ST41UNITEDSTATESENVIRONMENTALPROTECTIONAGENCYlv.IREGIONIXPRO75HawthorneStreetSanFrancisco,CA94105-3901DEC1-72013KentFieldManager,AirMonitoringDivisionVenturaCountyAirPollutionControlDistrict669CountySquareDrive,2ndFloorVentura,California93003-5417DearMr.Field:ThankyouforyoursubmissionoftheVenturaCountyAirPollutionControlDistrict’s(APCD’s)2013AmbientAirMonitoringNetworkPlaninJuly2013.Wehavereviewedthesubmitteddocumentbasedontherequirementssetforthunder40CFR58.Basedontheinformationprovidedintheplan,EPAapprovesallportionsofthenetworkplanexceptthosespecificallyidentifiedbelow.Withthisplanapproval,wealsonotethatEPAHeadquartershasapprovedthefollowingchangetothePAMSnetwork,per40CFR58.11(c):discontinuationofcontinuoushydrocarbonsamplingatSimiValley-CochranStreetmonitoringstation.Pleasenotethatwecannotapproveportionsoftheannualnetworkplanforwhichtheinformationintheplanisinsufficienttojudgewhethertherequirementhasbeenmet,orforwhichtheinformation,asdescribed,doesnotmeettherequirementsasspecifiedin40CFR58.10andtheassociatedappendices.EPARegion9alsocannotapproveportionsoftheplanforwhichtheEPAAdministratorhasnotdelegatedapprovalauthoritytotheregionaloffices.Accordingly,thefirstenclosure(A.AnnualMonitoringNetworkPlanItemswhereEPAisNotTakingAction)providesalistingofspecificitemsofyouragency’sannualmonitoringnetworkplanwhereEPAisnottakingaction.Thesecondenclosure(B.AdditionalItemsRequiringAttention)isalistingofadditionalitemsintheplanthatEPAwishestobringtoyouragency’sattention.Thethirdenclosure(C.AnnualMonitoringNetworkPlanChecklist)isthechecklistEPAusedtoreviewyourplanforoverallitemsthatarerequiredtobeincludedintheannualnetworkplanalongwithourassessmentofwhethertheplansubmittedbyyouragencyaddressesthoserequirements.Thefirsttwoenclosureshighlightasubsetofthemoreextensivelistofitemsreviewedinthethirdenclosure.Allcommentsconveyedviathisletter(andenclosures)shouldbeaddressed(throughcorrectionswithintheplan,additionalinformationbeingincluded,ordiscussion)innextyear’sannualmonitoringnetworkplan.PnntedonRecycledPaperIfyouhaveanyquestionsregardingthisletterortheenclosedcomments,pleasefeelfreetocontactmeat(415)947-4534orDenaVallanoat(415)972-3134.Sincerely,MeredithKurpius,ManarAirQualityAnalysisOfficeEnclosures:A.AnnualMonitoringNetworkPlanItemswhereEPAisNotTakingActionB.AdditionalItemsRequiringAttentionC.AnnualMonitoringNetworkPlanChecklistcc:MichaelVillegas,VenturaCountyAPCDGayleSweigert,CaliforniaAirResourcesBoardA. 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), 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 you agency’s annual network plan where

a requirement

was not being met
or information

in the plan was insufficient

to judge whether

the requirement was being met based

on 40 CFR 58.10 and the associated appendices. Therefore,

we are not acting

on of the following items: Item

Checklist Row Issue Instrument monitor type

46 Incorrect

in one instance Parameter
code for each

49 Insufficient information

to judge

in one instrument

instance 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 [Item

4] EPA

is requesting

that documentation

of approvals

for all system modifications that are approved outside
the network plan be included

in the following network plan. The goal of including

this information

is to provide appropriate opportunities

for public comment

and improve transparency

of system modification decisions. • [Item 34] The requirement

to meet the biannual Annual Performance Evaluation (gaseous)

was described.

It would

be helpful

to provide

1-2 dates for verification. • [Item 35] The last two semi-annual

flow rate audits
for PM monitors

at Piru Station PM 25 FEM monitor
and Simi Valley PM monitors

are listed

as occurring

on 11/2012
and 5/2013.

Tn future,

if the last two flow rate audits occurred

in different calendar years, please
list dates for the three most recent audits
(ie, for

a plan submitted

in 2014, please list the two audits that occurred

in calendar year 2013,

as well

as any audits available from 2014). • [Item 44] Per 40 CFR
58 Appendix

D, section (2)(e),
the EPA Regional Administrator and state
or local agencies... “may divide
the overall MSAICSA 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. • [Items 52-5

3] If there

is no seasonal sampling

or alteration from expected sampling frequency,
then the “current sampling frequency”

and the “calculated sampling frequency” should

be the same. Please clarify

in next year’s plan.

### C. ANNUAL MONITORING NETWORK PLAN CHECKLIST (Updated 11/26/2013)

Year: 2013 Agency: Ventura County APCD

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, and Speciation (STN/CSN).

Please note that this checklist summarizes many of the requirements of 40 CFR Part 58, but does not substitute for those requirements, nor do its contents provide a binding determination of compliance with those requirements. The checklist is subject to revision in the future and we welcome comments on its contents and structure.
Key: White

= 

### meets the requirement. Yellow

= 

### requirement is not met, or information is insufficient to make a determination. Action requested in next year’s plan or outside the ANP process. (items listed in Enclosure A) Green item requires attention in order to improve next year’s plan (items listed in Enclosure B)

1

### ANP requirement Citation Was the info Does the Notes within 40 submitted? 1 If information CFR 58 yes, page #s. provided 3 meet Flag if the req? 4 incorrect 2

? Submit pian by July 1st 58.10 (a)(1) Yes, late Yes Plan was submitted on July 30, 2013. Submittal letter 2. Statement of purpose for each monitor 58.10 (a)(l) Yes Yes Table 3 (p. 8) Appendix A— detailed station information 3. 30-day public comment 

### I inspection period 5 58.10 (a)(1), Yes, cover letter Yes 58.10 (a)(2) 4. Modifications to SLAMS network

— case when we 58.10 (a)(2) Yes, p 13-21 Yes In summer or fall of2Ol3, the PM2.5 non-FEM

are not approving actual system modifications (i.e., 58.10(e) sampler will be replaced with a PM2.5 FEM sampler

we will do it outside the ANP process 6 ) at Simi Valley. Please contact EPA prior to requesting approval for this system modification. 5. Modifications to SLAJvIS network

— case when we 58.10 (a)(2) Yes, p 13-21 Yes Plan includes request to discontinue continuous

are approving actual system modifications per 58.10 (b)(5) hydrocarbon sampling at Simi Valley due to 58.14(c) 58.10(e) equipment failure and Ventura County’s future

, 58.14 (c) within the PAMs monitoring network. Per 4OCFRS8. 11(c), EPA headquarters has the authority to approve changes to the PAMS network. EPA headquarters has confirmed approval for discontinuation of the continuous hydrocarbon sampling at Simi Valley. See May 14, 2013 email. 6. Does plan include documentation (e.g., attached Yes, Appendix F Yes Plan includes attached approval letter for following approval letter) for system modifications that have system modifications: been approved since last ANP approval? -2012 monitoring scheme for the PM2.5 study, including the replacement of the Piru and Thousand Oaks FRMs with PM2.5 continuous FEMs.

- Final PM2.5 network as outlined in the letter, if the

Response options: NA (Not Applicable), Yes, No, Incomplete, Incorrect. The responses “Incomplete” and “Incorrect” assume that some information has been provided.
2 To the best of our knowledge.

Assuming the information is correct “Response options: NA (Not Applicable)

— [reason], Yes, No, Insufficient to Judge.

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

### ANP 

### requirement Citation Was the info Does the Notes within 40 submitted? 1 If information CFR 58 yes, page #s. provided 3 meet

. 

### Flag if the req? 4 incorrect 2

? study shows good agreement between FRMs and FEMs

- Discontinuation of the Ojai PM1O FRM

- Replacement ofPMl0 FRMs at El Rio and Simi Valley sites with FEMs for a comparison study in 2012 -Final PM1O network scheduled for 2013, with PM1O FEMs at El Rio and Suni Valley and 1:12 collocation with an FRM at Simi Valley 7. NCore site operational (by 1/1/2011) 58.10 (a)(3) N/A N/A 8. Pb site for 0.5-1.0 tpy sources operational (by 58.10 (a)(4) N/A N/A No requirement. 12/27/2011) 9. NO 2 plan for area-wide and RA4O sites submitted by 58.10 (a)(5) N/A N/A No requirement. 7/1/2012 10. NO 2 area-wide and RA4O sites operational by 58.10 (a)(5) N/A N/A No requirement. 1/1/2013 11. NO 2 

### plan for near-road sites submitted by 7/1/2013 58.10 (a)(5) N/A N/A Not required to install a N02 rear-road site until 2017. p 18-19 

### of the plan contains potential site information. 12. SO 2 sites operational 

### (by 1/1/20 13) 58.10 (a)(6) N/A N/A and 58.13(d) 13. AQS site identification number for each site 58.10 (b)(1) Yes, Appendix B Yes 14. Location of each site: street address and geographic 58.10 (b)(2) Yes, Appendix B Yes coordinates 15. Sampling and analysis method(s) for each measured 58.10 

### (b)(3) Yes, Appendix B Yes parameter 16. Any proposals to remove or move a monitoring 58.10 

### (b)(5) Yes, p13-21 Yes See item 4; Also, “VCAPCD anticipates evaluating station within a period of 18 months following plan the justification for continuing the CSN at the Simi submittal Valley monitoring site in a future annual network plan” 17. Scale of representativeness for each monitor as 58.10(b)(6); Yes, p 7-8 Yes defined in Appendix D App D 18. Identification of sites suitable and sites not suitable 58.10 (b)(7) Yes Yes for comparison to the annual PM 2

. 5 NAAQS as Appendix B

— described in Part 58.30 detailed station information 19. MSA, CBSA, CSA or other area represented by the 58.10 

### (bX8) Yes, Appendix C Yes



### 3

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

within 40 submifted?’ If information

CFR 58 yes, page #s. provided 3 meet
Flag if the req? 4

incorrect 2

? monitor 20. Designation of any Pb monitors as either source- 58.10 (b)(9) N/A N/A oriented or non-source-oriented 21. Any source-oriented Pb site for which a waiver has 58.10 (b)(1 0) N/A N/A been granted by EPA RA 22. Any Pb monitor for which a waiver has been 58.10 (b)(1 1) N/A N/A requested or granted by EPA RA for use of Pb-PM 10 in lieu of Pb-TSP 23. Identification of required NO 2 monitors as either 58.10 (b)(12) Yes, Section 3.2.4 Yes near-road or area-wide p18 24. Identification of any PM 2

. 5 FEMs and/or ARMs not 58.10 (b)(13) N/A N/A eligible to be compared to the NAAQS (Note 1: must 58.11 (e) include required data assessment.) (Note 2: Required SLAMS must monitor PM 25 with NAAOS comparable monitor at the required sample frequency.) 25. For SPMs listed as non-regulatory, note the start 58.20(c) N/A N/A Date of FRM/FEM/ARM at SPM. If> 24 months, and monitor is eligible for comparison to the NAAQS per 58.11 (e) and 58.30, the agency must supply information that App A, C or E requirements

were not met. 26. Document how states and local agencies provide for 58.10 (c) Yes, Appendix C Yes the review of changes to a PM 2

. 5 monitoring network that impact the location of a violating PM 2

. 5 monitor. 27. Does the plan include a request for approval for and 58.11 (a) (2) N/A N/A alternative to appendix A requirements for SPMs operating a FRM/FEMJARM which also meets appendixE? 28. Precision/Accuracy reports submitted to AQS 58.16(a); Yes, p 10 Yes AppA, 1.3 and 5.1.1 29. Annual data certification submitted 58.15 Yes, plO and Yes App. A 1.3 Appendix F 30. Frequency of flow rate verification for manual PM App A 3.3.2 Yes, Appendix B Yes samplers audit 31. Frequency of flow rate verification for automated App A 3.2.3 Yes, Appendix B Yes



### 4

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

within 40 submitted? 1 If information

CFR 58 yes, page #s. provided 3 meet

. Flag if the req? 4

incorrect 2

? PM analyzers audit 32. Frequency of one-point flow rate verification for Pb App A N/A N/A samplers audit 3.3.4.1 33. Frequency of one-point QC check (gaseous) App. A 3.2.1 Yes, Appendix B Yes 34. Date of last Annual Performance Evaluation App. A 3.2.2 Yes, Appendix B Insufficient The requirement to meet the biannual performance (gaseous) information to evaluation was described. It would be helpful to judge provide 1-2 dates for verification. 35. Dates of last two semi-annual flow rate audits for App A, 3.2.4 Yes, Appendix B Yes Audits noted for Piru Station PM2.5 FEM monitor PM monitors and 3.3.3 and Simi Valley PM monitors are from 11/2012 and 5/2013. In future, if the last two flow rate audits occurred in different calendar years, please list dates for the three most recent audits (ie, for a plan submitted in 2014 please list the two audits that occurred in calendar year 2013, as well as any audits available from 2014). 36. Dates of last two semi-annual flow rate audits for Pb App A N/A N/A monitors 3.3.4.1 37. PM 2

. 5 collocation App A 3.2.5 No N/A —PQAO Ventura County APCD is part of the ARB PQAO, requirement 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. (Ventura does not currently have any collocated PM2.5 monitors and there is one collocated PM1O FRM sampler at the Simi Valley monitoring station, located 3 meters from the primary PMIO FRM sampler). 38. Designation of a primary monitor if there is more Need to Yes, Appendix B, Yes than one monitor for a pollutant at a site. determine B-13 collocation 39. Distance between collocated monitors (Note: waiver App. A Yes Yes There is one collocated PM1O FRM sampler at the request or the date of previous waiver approval must 3.2.5.6 and Simi Valley monitoring station, located 3 meters be included if the distance deviates from 3.2.6.3

. from the primary PM1O FRM sampler. requirement.) 40. Manual PM 10 method collocation met? (note: App A 3.3.1 Yes, Appendix E N/A Addressed by PQAO continuous PM 10 does not have this requirement) 41. Pb collocation App A N/A N/A No requirement.



### 5

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

### within 40 submitted?’ If information

CFR 58 yes, page #s. provided 3 meet

Flag if the req? 4

incorrect 2

? 3.3.4.3 42. pM 10

. 2 5 collocation (note: only applies to Fresno and App A 3.3.6 N/A N/A Phoenix NCore sites) 43. Instrument/monitoring method code for each App C 2.4.1.2 Yes 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 D 2(e) Yes, Section 2.3.3 Insufficient to Per 40 CFR 58 Appendix D, section (2)(e), the EPA

an MSA/CSA: does each affected State or local judge Regional Administrator and state or local agencies
agency meet full monitoring requirements or is “may divide the overall MSAJCSA monitoring

an agreement between the affected agencies and the responsibilities and requirements among the various EPA Regional Administrator in place? 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. 45. Start date for each monitor Required to Yes, Appendix B Yes

. determine if other req. (e.g., min# and colloc)

are met 46. Instrument monitor type for each monitor Required to Yes, Appendix B Incorrect in one Non-FEM PM2.5 SLAMS monitor at Simi-Valley determine if instance Cochran Street listed code as 88501. A non-FEM other req. instrument should be an SPM, not a SLAMS. 

### (e.g., min # and colloc)

are met 47. Monitoring objective for each instrument App D 1.1 Yes, Table 3, p 8 Yes 

### 58.10 (b)(6) 48. Site type for each instrument App D 1.1.1 Yes, Appendix B Yes 49. Instrument parameter code for each instrument Required to Yes, Appendix B Insufficient to PM1O FEM at Simi-Valley Cochran Street is listed as determine if judge in one 81 102-3. Please clarify or correct in next year’s plan. other req. instance (e.g., mm # 

### 6

### ANP requirement Citation Was the info Does the Notes within 40 submitted? 1 If information CFR 58 yes, page #s. provided 3 meet Flag if the req? 4 incorrect 2

? and colloc)


### are met 50. Instrument parameter occurrence code for each Required to Yes, Appendix B Yes instrument determine if other req. (e.g., mm # 

### and colloc)

. 

### are met 51. Sampling season for ozone (note: date of waiver 58.10 

### (b)(4) Yes, Appendix B Yes approval must be included if the sampling season App D, 4.1(i) deviates from requirement) 52. Sampling schedule for PM 25

- applies to year-round 58.10 (b)(4) Yes, Appendix B Yes If there is no seasonal sampling or alteration from and seasonal sampling schedules (note: date of 58.12(d) expected sampling frequency, then the “current waiver approval must be included if the sampling App D 4.7 sampLing frequency” and the “calculated sampling season deviates from requirement) EPA frequency” should be the same. Please clarify in next flowchart year’s plan. 53. Sampling schedule for PM 10 58.10 

### (bX4) Yes, Appendix B Yes If there is no seasonal sampling or alteration from 58.12(e) expected sampling frequency, then the “current App D 4.6 sampling frequency” 

### and the “calculated sampling frequency” should be the same. Please clarify in next 

### year’s plan. 54. Sampling schedule for Pb 58.10 

### (b)(4) N/A N/A No requirement. 58.12(b) AppD4.5 55. Sampling schedule for pM 10

. 2 5 58.10 

### (b)(4) N/A N/A 58.12(f)

. AppD4.8 56. 

### Minimum # of monitors for 03 [Note: should be App D, 4.1(a) Yes, Appendix C Yes supported by MSA ID, MSA population, DV, # 

### and monitors, 

### and # required monitors] (see footnote) 7 Table D-2 57. Identification of max. conc. 03 monitor(s) App D 4.1 (b) Yes, Section 2.3.1 Yes 

### and AppendixB 58. 

### Minimum monitoring requirements met for near-road App D 4.3.2 N/A N/A Requirement begins in 2017. NO 2 (2014 start date)



### 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?’ If 

### information

CFR 58 yes, page #s. provided 3 meet
Flag if the req? 4

incorrect 2

? 59. Minimum monitoring requirements met for area- App D 4.3.3 N/A N/A There is no requirement for area-wide N02 wide NO 2 monitoring in Ventura County 60. Minimum monitoring requirements met for RA-40 App D 4.3.4 N/A N/A There are no N02 monitors required in Ventura NO 2 County for RA-40 monitoring. 61. Minimum monitoring requirements met for SO 2 App D 4.4 Yes, Appendix C, Yes [Note: Only monitors considered tobe required C-4 SLAMs are eligible to be counted towards meeting minimum monitoring requirements.] 62. Minimum monitoring requirements met for Pb App D 4.5 Yes, Appendix C, Yes [Note: Only monitors considered to be required 58.13(a) C-6 SLAMs are eligible to be counted towards meeting minimum monitoring requirements.] 63. Minimum # of monitors for PM 2

. 5 [Note 1: should be App D, Yes, Appendix C, Yes supported by MSA ID, MSA population, DV, # 4.7.1(a) and C-2 monitors, and # required monitors] [Note 2: Only Table D-5 monitors considered to be required SLAMs are eligible to be counted towards meeting minimum monitoring requirements.] 64. Optional PM 2

. 5 Network Clarifications: Provide a list Need to N/A N/A of required sites if it does not include all SLAMS. assess several [Note: default will assume all SLAMS are requirements considered required sites.] 65. Required PM 2

. 5 sites represent area-wide air quality App D Yes, Table 3 Yes 4.7.1(b) 66. For PM 25

, is at least one site at neighborhood or App D Yes, Table 3 Yes larger scale in an area of expected maximum 4.7.l(b)(1) concentration 67. If additional SLAMS PM 2

. 5 required, is there a site in App D N/A N/A

an area of poor air quality 4.7. 1(b)(2) 68. Minimum monitoring requirements for continuous App D 4.7.2 Yes, Appendix C, Yes PM 25 C-2 69. Requirements for PM 2

. 5 background and transport App D 4.7.3 N/A N/A sites 70. Are PM 2

. 5 Chemical Speciation requirements met for App D 4.7.4 Yes, Section 2.3.3 Yes official STN sites? 71. Minimum # of monitors for PM 10 App D, 4.6 Yes, Appendix C, Yes (a) and Table C-3



### 8ANP requirement Citation Was the info Does the Notes

. 

### within 40 submitted?’ If information

CFR 

### 58 yes, page 

### #s. provided 3 meet
Flag if the req? 4

incorrect 2

? D-4 72. Minimum monitoring requirements met for PM 1025 App D 4.8 N/A N/A PMIO-2.5 monitoring is required only at NCore mass stations and there is no requirement for an NCore station in Ventura 

### County. 73. Distance of site from nearest road App E 6 Yes, Appendix B Yes 74. Traffic count of nearest road App E Yes, Appendix B Yes 75. Groundcover App E 3(a) Yes, Appendix B Yes 76. Probe height App E 2 Yes, Appendix B Yes 77. Distance from supporting structure App E 2 Yes, Appendix B Yes 78. Distance from obstructions on roof App E 4(b) Yes, Appendix B Yes 79. Distance from obstructions not on roof App E 4(a) Yes, Appendix B Yes 80. Distance from trees App B 5 Yes, Appendix B Yes 81. Distance to furnace or incinerator flue App E 3(b) Yes, Appendix B Yes 82. Unrestricted airflow App E, 4(a) Yes, Appendix B Yes and 4(b) 83. Probe material (if applicable) App E 9 Yes, Appendix B Yes 84. Residence time (if applicable) App E 9 Yes, Appendix B Yes



### Public Comments on 

### Annual Network Plan Were comments submitted to the S/LIT agency during the public comment period? If no, skip the remaining questions. If yes: No.

• 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 wasn’t adequate)?

• Are the sections of the annual network plan that received substantive comments approvable after consideration of comments?
o If yes, provide rationale:

9