for each instrument App D 1.1

58.10 (b)(6)

Incorrect

Tables 3-4

App B – under 

“Detailed Site 

Information”

Insufficient to 

judge

App B “Detailed Site Information” has a field for 

"monitor objective" that actually lists EPA site 

types. Information in Tables 3-4 listed as “monitor 

purpose” (which is really site type) information 

appears to be “monitor objective” in the App B 

tables. There are inconsistencies between the 

information provided in Tables 3-4 and App B 

“monitor objective.” Table 2 has information for 

“monitor objective” but this does not match EPA’s 
10

ANP requirement Citation 

within 40 

CFR 58

Was the info 

submitted?1If 

yes, page #s. 

Flag if 

incorrect2?

Does the 

information 

provided3 meet 

the req?

4

Notes 

definition of monitor objective and is also different

from the information provided under App B tables 

under the field of “monitor objective”.

See 2012 ANP memo, Attachment D

41. Site type for each instrument App D 1.1.1 Incorrect

App B – under 

“Detailed Site 

Information”

Insufficient to 

judge

App B “Detailed Site Information” has a field for 

"site type" that lists monitor type.

See 2012 ANP memo, Attachment D

42. Instrument parameter code for each instrument Required to 

determine if 

other req. 

(e.g., min # 

and co-lo) are 

met

Incomplete

App B – under 

“Detailed Site 

Information”

Insufficient to 

judge

Parameter code not provided for any monitors.

43. Instrument parameter occurrence code for each 

instrument

Required to 

determine if 

other req. 

(e.g., min # 

and co-lo) are 

met

Yes for most cases. 

Incomplete / 

incorrect 

information given 

for cases listed in 

notes.

App B – under 

“Detailed Site 

Information”

Yes for cases 

where information 

was complete. 

Insufficient to 

judge for 

incomplete / 

incorrect

information.

-POC not provided for all monitors (e.g., Anaheim 

PM10 manual).

-Rehrig: Incorrect POCs given. All 3 monitors are 

listed as POC 1 but each is actually a different 

POC.

-Riverside: Incorrect POCs given. The 2 monitors 

are listed as POC 1 but each is actually a different 

POC.

-Rubidoux: Numerous pollutants with of the same 

parameter have the same parameter occurrence 

code - these should be different.

44. Sampling season for ozone (note: date of waiver 

approval must be included if the sampling season 

deviates from requirement)

App D, 4.1(i) Yes

App B – under 

“Detailed Site 

Information”

Yes

45. Sampling schedule for PM2.5 - applies to year-round 

and seasonal sampling schedules (note: date of waiver 

approval must be included if the sampling season 

deviates from requirement)

58.12(d)

App D 4.7

Yes for schedule 

No for DV and 

continuous 

monitors

Page 21 

App B – under 

“Detailed Site 

Insufficient to 

judge at sites that 

are not operated at 

1:1

Requirement is for 1:1 sampling if DV is within 

5% of NAAQS at required sites. Need to know DV 

site(s) and conc. to judge whether sites should be 

at 1:1. 

Also, it should be noted if any of these sites are colocated with cont. FEM to make it 1:1 or if there 

are any cont. FEM sites not co-located with FRM 
11

ANP requirement Citation 

within 40 

CFR 58

Was the info 

submitted?1If 

yes, page #s. 

Flag if 

incorrect2?

Does the 

information 

provided3 meet 

the req?

4

Notes 

Information” as primary.

-Burbank and Mira Loma PM2.5 manual samplers 

listed as 1:3 sampling frequency but AQS shows 

1:1.

46. Sampling schedule for PM10 58.12(e)

App D 4.6

Yes for schedule

No for justification 

of schedule 

Page 3

App B – under 

“Detailed Site 

Information”

Insufficient to 

judge.

The site that represents the max. concentration for 

the area is required to operate on the schedule 

prescribed by 58.12 Figure 1. There is no 

information to justify the sampling schedule per 

58.12 – a comparison to Fig. 1 is needed for max. 

concentration sites.

47. Sampling schedule for Pb 58.12(b)

App D 4.5

Yes

App B – under 

“Detailed Site 

Information”

Yes

48. Sampling schedule for PM10-2.5 58.12(f)

App D 4.8

Incomplete

Page 9

App B – under 

“Detailed Site 

Information”

Insufficient to 

judge

There is not enough information in either the 

background on NCore (page 9) or the detailed site 

descriptions to determine which instruments are 

being used for the PM10-2.5 measurements. 

Therefore, neither the compatibility of the 

instruments nor the adequacy of the sampling 

schedule can be determined. Recommend 

addressing PM10-2.5 under NCore section of plan.

49. Minimum # of monitors for O3[Note: should be 

supported by MSA ID, MSA population, DV, # 

monitors, and # required monitors]

App D, 4.1(a) 

and 

Table D-2

Yes on min # O3, 

except for 

incorrect inclusion 

of middle-scale 

sites

No on DV

information

Page 13

Yes ANP includes note that DV>85% but actual DV 

should be included with a DV site identified. 

Requirement can be determined to be met since 

both areas are required to have the most number 

per population that could be required per CFR.

Note that sites that are too close to roadways that 

are middle and micro-scale sites (i.e., LAX 

Hastings, Pomona, and West LA) are not suitable 

for comparison to the NAAQS and should 

therefore not be included in minimum monitoring 

numbers.
12

ANP requirement Citation 

within 40 

CFR 58

Was the info 

submitted?1If 

yes, page #s. 

Flag if 

incorrect2?

Does the 

information 

provided3 meet 

the req?

4

Notes 

50. Identification of max. conc. O3 monitor(s) App D 4.1 (b) Yes – sites are 

identified as 

“highest 

concentration” sites

Table 2

App B – under 

“Detailed Site 

Information”

Yes

51. Minimum monitoring requirements met for SO2 App D 4.4 Yes

Page 14

Yes

52. Minimum monitoring requirements met for Pb App D 4.5 

58.13(a)

Yes

Pages 14-15

Yes

53. Minimum # of monitors for PM2.5 [Note: should be 

supported by MSA ID, MSA population, DV, # 

monitors, and # required monitors]

App D,

4.7.1(a) and 

Table D-5

Incorrect 

information is 

given on min # 

PM2.5

No on DV 

information

Page 15

Yes – they have 

many more than 

would be required 

even under the 

most stringent 

scenario

The table is given per PQAO but the minimum 

monitoring requirements for PM2.5 are per CBSA.

See note for 67 re. DV #.

ANP needs to include a statement (e.g., footnote) 

that all cont. FEMs are co-located with manual 

samplers. Otherwise a new table should be made 

that combines total FRM/FEM monitors.

54. Required PM2.5 sites represent community-wide air 

quality 

App D

4.7.1(b)

Yes

Table 2

Table 3

Yes Please note in future plans: All the manual PM2.5 

instruments are neighborhood scale (Table 2) and 

population exposure (Table 3), thus representing 

community-wide air quality

55. For PM2.5, is at least one site in a population-oriented 

area of expected maximum concentration

App D

4.7.1(b)(1)

Yes

Table 3

Yes Please note in future plans: Multiple sites are listed 

as population exposure and high concentration.

56. If >1 SLAMS PM2.5 required, is there a site in an 

area of poor air quality

App D

4.7.1(b)(2)

No Yes Please note in future plans: All of the South Coast 

Air Basin is in non-attainment for PM2.5 so most 

of the sites are in an area of poor air quality.

57. Minimum monitoring requirements for continuous 

PM2.5

App D 4.7.2 Yes for total 

number

Incomplete 

information for colocation, including 

continuous 

instruments

Table 4

Yes for total 

number – they have 

many more than 

would be required 

even under the 

most stringent 

scenario.

Insufficient to 

There is one co-located BAM (it’s not specified 

whether it’s FEM or not) listed in Table 4. The 

table for continuous PM2.5 monitoring (page 15) 

lists one non-FEM BAM for co-location. It is not 

clear what the footnotes mean. Continuous 

monitors are required to be co-located with both 

FRM and other FEM samplers. See Attachment B 

of 2012 ANP memo.
13

ANP requirement Citation 

within 40 

CFR 58

Was the info 

submitted?1If 

yes, page #s. 

Flag if 

incorrect2?

Does the 

information 

provided3 meet 

the req?

4

Notes 

Page 15 judge for colocation.

58. Requirements for PM2.5 background and transport 

sites

App D 4.7.3 NA – State-level 

requirement

N/A – State-level 

requirement

59. Are PM2.5 Chemical Speciation requirements met for 

official STN sites?

App D 4.7.4 Yes for #

Pages 8 and 16

Sampling 

frequency found in 

App B “Detailed 

Site Information”

Yes Official CSN sites should be identified in ANP as 

Rubidoux and LA N. Main (both sites operating at 

1:3).

60. Minimum # of monitors for PM10 App D, 4.6 

(a) and Table 

D-4 

Incomplete 

information - 

concentration and 

site info needed.

Page 14

Insufficient to 

judge for Coachella 

Valley

Incorrect 

information for 

total monitors

ANP includes note that one MSA is med. 

concentration and the other MSA is high 

concentration. The max concentration value for the 

DV site, with the DV site identified, should be 

included. 

Requirement for LA MSA can be determined to be 

met since the area has enough sites to satisfy the 

most stringent number of sites per Table D-4.

The requirement for the Coachella Valley cannot 

be judged at this time since a site may be required 

in the Southern Coachella Valley as the DV site.

The minimum monitoring table for PM10 on page 

14 says there are a total of 21 PM10 monitors 

when there are actually 25 regulatory monitors 

operated by SCAQMD – please correct in next 

year’s plan.

61. Minimum monitoring requirements met for PM10-2.5 

mass 

App D 4.8 No Insufficient to 

judge

See item 48.

62. Distance of site from nearest road App E 6 Yes for most cases. 

Incomplete 

information given 

for cases listed in 

notes.

App B – under 

“Detailed Site 

Information”

Yes for cases 

where information 

was complete. 

Insufficient to 

judge for 

incomplete 

information.

The following roads are not the closest to the 

monitoring sites but are close enough to 

potentially influence measurements and so 

distance and traffic counts should be listed:

-Anaheim - I-5

-Azusa - I-210

-Banning - I-10

-Burbank - I-5
14

ANP requirement Citation 

within 40 

CFR 58

Was the info 

submitted?1If 

yes, page #s. 

Flag if 

incorrect2?

Does the 

information 

provided3 meet 

the req?

4

Notes 

-Compton - I-5

-Perris - I-215

-Pico Rivera - San Gabriel Pkwy

-Rubidoux - 60

Long Beach (North): The distance to the road is 

given as 8-55 m. Some microscale pollutants have 

more specific allowable ranges. The distance to the 

road for the near-road pollutants should be given.

63. Traffic count of nearest road App E Yes for most cases. 

Incomplete 

information given 

for cases listed in 

notes.

App B – under 

“Detailed Site 

Information”

Yes for cases 

where information 

was complete. 

Insufficient to 

judge for

incomplete 

information.

See comments for 85.

64. Groundcover App E 3(a) Yes Yes

65. Probe height App E 2 Yes all but one 

case. Incorrect 

information given 

for case listed in 

notes.

App B – under 

“Detailed Site 

Information”

Yes for cases 

except that in 

notes. Insufficient 

to judge for 

incorrect 

information.

-Upland: "All year" listed as probe height for 

BAM PM2.5 non-FEM.

66. Distance from supporting structure App E 2 Yes Yes In some cases (e.g., Indio), a colon is used in place 

of a period (?).

67. Distance from obstructions on roof App E 4(b) Yes Yes

68. Distance from obstructions not on roof App E 4(a) Incomplete 

information for 

cases where 

obstacle was 

present.

App B – under 

“Detailed Site 

Insufficient to 

judge for cases 

where an obstacle 

was present.

Need height above obstacle, in addition to distance 

to obstacle, to judge whether this requirement is 

met (e.g., Anaheim, Long Beach (North), Mission 

Viejo PM, Reseda).
15

ANP requirement Citation 

within 40 

CFR 58

Was the info 

submitted?1If 

yes, page #s. 

Flag if 

incorrect2?

Does the 

information 

provided3 meet 

the req?

4

Notes 

Information”

69. Distance from trees App E 5 Yes Yes except those 

cases listed in 

notes. Crestline is 

critical to address.

-Anaheim: CO, NO2, O3, PM2.5 BAM, and PM10 

BAM are all within 6m of a tree – if it’s the trunk 

of a palm (seen in a picture) then make a note.

-Crestline: all pollutants are within 10m of trees 

– for ozone this site is the DV site for the SC 

Basin and it is critical to fix this.

-La Habra: site description indicates trees within 

3m but pictures suggest that they are below the 

height of the probe. If this is the case, note how 

much below they are.

-Long Beach (North): All pollutants within 10 m 

of trees (6 m). See above notes. 

-Pasadena: All pollutants within 10 m of trees (6 

m). See above notes.

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

71. Unrestricted airflow App E, 4(a) 

and 4(b)

Yes all but one 

case. Incorrect 

information given 

for case listed in 

notes.

App B – under 

“Detailed Site 

Information”

Yes for cases 

except that in 

notes. Insufficient 

to judge for 

incorrect 

information.

-Redlands: "Teflon" listed for PM10, which is the 

probe material rather than whether there is 

unrestricted airflow.

72. Probe material (if applicable) App E 9 Yes all but one 

case. Incorrect 

information given 

for case listed in 

notes.

App B – under 

“Detailed Site 

Information”

Yes for cases 

except that in 

notes. Insufficient 

to judge for 

incorrect 

information.

-Temecula: Probe material is listed as “N/A” for 

ozone but needs to be given.

73. Residence time (if applicable) App E 9 Yes all but one 

case. Incorrect 

information given 

for case listed in 

Yes for cases 

except that in 

notes. Insufficient 

to judge for 

-LA (Main): Residence time for NCore CO and 

NO2 listed as NA.
16

ANP requirement Citation 

within 40 

CFR 58

Was the info 

submitted?1If 

yes, page #s. 

Flag if 

incorrect2?

Does the 

information 

provided3 meet 

the req?

4

Notes 

notes.

App B – under 

“Detailed Site 

Information”

incorrect 

information.

74.

75. Not required as part of plan but good to check

76. For SPMs listed as non-regulatory, note the start Date 

of FRM/FEM/ARM at SPM. If > 24 months, agency 

must supplyinformation that App A, C or E 

requirements were not met.

58.20(c) – (e) NA No PM2.5 SPMs

77.

78.

Public Comments on Annual Network Plan

Were comments submitted to the S/L/T agency during the public comment period? 

Yes. One set of comments was submitted jointly by Breathe California, Communities for a Better Environment, and Natural Resources Defense 

Council.

If no, skip the remaining questions.

If yes:

 Were any of the comments substantive? Yes

o If yes, which ones? The comments were primarily concerned with monitoring pollution near heavily-trafficked areas. The substantive 

comments related to the ambient air monitoring network are those regarding PM2.5 and NO2 near-road monitoring.

o Explain basis for determination if any comments were considered not substantive: Comments that were not related to the ambient air 

monitoring network (e.g., planning issues such as the “black box”) were not considered substantive for the annual monitoring 

network plan.

 Did the agency respond to the substantive comments?

o If yes, was the response adequate? Yes

 Do the substantive comments require separate EPA response (i.e., agency response wasn’t adequate)? No

 Are the sections of the annual network plan that received substantive comments approvable after consideration of comments?
17

o If yes, provide rationale: Yes. The comments did not provide compelling information to alter the current or proposed near-road 

monitoring networks.

General Notes

 The pictures and maps are very helpful and informative.
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 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 

following system modifications listed in the plan per the applicable requirement: near 

road NO2 monitoring site selection, Van Nuys Pb Airport closure, and South Long Beach 

relocation. Therefore, we are not acting on these items as part of this year’s annual 

network plan.

 EPA identified items in your agency’s annual network plan where information in the plan 

was insufficient to judge whether the requirement was being met based on 40 CFR 58.10 and 

the associated appendices. However, this lack of information may be addressed later, and 

does not necessarily reflect upon the adequacy of the air monitoring network to perform its 

required functions. Therefore, we are not acting on of the following items:

Item Checklist Row 

(Attachment A) Issue

PM10 expected maximum 

concentration site

60 Insufficient information to judge for 

Coachella Valley Air Basin

Distance from trees 69 Insufficient information to judge for some 

cases

Pb site for 0.5-1.0 tpy sources 8 Insufficient information to judge

Designation of any Pb 

monitors as either sourceoriented or non-sourceoriented

19 Insufficient information to judge

Instrument/monitoring method 

code for each monitor

37 Insufficient information to judge

Instrument parameter code for 

each instrument

42 Insufficient information to judge

Scale of representativeness 16 Insufficient information to judge

Sampling schedule for PM2.5 45 Insufficient information to judge for some 

cases

PM2.5 co-location 32 Insufficient information to judge
Identification of sites suitable 

and sites not suitable for 

comparison to the annual 

PM2.5 NAAQS

17 Insufficient information to judge for some 

monitors

Frequency of one-point flow 

rate verification for Pb 

samplers audit

27 Insufficient information to judge for some 

sites

Annual data certification 

submitted

24 Insufficient information to judge

Site type for each instrument 41 Insufficient information to judge

Sampling schedule for PM10 46 Insufficient information to judge

Distance of site from nearest 

road

62 Insufficient information to judge for some 

cases

Traffic count of nearest road 63 Insufficient information to judge for some 

cases

Distance from obstructions not 

on roof

68 Insufficient information to judge for some 

cases

Pb co-location 35 Insufficient information to judge for highest 

site

Distance between co-located 

monitors

33 Insufficient information to judge for some 

sites

Monitoring objective for each 

instrument

40 Insufficient information to judge

Instrument monitor type for 

each monitor

39 Insufficient information to judge

Frequency of flow rate 

verification for manual PM 

samplers audit

25 Insufficient information to judge for one site

Dates of last two semi-annual 

flow rate audits for PM 

monitors

30 Insufficient information to judge for a few 

sites

Dates of last two semi-annual 

flow rate audits for Pb 

monitors

31 Insufficient information to judge for a few 

sites

Instrument parameter 

occurrence code for each 

instrument

43 Insufficient information to judge for a few 

cases

Document how states and 

local agencies provide for the 

review of changes to a PM2.5 

monitoring network that 

impact the location of a 

violating PM2.5 monitor.

22 Insufficient information to judge

Precision/Accuracy reports 

submitted to AQS

23 Insufficient information to judge
Sampling schedule for PM10-

2.5

48 Insufficient information to judge

Minimum monitoring 

requirements met for PM10-

2.5 mass

61 Insufficient information to judge

Probe height 65 Insufficient information to judge for one 

case

Unrestricted airflow 71 Insufficient information to judge for one 

case

Probe material (if applicable) 72 Insufficient information to judge for one 

case

Residence time (if applicable) 73 Insufficient information to judge for one 

case

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.

 [Item 2] It would be helpful to clarify the Statement of Purpose for each monitor (item 

#2). Tables 3-4 have a heading that indicates that the information includes “Monitoring 

Purpose.” The information that is given is actually site type. The site type could be used 

with the monitoring objective to define the Statement of Purpose but the current network 

plan conflates these various terms, which have specific CFR definitions (see EPA’s May 

2012 ANP memo).

 [Item 13] The following errors were identified for sampling and analysis method(s):

o Lake Elsinore: Start date listed for analysis method for NO2.

o Reseda: Analysis method for PM2.5 non-FEM BAM should be "beta attenuation" 

- see Riverside – Magnolia

o W. LA: There is a TSP sampler that is listed as "Tisch" for 

instrument/manufacturer/model and ICPMS for analysis method - is this Pb? It is 

not clear what pollutant is being measured due to the incomplete pollutant 

description and sampling and analysis method information.

 [Item 18] Identification as an area as an MSA (versus CSA or other) was missing for the 

following sites: ATSF, Closet World (Quemetco), Long Beach (North), Rehrig, 

Uddeholm, Upland

 [Item 38] Start date is missing for some parameters at the Long Beach (North) site.

 [Items 49 and 53] For ozone and PM2.5, the minimum monitoring requirements are 

based on the design value site’s proximity to the NAAQS. It would be helpful for the 

plan to include the design value site, along with the current design value, for each of 

these pollutants.

 [Item 49] Ozone monitors that are middle and micro-scale sites due to proximity to 

roadways (i.e., LAX Hastings, Pomona, and West LA) are not suitable for comparison to 

the NAAQS and should therefore not be included in minimum monitoring numbers. 

Please note this in the ozone minimum monitoring tables and in the detailed site tables.

 [Item 53] PM2.5 minimum monitoring requirements are listed per PQAO but these are 

specified in the CFR to be per MSA – please correct this. It is unclear whether the PM2.5 
FEMs are being operated as primary monitors or as solely additional monitors where 

FRMs are being operated. Due to this, it is difficult to crosswalk between minimum 

monitoring requirements and numbers of filter-based and continuous FEM monitors. It 

would be helpful to have a table that combines some of the information from Tables 3 

and 4 that focuses solely on PM2.5. Adding sampling frequency to such a table, along 

with the officially co-located monitors would also be extremely helpful for a network as 

extensive as South Coast’s PM2.5 network.

 [Item 55]The CFR requires that for PM2.5, there is at least one site in a populationoriented area of expected maximum concentration. It is assumed that sites listed in Table 

3 as population exposure, high concentration sites are intended to meet this requirement. 

Please review this list to ensure that this is the intention of your agency

 [Item 56] The CFR requires that If >1 SLAMS PM2.5 is required, there is a site in an 

area of poor air quality. In the current plan, EPA has determined that all of the South 

Coast Air Basin is in non-attainment for PM2.5 so most of the sites are in an area of poor 

air quality. It would be useful for future plans to include a statement to this effect.

 [Item 57] There is one co-located BAM (it’s not specified whether it’s FEM or not) listed 

in Table 4. The table for continuous PM2.5 monitoring (page 15) lists one non-FEM 

BAM for co-location. It is not clear what the footnotes mean. Continuous monitors are 

required to be co-located with both FRM and other FEM samplers and must consider 

method codes.

 [Item 59] It would be useful for official CSN sites (i.e., Rubidoux and LA North Main) to 

be identified in future annual network plans.

 [Item 60] The number of PM10 monitors listed in the PM10 minimum monitor table 

(page 14) has a total of 21 monitors listed when SCAQMD operates 25. This should be 

corrected in future plans.

 [Item 66] The detailed site report for Indio uses a colon instead of a period for the 

measurement of the distance from the supporting structure – this is presumably a typo.

 Although EPA Region 9 is not taking action on the NO2 portions of the plans this year, 

for next year, please identify sites fulfilling the NO2 area-wide and RA40 requirements.