North Coast Unified Air Quality Management District 

2300 Myrtle Avenue 

Eureka, California 95501 

Dear Mr. Martin: 

Thank you for your submission of the North Coast Unified Air Quality Management District's 

(NCU's) Air Monitoring Network Plan 2013 in June 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 

modifications: shutdown ofEureka I Street station in accordance with 40 CFR 58.14(c)(1), and 

conversion of Jacobs to SLAMS for PM10 and PM2.s· These changes are described in the network 

plan and additional information was provided to EPA by NCU in a July 15, 2013 letter, 

September 26,2013 email and September 30,2013 letter. Please include these documents and 

any associated attachments in next year's annual network plan. EPA further notes that the 

addition of a FEM PM10 instrument to the Crescent City, Del Norte County site was described in 

the network plan and a separate letter sent to EPA on April 25, 2013. NCU has since clarified 

that its plans were altered and it now intends to install a SPM FEM PM2.s/non-FEM PM to 

GRIMM 180 instrument at Crescent City. EPA is not required to approve new SPMs, therefore 

the Crescent City system modification does not need to be approved. Please include this network 

clarification in next year's plan. NCU's September 16, 2013 email also indicates that any 

changes to the PM10 FRM at 880 Northcrest, Crescent City, will be addressed in a separate future 

request. We thank you for your correspondence and look forward to working through any future 

network modifications with you. 

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. 

Printl'd on Rl'cyclt'd Papt'r 
(through corrections within the plan, additional i

o

at

o

g 

, 

) 

next year's annual monitoring network plan. If you have any questions regarding this letter or the 

enclosed comments, please feel free to contact me at (415) 947-4534 or Gwen Yoshimura at 

(415) 947-4134. 

Enclosures: 

Sincerely, 

4~ ~ . 

Meredith Kurpius, Man~ 

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: Wendy Caruso, NCU 

Gayle Sweigert, California Air Resources Board 
y

g

y

onitoring 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 

Identification and justification 18, 24, 25 Not meeting requirement 

for PM2.s FEMs not 

comparable to the NAAQS 

Sampling schedule for PM2.s 52 Not meeting requirement 

Dates oflast two semi-annual 35 Insufficient to judge 

flow rate audits for PM 

monitors 

PM2.s collocation 37 Insufficient information to judge 

Manual PM to collocation 40 Insufficient information to judge 

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). 
• [Row 37] NCU's statement on pages 13 and 16 of the plan, ''No collocation ofSPM 

monitors is required," is not correct. Unless SPMs are non-regulatory or are expected to 

run for a short period of time only, collocation is required as they are eligible for 

comparison to the NAAQS. 

• [Row 48] EPA incorrectly identified ''population oriented" as a site type in last year's 

response letter. NCU was correct that it should be ''population exposure" to match AQS 

and Appendix D. 

• [Row 57] While NCU does not have any required ozone sites, EPA recommends 

considering whether your network contains a max ozone monitor with your next network 

plan, or during your 5-year Network Assessment. 

• [Row 66] While NCU does not have any required PM2.s sites, EPA recommends 

considering whether your network contains a max concentration monitor at a 

neighborhood or larger scale with your next network plan, or during your 5-year Network 

Assessment. 
C. ANNUAL MONITORING NETWORK PLAN CHECKLIST 

(Updated 11/26/2013) 

Year: 2013 

Agency: North Coast Unified AQMD (NCU) 

40 CFR 58.1 O(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, S1N 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)(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: P AMS, NCore, and Speciation (S1N/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 the ANP 

,...,-----. process. (items listed in Enclosure A) 

lGI'een I =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 

within40 submitted?1 If information 

CFR58 yes, page #s. provided3 meet 

Flag if thereq?4 

incorrecf? 

1. Submit plan by July 1st 58.10 (a)(1) Yes Yes Submitted June 28, 2013 

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

3. 30-day public comment I inspection period) 58.10 (a)(1), Yes Yes Attached public notices. No public comments were 

58.10 (a)(2) received, per email sent 6/28/2013. 

4. Modifications to SLAMS network- case when we 58.10 (a)(2) Yes,pg 16 Yes While we encourage agencies to inform us of such 

are not approving actual system modifications (i.e., 58.10(e) changes, EPA is not required to approve changes to a 

we will do it outside the ANP process

6

) non-violating, non-required SPM such as the SPM 

PM2.s sampler at Jacobs. EPA also is not required to 

approve new SPMs. EPA will work with NCU on 

any future changes to their network, such as 

placem~t of new SLAMs PM2•5 monitors. 

5. Modifications to SLAMS network- case when we 58.10 (a)(2) Yes, pg 16 Yes We are approving the shutdown ofEureka I street, 

are approving actual system modifications per 58.10 (b)(5) and the change of Jacobs to SLAMS for PM10 and 

58.14(c) 58.10(e) PM2.s. As of a September 16, 2013 communication, 

58.14 (c) we also understand that NCU no longer intends to 

deploy a FEM PM10 instrument at Crescent City (as 

described in the network plan and a separate April 

25, 2013 letter to EPA), and instead will place an 

SPM instrument at Crescent City. This network 

modification therefore no longer requires EPA 

approval, as installation of a SPM does not require 

EPA approval. We encourage you to continue 

keeping EPA and ARB informed of any such 

network changes. 

6. Does plan include documentation (e.g., attached NA NA No mods approved since last ANP. Included letter 

approval letter) for system modifications that have requesting PM10 changes. 

1 Response options: NA (Not Applicable), Yes, No, Incomplete, Incorrect. The responses "Incomplete" and "Incorrecf' 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 
ANP requirement Citation Was the info Does the Notes 

within 40 submitted?1 If information -

CFRS8 yes, page #s. provided3 meet 

Flag if the req?4 

incorrecr? 

been approved since last ANP approval? 

7. NCore site operational (by 1/112011) 58.10 (a)(3) NA NA No NCore site required. 

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

12127/2011) I 9. N02 plan for area-wide and RA40 sites submitted by 58.10 (a)(5) NA NA No N02 sites required. 

7/1/2012 

10. N02 area-wide and RA40 sites operational by 58.10 (a)(5) NA NA No N02 sites required 

111/2013 

11. N02 plan for near-road sites submitted by 7/112013 58.10 (a)(5) NA NA No N02 sites required. 

12. so2 sites operational (by 1/1/2013) 58.10 (a)(6) NA NA No S02 sites required. 

and 58.13(d) 

13. AQS site identification number for each site 58.10 (b)(l) Yes, pgs 18-27 Yes 

14. Location of each site: street address and geographic 58.10 (b)(2) Yes, pgs 18-27 Yes 

coordinates 

15. Sampling and analysis method(s) for each measured 58.10 (b)(3) Yes, pgs 18-27 Yes 

parameter 

16. Any proposals to remove or move a monitoring 58.10 (b)(5) Yes,pg 16 Yes 

station within a period of 18 months following plan 

submittal 

17. Scale of representativeness for each monitor as 58.10(b)(6); Yes, pgs 18-27 Yes 

defined in Appendix D AppD 

18. Identification of sites suitable and sites not suitable 58.10 (b)(7) Incorrect Yes NCU is operating an FEM GRIMM at both 

for comparison to the annual PM2.

5 NAAQS as Humboldt Hill (pg 22-23) and Weaverville (pg 24-

described in Part 58.30 25). They ID them as not comparable to the annual 

PM2.s NAAQS in the detailed site information tables, 

and on pg 13 state that these instruments "are nonregulatory and their data is not expected to meet the 

FRM similarity requirements which would enable 

them to be used for in national comparison." As 

discussed in Row 24 and Row 25 below, such a 

statement must be accompanied by additional 

information in order for EPA to determine whether it 

is appropriate to consider these instruments not 

comparable to the NAAQS. Until such information 

is provided, EPA will consider these data valid for 

comparison to the NAAQS. 

19. MSA, CBSA, CSA or other area represented by the 58.10 (b)(8) Yes, pgs 18-27 Yes 

3 
ANP requirement Citation Was the info Does the Notes 

within 40 submitted?1 If information I 

CFR58 yes, page #s. provided3 meet I 

Flag if the req?4 

incorrecr? 

monitor 

20. Designation of any Ph monitors as either source- 58.10 (b)(9) NA NA No Ph monitors required. 

oriented or non-source-oriented 

21. Any source-oriented Ph site for which a waiver has 58.10 (b)(IO) NA NA No Ph monitors required. 

been ~ted by EPA RA 

22. Any Ph monitor for which a waiver has been 58.10 (b)(11) NA NA No Ph monitors required. 

requested or granted by EPA RA for use ofPb-PM10 

in lieu ofPb-TSP 

23. Identification of required N02 monitors as either 58.10 (b)(12) NA NA No N02 monitors required. 

near-road or area-wide 

24. Identification of any PM2_5 FEMs and/or ARMs not 58.10 (b)(l3) Incomplete No See comment in Row 18. No associated data 

eligible to be compared to the NAAQS (Note 1: must 58.11 (e) assessment was provided, therefore, this requirement 

include required data assessment.) (Note 2: Required was not fully met. 

SLAMS must monitor PM2.

5 with NAAOScomparable monitor at the required sample 

frequency.) 

25. For SPMs listed as non-regulatory, note the start 58.20(c) Incomplete No See comment in Row 18. Both Humboldt Hill and 

Date ofFRM!FEM/ARM at SPM. If> 24 months, Weaverville PM2.

5 GRIMMs are SPMs. While start 

and monitor is eligible for comparison to the dates were provided and these instruments were 

NAAQS per 58.11 (e) and 58.30, the agency must called non-regulatory on pg 13, information was not 

supply information that App A, C or E requirements provided showing that App. A, C or E were not met. 

were not met. Unless information is provided and approved 

showing these monitors should be considered nonregulatory, the data will be considered regulatory. 

All other criteria pollutant SPMs are listed as being 

run for NAAQS comparison. 

26. Document how states and local agencies provide for 58.10 (c) Yes,pg 16 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) NA NA The plan did not request such an approval. 

alternative to appendix A requirements for SPMs 

operating a FRMIFEM/ ARM which also meets 

appendix.E? 

28. Precision/ Accuracy reports submitted to AQS 58.16(a); Yes,pg 17 Yes 

AppA, 1.3 

and 5.1.1 --- -- - - - - - - - - -

4 
ANP requirement Citation Was the info Does the Notes 

within 40 submitted?1 If information 

CFR58 yes, page #s. provided3 meet 

Flag if thereq?4 

incorrec;r? 

29. Annual data certification submitted 58.15 Yes,pg 17 Yes ARB has submitted data certification; NCU will take 

App. A 1.3 over this responsibility starting in 2013. 

30. Frequency of flow rate verification for manual PM AppA3.3.2 Yes, pg 18-27 Yes Recommend basing frequency of flow rate 

samplers audit verifications on the required calendar time-frame, as 

opposed to doing it by# sample runs. For PMIO hivol filter based instruments, this would be once every 

three months (as opposed to every 15 sampling runs). 

31. Frequency of flow rate verification for automated AppA3.2.3 Yes, pg 18-27 Yes 

PM analyzers audit 

32. Frequency of one-point flow tate verification for Ph AppA NA NA No Pb instruments. 

samplers audit 3.3.4.1 

33. Frequency of one-point QC check (gaseous) App.A3.2.1 Yes, pg 18-27 Yes 

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

(gaseous) 

35. Dates of last two semi-annual flow rate audits for App A, 3.2.4 No ? - insufficient info Did not include this information in the plan. Please 

PM monitors and 3.3.3 to judge whether include dates in subsequent plans. 

requirement is met 

36. Dates oflast two semi-annual flow rate audits for Pb AppA NA NA No Pb instruments. 

monitors 3.3.4.1 

37. PM2.s collocation App A 3.2.5 Incomplete - pg 16 NA NCU is part of the ARB PQAO, and relies on 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. 

(NCU does not currently have any collocated 

monitors.) Note: NCU's statement, "No collocation 

ofSPM monitors is required," pg 16 and 13, is not 

correct. Unless SPMs are non-regulatory, 

collocation is required as they are eligible for 

comparison to the NAAQS. 

38. Designation of a primary monitor if there is more Need to NA NA NCU does not have more than one monitor for a 

than one monitor for a pollutant at a site. determine pollutantat a site at this time. 

collocation 

39. Distance between collocated monitors (Note: waiver App.A NA NA No collocated monitors in NCU network. 

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 

requirement) 

5 
ANP requirement Citation Was the info Does the Notes 

within 40 submitted?1 If information 

CFR 58 yes, page #s. provided3 meet 

Flag if the req?4 

incorrecr? 

40. Manual PM10 method collocation met? (note: App A 3.3.1 No, not discussed NA NCU is part of the ARB PQAO, and relies on the 

continuous PM10 does not have this requirement) in plan. 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. 

(NCU does not currently have any collocated 

monitors.) 

41. Pb collocation AppA NA NA No Ph monitors 

3.3.4.3 

42. PM10 .. 2.s collocation (note: only applies to Fresno and AppA3.3.6 NA NA 

Phoenix NCore sites) 

43. Instrument/monitoring method code for each App C 2.4.1.2 Yes, pgs 18-27 Yes 

monitor: is it reported properly? Is it reported 

correctly (i.e., appropriate method code for 

regulatory monitors)? 

44. For agencies that share monitoring responsibilities in App D2(e) NA NA 

an MSNCSA: does each affected State or local i 

agency meet full monitoring requirements or is i 

an agreement between the affected agencies and the 

EPA Regional Administrator I in place? 

45. Start date for each monitor Required to Yes, pgs 18-27 Yes 

determine if 

otherreq. 

(e.g., min# 

and colloc) I 

are met 

46. Instrument monitor type for each monitor Required to Yes Yes 

determine if 

otherreq. 

(e.g., min# 

and coiloc) 

are met 

47. Monitoring objective for each instrument AppD 1.1 Yes, pgs 18-27 Yes 

58.10 CbX6) 

48. Site type for each instrument App D 1.1.1 Yes, but incorrect Yes EPA incorrectly identified "population oriented" as a 

in some instances site type in last year's response letter. NCU was 

correct that it should be "population exposure." 

49. Instrument parameter code for each instrument Required to Yes, pgs 18-27 Yes 

6 
ANP requirement Citation Was the info Does the Notes 

within 40 submitted?1 If information 

CFRS8 yes, page #s. provided3 meet 

Flag if the req?4 

incorrecr? 

determine if 

otherreq. 

(e.g., min# 

and colloc) 

are met 

so. Instrument parameter occurrence code for each, Required to Yes Yes 

instrument determine if 

otherreq. 

(e.g., min# 

and colloc) 

are met 

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

approval must be included if the sampling season App D, 4.1(i) ' 

deviates from requirement) 

52. Sampling schedule for PM2.

5 - applies to year-round 58.10 (b)(4) Yes, but incorrect - No Jacobs is listed as running an FRM. Per 40CFR58, it 

and seasonal sampling schedules (note: date of 58.12(d) pg 19 should be sampling at a I :3 sampling frequency, or 

waiver approval must be included if the sampling AppD4.7 be collocated with a continuous instrument. 

season deviates from requirement) EPA 

flowchart 

53. Sampling schedule for PM10 58.10 (b)(4) Yes Yes 

58.12(e) 

AppD4.6 

54. Sampling schedule for Pb 58.10 (b)(4) NA NA 

58.12(b) 

App04.5 

55. Sampling schedule for PM10 .. 2.s 58.10 (b)(4) NA NA 

58.12(f) 

AppD4.8 

56. Minimum# of monitors for 0 3 [Note: should be App D, 4.1(a) Yes Yes No ozone monitors required. 

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

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

57. Identification of max. cone. 0 3 monitor(s) AppD4.1 (b) NA NA While NCU does not have any required ozone sites, 

EPA recommends considering whether your network 

- --- - '--------- - - contains a max <!_zone monitor with your next 

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. 

7 
ANP requirement Citation Was the info Does the Notes 

within 40 submitted?1 If information I 

. CFR58 yes, page #s • provided3 meet 

Flag if the req?4 

incorrecf? 

network plan, or during your 5-year Network 

Assessment. 

58. Minimum monitoring requirements met for near- AppD4.3.2 Yes Yes No required N02 sites. 

road N02 (2014 start date) 

59. Minimum monitoring requirements met for area- ~ppD4.3.3 Yes Yes No required N02 sites. 

wideN02 

60. Minimum monitoring requirements met for RA-40 AppD4.3.4 Yes Yes No required N02 sites. 

N02 

61. Minimum monitoring requirements met for S~ AppD4.4 Yes Yes No required S02 sites 

[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 AppD4.5 Yes Yes No required Pb sites. 

[Note: Only monitors considered to be required 58.13(a) 

SLAMs are eligible to be counted towards meeting 

minimum monitoring requirements.] 

63. Minimum # of monitors for PM2.s [Note 1: should be . AppD, Yes Yes No required PM2.

5 sites. Running 1 SLAMs. 

supported by MSA ID, MSA population, DV, # 4.7.1(a) and 

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 NA NA Did not do. Do not have any required PM2.

5 sites per 

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

[Note: default will assume all SLAMS are requirements 

considered required sites.] 

65. Required PM2.5 sites represent area-wide air quality AppD NA NA No required PM2.

5 sites. Jacobs and Humboldt Hill 

4.7.1(b) are listed as neighborhood scale, 

66. For PM2_5, is at least one site at neighborhood or AppD NA NA While NCU does not have any required PMu sites, 

larger scale in an area of expected maximum 4.7.l(b)(l) EPA recommends considering whether your network 

concentration contains a max concentration monitor at a 

neighborhood or larger scale with your next network 

plan, or during your 5-year Network Assessment. 

67. If additional SLAMS PM2.s required, is there a site in AppD NA NA No required PM2.5 sites. NCU has one SLAMS 

an area of poor air quality 4.7.1(b)(2) PM2.s monitor. 

68. Minimum monitoring requirements for continuous AppD4.7.2 Yes Yes No required continuous PM2.s instruments. 

PM2.s ----- ---

8 
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? 

69. Requirements for PM2.s background and transport AppD4.7.3 NA NA No required PM2.s sites. 

sites 

70. Are PM2.s Chemical Speciation requirements met for AppD4.7.4 NA NA No STN sites in NCU .. 

official STN sites? 

71. Minimum # of monitors for PM10 AppD,4.6 Yes Yes All3 counties are nonattainment for the state PM10 

(a) and Table standard. Each county therefore has 1 SLAMS PM10 

D-4 monitor. There are no PM10 monitors required 

under federal requirements or plans. 

72. Minimum monitoring requirements met for PMu>.2.s AppD4.8 Yes Yes No PM1a-2.s monitors required. 

mass 

73. Distance of site from nearest road AppE6 Yes, pg 18-27 Yes 

74. Traffic count of nearest road AppE Yes, pg 18-27 Yes 

75. Groundcover AppE 3(a) Yes, pg 18-27 Yes 

76. Probe height AppE2 Yes, pg 18-27 Yes 

77. Distance from supporting structure AppE2 Yes, pg 18-27 Yes 

78. Distance from obstructions on roof AppE4(b) Yes, pg 18-27 Yes 

79. Distance from obstructions not on roof AppE4(a) Yes, pg 18-27 Yes Recommend noting how high the obstacle is above 

the probe in addition to distance. 

80. Distance from trees AppE5 Yes, pg 18-27 Yes 

81. Distance to furnace or incinerator flue AppE.3(b) Yes, pg 18-27 Yes 

82. Unrestricted airflow AppE, 4(a) Yes, pg 18-27 Yes 

and4@ ' 

83. Probe material (if applicable) AppE9 Yes, pg 18-27 Yes 

84. Residence time (if applicable) AppE9 Yes, pg 18-27 Yes 

9 
Public Comments on Annual Network Plan 

Were comments submitted to the S/L/T 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? ) 

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? 

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

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

o If yes, provide rationale: 

10