UNITEDSTATESENVIRONMENTALPROTECTIONAGENCYREGIONIX075HawthorneStreetSanFrancisco,CA94105.3901JUNO92008Ms.KarenMagliano,ManagerAirQualityDataBranchPlanningandTechnicalSupportDivisionAirResourcesBoardCaliforniaEnvironmentalProtectionAgencyP.O.Box2815Sacramento,CA95812DearMs.Magliano:Thankyouforyoursubmissionofthe“AnnualMonitoringNetworkPlanfortheSmallDistrictsinCalifornia,Volume1”,datedJune2007.Werecognizethatproducingthisdocumentandtheassociatedpublicinspectionprocessrepresentednewrequirementsandweappreciateyourefforttomeetthem.WehavereviewedthesubmitteddocumentandhavefoundthatitdoesnotfullymeettheQminimumrequirementssetforthunder40CFRPart58.10.Thecommentsenclosedwiththisletteridentif’severalareasinthePlanwhereadditionalinformationisrequestedinordertocompletethedocumentandfullysatisfytherequirementsof40CFRPart58.10.Ratherthanattempttoresolvethesedatagapsinthisdocument,werequestthatARBaddresstheenclosedcommentsinfuturenetworkplans.Ifyouhaveanyquestionsregardingthisletterortheenclosedcomments,pleasefeelfreetocontactmeat(415)972-3261orCatherineBrownat(415)947-4137.Sincerely,AirQualityAnalysisOfficeEnclosurecc:3.CookK.Stroud0PrintedonRecycledPaperQ Review

of: “Annual Monitoring Network Report
for Small Districts

in California Volume

1”, June 2007, California EPA, Air Resources Board General Comments The subject network plan submitted

by ARB

in fulfillment

of 40 CFR Part 58.10 does not fully meet EPA’s reporting requirements

and the organization

of the Plan

is difficult

to follow, particularly

for

a member

of the public. Included with these comments

is
a copy of the template EPA provided

to assist districts with preparing

the annual plans. This template includes

a list of the elements required

by 40 CFR Part 58.10 and

a suggested organization which we advise ARB follows

in developing future network plans. Also, recognizing

that ARB already produces

a “California
State and Local Air Monitoring Network Plan” which covers some of the elements required

by 40 CFR Part 58.10,
we suggest considering options

to augment
this document

to fulfill EPA annual network plan requirements. Attempting

to meet EPA’s requirements through two separate submitlals presents organizational
issues which might
be more easily addressed

if the information was consolidated

into one document. For reference, listed below
are examples

of network plans that we found

to fully meet the requirements

of 40 CFR Part 58.10. Annual Network Plan for the Bay Area Quality Management District Q
(http ://www.baagmd. gov/tec/aammet/network_plan.htm) Annual Network Plan for San Diego Air Pollution Control District (http://www.sdapcd.org/index.html) Also, please note that

a final hardcopy version

of the annual network plan should

be submitted,
with

a signed cover letter,

to Sean Hogan, Manager

of the Air Quality Analysis Office. In meeting

the requirements

of 40 CFR Part 58.10, the network plan should provide

a comprehensive picture

of the ARB ambient

air monitoring network
and thereby give the general public

an understanding

of the scope
of air monitoring

in the State. This should include discussion

of the federal monitoring programs

and ARB involvement

(i.e. IMPROVE, PAMS, NCORE, SLAMS). Section

1- Purposes, Scope and Organization

of Report This section states there are fourteen local districts reporting separately

on their jurisdictions.

The document should more clearly explain
the scope
of ARB’s jurisdiction throughout

the State and how

it interacts with these fourteen districts.

For example, does ARB have statewide jurisdiction

and

a role
in ensuring
that these agencies develop
and submit annual network plans? 0