UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION
IX Mr. Daniel Inouye Chief, Monitoring and Planning Air Quality Management Division Washoe County Health District P.O. Box 11130 Reno, Nevada 89520-0027 Dear Mr. Inouye:

75 Hawthorne Street San Francisco, CA 94105·3901 DEC 1 1 2013 Thank you for your submission
of the Washoe County Health District Air Quality Management Division (AQMD's) 2013 Ambient 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. With this plan approval, we also formally approve the following system modification(s): relocation
of the Galletti site to address adequate spacing from trees, and initiation of SLAMS PM
2 .s monitoring

at the Sparks site. 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 of your 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.

**Print~d** on Rtcycltd PaptrIf you have any questions regarding this letter or the enclosed comments, please feel free to contact me at (415) 947-4534
or Elfego Felix at (415) 947-4141. Enclosures:

·-- Sincerely,

**~ v/JI~~~**  Meredith Kurpius, Manager Air Quality Analysis Office A. Annual Monitoring Network Plan Items where EPA is Not Taking Action B. Additional Items Requiring Attention C. Annual Monitoring Network Plan Checklist cc: Craig Petersen, AQMD Kevin Dick, AQMDA. Annual 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. • Per 40 CFR 58.11(c), NCore and STN network design and changes are subject to approval of the EPA Administrator. Therefore, we are not acting on these items. • EPA identified items in your agency's annual monitoring 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 the following items: Item Checklist Row Issue Modifications

to SLAMS

4 Insufficient

to judge network Document how states and

26 Insufficient

to judge local agencies provide for the review of changes
to a PM2.s monitoring network that impact the location of a violating PM2.s monitor. Scale of representativeness

for 17,73 Insufficient

to judge in some instances each monitor
& distance of site from nearest road Monitoring objective for each

47 Insufficient

to judge instrument Site type for each instrument

48 Insufficient tojudge
in some instances Additional information
for each of these items may be found for the row listed in column
2, in the third enclosure (C. Annual Monitoring Network Plan Checklist).B. Additional Items Requiring Attention • [Items 9, 10, 12] EPA recommends
for AQMD
to clarify the applicability ofall40 CFR Part 58 monitoring requirements

in future ANP submittals. • [Item 37 & 40] It is recommended that AQMD develop

a section in future ANP submittals that describes how collocation requirements
are being met. • [Item 38] AQMD uses the term ''Designated" (rather than ''Primary'')

to differentiate between

a "Collocated" monitor.

It is recommended that the term ''Primary''
be adopted in place of"Designated."

· • [Item 46] NCore required parameters reported (p.26-31) are considered

a subset of the SLAMS network. Please also add SLAMS
as a monitor type to the NCore parameters.

## C. ANNUAL MONITORING NETWORK PLAN CHECKLIST 

## (Updated 11/26/2013) Year: 2013 Agency: Washoe County Health District Air 

## Quality Management Division (AQMD) 40 CFR 58.1O(a)(1) requires that each Annual Network Plan (ANP) include information regarding the following types ofmonitors: SLAMS monitoring stations including FRM, FEM, and ARM monitors that are part ofSLAMS, 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 ofpurposes for each monitor and evidence that siting and operation of each monitor meets the requirements ofappendices A, C, D, and E ofthis part, where applicable." On this basis, review ofthe 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 ifthe required information is included and correct. The items requiring approval by the Administrator are: PAMS, NCore, and Speciation (STN/CSN). Please note that this checklist summarizes many ofthe requirements of40 CFR Part 58, but does not substitute for those requirements, nor do its contents provide a binding determination ofcompliance 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 insufficientto make a determination. Action requested in next year's plan or outside the ANP process. = item requires attention in order to 

## improve next year's plan.

1

### ANP requirement Citation Was the info Does the Notes within 40 submitted? 1 

### If information CFR58 yes, page

## #s. provided 3 

### meet Flag if 

### the req?4 · 

### incorrecr? 1. SubmitplanbyJuly 1st 58.10 (a)(l) Yes Yes 2. Statement ofpurpose for each monitor 58.10 (a)(1) Yes, p.l2-39 Yes

3. 30-daypublic comment 

### I inspection**period~** 58.10 (a)(1), Yes, coverletter Yes No comments received. 58.10 (a)(2) 

### 4. Modifications to SLAMS network

- case when we are 58.10 (a)(2) Yes, p.7-8 Insufficient tojudge -Please include a rationale for the proposal to not approving actual system modifications (i.e., we 58.10(e) initiate SLAMS PM2.5 monitoring at Galletti will do it outside the ANP process6) (p.8). -While EPA Region 9 does not have authority to approve the Reno3 NCore site meteorology modifications proposed on p.7, we fmd these acceptable and would recommend approval to the Administrator. 5. Modifications to SLAMS network- case whenwe are 58.10 (a)(2) Yes, p.7-8 Yes -EPA approves the relocation ofentire Galletti approving actual system modifications per 58.14(c) 58.10 (b)(5) site approximately 45 meters northto correctthe 58.10(e) spacing from trees siting issues. 58.14 (c)

- EPA is aware ofAQMD efforts to better understandthe spatial distribution ofPM2• 5 across the region andthe potential for higher PM2

### .s concentrations at Sparks inparticular. EPA therefore approves the initiation ofPM2• 5 SLAMS monitoring (and collocation as needed) atthe Sparks site.



# - -EPA appreciates AQMD's effort to informEPA

1Response options: NA (NotApplicable), Yes, No, Incomplete, Incorrect. The responses "Incomplete" and "Incorrect'' assume that some information 

### has beenprovided. 2 To the best ofourknowledge. · · 3 Assumingthe information is correct 4 Response options: NA (NotApplicable)- [reason], Yes, No, Insufficient to Judge. 5 The affected state or local agency must document the process for obtainingpublic comment and include any comments received through thepublic notificationprocess within their submitted plan. · · 6 See 58.14(c) 

## 2

## ANP requirement Citation Wasthe info Does the Notes within 40 submitted? 1 

### If 

## information CFR58 yes, page#s. provided 3 

## meet Flag if 

## the req?4 

## incorrecf? ofthe PM10 

### instrument modifications occurring within their SLAMS network at the Galletti & 

### Sparks site (p.

### 7). SLAMS FRM/FEM instrument modifications, provided they are replacing other SLAMS FRMIFEM designated instruments, do not require EPA approval. Therefore, AQMD's proposed PM 10 

### SLAMS instrumentreplacements from manual methods to continuous methods is acceptable, provided that the replacement instruments continue to be SLAMS and of FRMIFEM designation. -Meteorology instrument adjustments at the Toll, So

.Reno, Plumb-kit, Galletti, and Sparks sites are acceptable and do not require EPA approval. 6. Does plan include documentation (e.g., attached N/A N/A No system modifications approved outside the approval letter) for system modifications that have ANP since last ANP approval. been approved since last ANP approval? 7. NCore site operational (by 1/1/2011) 58.10 (a)(3) Yes, p.24-31 N/A- HQ approval All required parameters operational. EPA does not currently expect agencies to operate speciated PMu1-2.s. 8. Ph site for 0.5-1.0 tpy sources operational (by 58.10 (a)(4) N/A N/A- no current No sources over 0.5 tons per year and a CBSA 12/27/2011) requirement. population less than 500,000 listed as rationale_on p.4. 

### 9.

**N~** 

### plan for area-wide and RA40 sites submitted by 58.10 (a)(5) N/A N/A- no current EPA recommends for AQMD to clarify the 7/1/2012 requirement. applicability ofthis requirement in future 

### ANP submittals (currently not applicable). 10.

**N~** 

### area-wide and RA40 sites operational by 58.10 (a)(S) N/A N/A- no current EPA recommends for AQMD to clarify the 1/1/2013 requirement. applicability ofthis requirement in future 

### ANP submittals (currentlynot applicable). 11. N02plan for near-road sites submittedby 7/1/2013 58.10 (a)(5) N/A N/A- no current AQMD lists CBSA population size as rationale requirement. on p.4. 12. 

## so2 sites

**ope~tional** 

### (by 1/1/2013) 58.10 (a)(6) Yes, p.27 Yes -AQMD operates one required monitor at 

### NCore. and 58.13(d) PWEI monitoring not currently required.

- EPA recommends for AQMD to clarify the applicability ofPWEI monitoring requirements in

-
- - - -- future 

## N"lP submittals { currentl}' not

**ap~licable**

### ). 

## 3

## ANP requirement Citation Was the info Does the Notes within 40 submitted?1 

### H 

## information CFR58 yes, page#s. provided 3 

## meet Flag if 

## the req?4 

## incorrecr? 13. AQS site identification number for each site 58.10 (b)(l) Yes, p.12-39 Yes 14. Location ofeach site: street address and geographic 58.10 (b)(2) "X"es, p.l2-39 Yes coordinates 15. Sampling and analysis method(s) for each measured 58.10 (b)(3) Yes, p.14-41 Yes parameter 16. Anyproposals toremove ormove a monitoring station 58.10 (b)(5) Yes,p.7 Yes See Galletti site relocation from item 5 above. within a period of 18 months following plan submittal 17. Scale ofrepresentativeness for each monitor as 58.1O(b)(6); Yes, p.l4-41 Insufficient tojudge See item 73 for discussion on Reno3. defmed 

### in Appendix D AppD some parameters at Reno3 Yes- all others 18. Identification ofsites suitable and sites not suitable for 58.10 (b)(7) Yes, p.14-41 Yes comparisonto the annual PM2

### .s NAAQS as described inPart 58.30 

## - 19. MSA, CBSA, CSA or other arearepresentedbythe 58.10 (b)(8) Yes, p.12-39 Yes monitor 20. Designation ofany Pb monitors as either source- 58.10 {b)(9) N/A N/A- no current oriented ornon-source-oriented requirement 21. Any source-oriented Pb site for which a waiver

### has 58.10 (b)(lO) N/A N/A- no current been granted byEPARA requirement 22. Any Pb monitor for which a waiverhas been 58.10 (b)(ll) N/A N/A- no current requested or grantedbyEPARA for use ofPb-PM10 requirement in lieu ofPb-TSP 23. Identification ofrequired N02 monitors as either 58.10 {b)(l2) N/A N/A- no current near-road or area-wide requirement 24. Identification ofanyPM2

### .s FEMs and/or ARMs not 58.10 (b)(13) N/A N/A-no such eligible to be comparedto the NAAQS (Note 1: must 58.11 (e) monitors identified include required data assessmenq (Note 2: Required SLAMS must monitor PM2

### .s with NAAOScomparable monitor at the required sample frequency.) 25. For SPMs listed as non-regulatory, note the start Date 58.20(c) Yes,p.3 &38 Yes The PM2.s andPM10 SPM BAMs listed onp.38 

### if ofFRMIFEM/ARM at SPM. If> 24ytonths, and continuingto operate pastJuly 2013 shouldbe monitor is eligible for COiilparison to the NAAQS per listed as NAAQS comparable unless information 58.11 (e) and 58.30, the agencymust supply is provided showingApp.A, C, orE are not being information that App A, C orErequirements were not met. 

### 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 

### incorrecr? met.

- 26. Document how states and local agencies provide for 58.10 (c) Incomplete, p.l & 8 Insufficient tojudge AQMD provides a section in the ANP describing the review ofchanges to a PM2.5 monitoring network the public inspection process and modifications to that impact the location ofa violating PM2 

### ..s monitor. the PM2.5 monitoring network. Please clarify specifically how AQMD provides for the review ofchanges to a PM2.5 monitoring network that impact the location ofa violating PM2 .5 monitor. 27. Does the plan include a request for approval for and 58.11 (a) (2) N/A N/A-no such alternative to appendixA requirements for SPMs request included operating a FRMIFEM/ ARM which also meets appendixE? 28. Precision/Accuracyreports submitted to AQS 58.16(a); Yes, p.8 Yes AppA, 1.3 and 5.1.1 29. Annual data certification submitted 58.1 5 Yes, p.8 Yes I App.A 1.3 I 30

. Frequency offlow rate verification for manual PM AppA3.3.2 Yes, p.14-41 Yes samplers audit 31. Frequency offlow rate verification for automatedPM · AppA3.2.3 Yes, p.14-41 Yes analyzers audit 32. Frequency ofone-point flow rate verification for Ph App A 3.3.4

. 1 N/A N/ A- no current samplers audit requirement 33. Frequency ofone-point QC check (gaseous) App. A 3.2.1 Yes, p.14-41 Yes 34. Date oflastAnnual Performance Evaluation (gaseous) App.A3.2.2 Yes, p.14-41 Yes 35. Dates oflast two semi-annual flow rate audits for PM AppA,3 :2.4 Yes, p.14-41 Yes monitors and3.3.3 36. Dates oflasttwo semi-annual flow rate audits for Ph App A 3.3.4.1 N/A N/A- no current monitors requirement 37. PM2.s collocation AppA3.2.5 Yes, p.28 Yes It is recommended that AQMD develop a section in future ANP submittals that describes how collocation requirements are being met. 38. Designation ofa primary monitor ifthere is more than Needto Yes, p.28 & 38 Yes AQMD uses the term "Designated" (rather than one monitor for a pollutant at a site. determine "Primary") to differentiate between a collocation "Collocated" monitor. It is recommended that the term "Primary'' be adopted in place of "Designated

." 39. Distance between collocatedmonitors (Note: waiver App.A Yes, p.28 & 38 Yes 

### 5

## ANP requirement Citation Was theilifo Does the Notes 

# I within 40 submitted?1 

### H 

## information



## . CFR58 yes, page #s. provided 3 

## meet Flag if 

## the req?4 

## incorrecf? i request orthe date ofprevious waiver approval must 3.2.5.6 and be included 

### ifthe distance deviates from requirement.) 3.2.6.3 40. Manual PM 10 method collocation met? (note: AppA 3.3

. 1 Yes, p.38 Yes It is recommended that AQMD develop a section 1 continuous PM 10 does not have this requirement) in future ANP submittals that describes how

I collocation requirements are being met. 41. Ph collocation App A 3.3.4.3 N/A N/A- no current I requirement 42. PM10•2• 5 collocation (note: only applies to Fresno and AppA3.3.6 N/A N/A- no current PhoenixNCore sites) requirement 43. Instrument/monitoring method code for eachmonitor: AppC2.4J.2 Yes, p.l4-41 Yes 

### is itreportedproperly? Is 

### itreported correctly (i.e., appropriate method code forregulatory_

**monitors~?** 

### 44. For agencies that share monitoringresponsibilities in AppD2(e) Yes, p.4-5& 9 Yes AQMD currentlymeets 

### all minimum monitoring an MSA/CSA: does each affected State orlocal requirements for the Reno

-Sparks, NV CBSA. agencymeet

### full monitoringrequirements oris an agreementbetweenthe affected agencies andthe EPARegional Administrator inplace? 45. Start date for each monitor Required to Yes, p.l4-41 Yes determine 

### if otherreq. (e.g

., min# and colloc) are met 

## - 46

. Instrument monitor ty.pe for each monitor Required to Yes. p.l4-4l Yes NCore required parameters reported (p.26

-31) are determine if considered a subset ofthe SLAMS network

. otherreq. Please also add SLAMS as a monitor type 

### to the (e.g., min# NCore parameters. and colloc) are met 47. Monitoring objective for each instrument App D 1.1 No Insufficient tojudge Recommend adding a row called "Monitoring 58

. 10 (b)(6) objective(s)" to the detailed site tables on p.l4-4l. The monitoring objective should list one or a combination ofthe following: NAAQS com parison, Public Information, and/or Research. 48. Site type for each instrument App D 1.1.1 Incorrect, p.14-4l Insufficient tojudge These should match one ofthe acceptable AQS in multiple codes for Site Types
. See Attachment D ofthe instances Region 9 2012 ANP memo for guidance or feel free to contact Region 9 directly. 

## 6

## ANP requirement Citation Was the info Does the Notes within 40 submitted? 1 

### If 

## information CFR58 yes, page #s. provided 3 

## meet Flag if 

## the req?4 

## incorrecf? 49. Instrumentparameter code for each instrument Required to Yes, p.14-41 Yes determine if otherreq. (e.g., min# and colloc) are met 50. Instrumentparameter occurrence code for each Required to Yes, p.14-41 Yes instrument determine 

### if other req. (e.g., min# and colloc) are met 51. Sampling season for ozone (note: date ofwaiver 58.10 (bX4) Yes, p.14-41 Yes Currently all year for all ozone sites. approval mustbe included ifthe sampling season App D, 4.l(i) deviates from requirement) 52. Sampling schedule for PM2

### .s - applies to year-round 58.10 (b)(4) Yes, p.28-29 & 38 Yes and seasonal sampling schedules (note: date ofwaiver 58.12(d) approval mustbe included ifthe sampling season AppD4.7 deviates from requirement) EPA flowchart 53. Sampling schedule for PM10 

### 58.10 (bX4) Yes. P.14-41 Yes 58.12(e) AppD4.6 54. Sampling schedule for Pb

. 58.10 (bX4) N/A N/A- no current 58.12(b) requirement AppD4.5 55. Sampling schedule for PM1

### o.2

### .s 58.10 (b)(4) Yes, p.28-29 Yes 58.12(t) App_D4.8 56. Minimum# ofmonitors for 

### 0 3 

### [Note: shouldbe App D, 4.1(a) Yes, p.4 Yes supported byMSA ID, MSApopulation, DV, # and monitors, and#required monitors] (see footnote)' TableD-2 57. Identification ofmax. cone. 

### 0 3 

### monitor(& AppD4.1 (b) Yes, p.20, 34, &37 Yes 58. Minimum monitoringrequirements met for near-road AppD4.3.2 N/A 

### NIA- no current

7 

### Onlymonitors considered to berequired SLAMs are eligible to be countedtowards meeting minimum monitoringrequirements. 

### Inaddition, ozone monitors that do not meet traffic count/distance requirements to be neighborhood scale (40 CFR58 Appendix E, Table E-1) cannotbe counted towards minimum monitoringrequirements. 

### 7

### ANP requirement Citation Was the info Does the Notes within 40 submitted?1 

## If information CFR58 yes, page#s. provided 3 

### meet

I 

### Flag if 

### the req?4

I 

### incorrect2

### ? N02(2014 start date) requirement 59. Minimum monitoring requirements met for area-wide AppD4.3.3 N/A N/A- no current i 

### N02 requirement 60. Minimum monitoring requirements met for RA-40 AppD4.3.4 N/A N/A- no current
I 

### N02 requirement 61. Minimum monitoringrequirements met for so2 AppD4.4 Yes,p.5 Yes Yes for NCore, no current PWEI requirement. I 

### [Note: Only monitors considered to be required SLAMs are eligible to be countedtowards meeting minimum monitoringrequirements.] 62. Minimum monitoring requirements met for Pb [Note: AppD4.5 N/A N/A- no current Only monitors consideredto berequired SLAMs are 58.13(a) requirement eligible to be countedtowards meeting minimum monitoring requirements.] 63. Minimum # ofmonitors for PM2 . 5 

### [Note 1: shouldbe AppD, Yes, p.4 Yes supported by MSA ID, MSA population, DV, # 4.7.l(a) and monitors, and#required monitors] [Note

**2~** 

### Only Table D-5 monitors consideredto be required SLAMs are eligible to be countedtowards meeting minimum monitoringrequirements.] 

### 64. Optional PM2 

### .s Network Clarifications: Provide a list Need to N/A N/A ofrequired sites 

### ifit does not include all SLAMS

. assess several [Note: default will assume all SLAMS are considered requirements required sites.] 65. Required PM2 

### .s sites represent area-wide air quality AppD

. Yes Yes 4

.7
. !{1>) 66. ForPM25, is at least one site at neighborhood orlarger AppD Yes,p
.28 Yes scale in an area ofexpected maximum concentration 4.7.l(b)(l) 67. 

### Ifadditional SLAMS PM2 .5 

### required, 

### is there a

**si~** 

### in .A.ppD N/A N/A- no additional an area ofpoor air quality 4.7.1(b)(2) sites required 68. Minimum monitoringrequirements for continuous AppD4

.7
.2 Yes, p.4 Yes PM2

.s 69. Requirements for PM2 .5 

### background and transport App D 4.7.3 N/A N/A- state sites requirement 70. Are PM2 .5 

### Chemical Speciation requirements met for AppD4.7.4 Yes,p.29 Yes official STN sites? 71. Minimum# ofmonitors for PM10 

### App D, 4.6 (a) Yes,p.5 Yes and Table D-4 

### 8

## ANP requirement Citation Was the info Does the Notes I 

## within 40 submitted? 1 

### If 

## information
I 

## CFR58 yes, page#s. provided 3 

## meet Flag if 

## the req?4 

## incorrecf? 72. Minimum monitoring requirements met for PM 10.. 2.s AppD4.8 Yes, p.28-29 Yes mass 73. Distance ofsite from nearestroad AppE6 Yes, p.12-39 Insufficienttojudge -The Reno3 site is listed as 6.7 m from River atReno3 RockRoad and does notprovide traffic estimates for this road. This does notmeetthe minimum Yes- all others requirement of 1Om for ozone, oxides ofnitrogen (NO, N02, NOy), and CO monitoring at the neighborhood scale. Please clarify this situation in next year'splan. Options for clarifying the situation may include revisiting the spatial scale or seeking ofa waiver per40 CFR 58, Appendix E, Section 10. -All parameters (Ozone, CO, 

### & PM 10) at the Toll site are listed as middle scale due to the distance from the probe to the nearest roadway. Ozone and PM 10 are ofsufficient distance from the roadto be considered neighborhood scale. AQMD may choose to reexamine the scale for two parameters as deemed appropriate. 74. Traffic count ofnearestroad AppE Yes, p.12-39 Yes 75. Groundcover AppE 3(a) Yes, p.12-39 Yes 76. Probe height AppE2 Yes, p.14-41 Yes 77. Distance from

- supporting structure AppE2 Yes, p.14-41 Yes 78

. Distance from obstructions on roof App E4(b) Yes, p.14-41 Yes 79. Distance from obsP"uctions not on roof AppE4(a) Yes, p.14-41 Yes 80. Distance from trees AppES Yes, p.14-41 Yes 81. Distance to furnace or incinerator flue A_pp E 3(b)_ Yes,p.14-41 Yes 82. Unrestricted airflow AppE, 4(a) Yes, p.14-41 Yes and4(b) 83. Probe material (ifapplicable) AppE9 Yes,_1).14-4 1 Yes 84

. Residence time (ifapplicable) AppE9 Yes, p.14-41 Yes



### 9

### Public Comments on Annual NetworkPlan 

### Were comments submittedto the S/L/T agency during the public commentperiod? No Ifno, skip the remaining questions. Ifyes: • Were any ofthe comments substantive? o Ifyes, which ones? o Explain basis for determination ifany comments were considered not substantive: • Didthe agency respond to the substantive comments? o If

### yes, was the response adequate? • Do the substantive comments require separate EPAresponse (i.e., agency response wasn't adequate)? • Are the sections ofthe annual network planthatreceived substantive comments approvable after consideration ofcomments? o Ifyes, provide rationale:

10