Planning and Technical Support DivisionAir Resources Board

California Environmental Protection Agency

P.O. Box 2815

Sacramento, CA 95812

Dear Ms. Magliano:

Thank you for your submission ofthe “Annual Monitoring Network Plan for the Small

Districts in California, Volume 1”, dated June 2007. We recognize that producing this document

and the associated public inspection process represented new requirements and we appreciate

your effort to meet them.

We have reviewed the submitted document and have found that it does not fully meet the

Q minimum requirements set forth under 40 CFR Part 58.10. The comments enclosed with this letter identif’ several areas in the Plan where additional information is requested in order to

complete the document and fully satisfy the requirements of 40 CFR Part 58.10. Rather thanattempt to resolve these data gaps in this document, we request that ARB address the enclosed

comments in future network plans.

If you have any questions regarding this letter or the enclosed comments, please feel free

to contact me at (415) 972-3261 or Catherine Brown at (415) 947-4137.

Sincerely,

Air Quality Analysis Office

Enclosurecc: 3. Cook

K. Stroud

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Printed on Recycled Paper
ofthe template EPA provided to assist districts with preparing the annual plans. This

template includes a list ofthe 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 ofthe 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 ifthe 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 ofthe Air Quality

Analysis Office.

In meeting the requirements of 40 CFR Part 58.10, the network plan should provide a

comprehensive picture ofthe ARB ambient air monitoring network and thereby give the

general public an understanding ofthe scope of air monitoring in the State. This should

include discussion ofthe federal monitoring programs and ARB involvement (i.e.

IMPROVE, PAMS, NCORE, SLAMS).Section 1- Purposes, Scope and Organization ofReport

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?

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