Mr. Justin Green Director UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION4 ATLANTA FEDERAL CENTER 61 FORSYTH STREET ATLANTA, GEORGIA 30303·8960 October 29, 2015

Division of Air Resources Management Florida Department of Environmental Protection 2600 Blair Stone Road Tallahassee, Florida 32399-2400 Dear Mr
. Green: Thank you for submitting the State ofFlorida's 2015 annual ambient air monitoring network plan (Network Plan) dated May 2015. The Network Plan is required by 40 Code of Federal Regulations (CFR) § 58.10. The Network Plan covers the ambient air monitoring network operated by the Florida Department of Environmental Protection (FDEP) and the local air quality agencies in Florida. The U
. S. Environmental Protection Agency Region 4 understands that FDEP provided the public a 30- day review period and received no comments . According to 40 CFR § 58.10(a)(2), since public inspection and comments have already been solicited, the EPA is not required to offer another comment period. The EPA approves the State's 2015 Network Plan with the exception ofthe proposals for three monitoring sites
. As we have discussed, once you have all the information needed for full evaluation of these proposed sites (two near-road monitoring sites and one source-oriented S02 site) we will review and respond to your request as discussed in the enclosure. After we have reached an agreement with the proposed locations for these sites, the state will need to make that information available for public inspection
. Upon completion ofthe public inspection process, an addendum to the Network Plan will need to be submitted to the EPA Region 4 for approval. We have enclosed comments on the Network Plan and details of our review. Thank you for working with us to monitor air pollution and promote clean air in Florida. If you have any questions or concerns, please contact Gregg Worley at (404) 562-9141 or Daniel Garver at (404) 562-9839
. Sincerely, 

# iE£**J.t~ ;.** **~** /1-"ir Air, Pesticides and Toxics Management Division
Enclosure
Internet Address (URL) • http://www.epa.gov Recycled/Recyclable • Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Postconsumer)cc: Mr. Jeffery Halsey Director, Air Quality Division, Broward County Ms
. Mallika Muthiah Chief, Miami-Dade County Air Quality Management Division Ms. Melissa Long Chief, Environmental Quality Division, City ofJacksonville Mr. Jerry Campbell, PE Director, Hillsborough County Environmental Protection Commission, Air Management Division Mr. Ajaya Satyal Director, Pinellas County Air Quality Division Mr. Laxmana Tallam Palm Beach County Divis ion of Environmental Health and Engineering Services, Air Pollution Control Section Ms
. Renee Parker Environmental Programs Supervisor, Orange County Environmental Protection Division Air Pollution Control Program Mr. Ray Smith Director, Collier County Pollution Control & Prevention Department Mr
. Greg Blanchard Air Quality Manager, Manatee County Environmental Management Department Mr. John Hickey, P.E
. Manager, Sarasota County Air & Water Quality Ms
. Laura Ackennan EPA Regi on 4 SESD

### 2015 State ofFlorida Ambient Air Monitoring Network Plan U.S. EPA Region 4 Comments and Recommendations
This document contains U.S. EPA Region 4 comments and recommendations on the state ofFlorida's 2015 ambient air monitoring network plan (Network Plan). Ambient air monitoring rules, which include regulatory requirements that address network plans, data certification, and minimum monitoring requirements, among other requirements, are found in 

### 40 CFR Part 58. Minimum monitoring requirements for criteria pollutants are listed in 

### 40 CFR Part 58, Appendix D. Minimum monitoring requirements are listed for ozone (OJ), particulate matter less than 2.5 microns (PM2.s), particulate matter less than 10 microns (PMto), nitrogen dioxide (N02), sulfur dioxide (SOz), carbon monoxide (CO), and lead (Pb). The minimum monitoring requirements are based on core based statistical area (CBSA) boundaries as defmed by the U.S
. Office of Management and Budget (OMB), July 1, 

### 2014, population estimates from the U.S. Census Bureau, and historical ambient air monitoring data. Minimum monitoring requirements for OJ, PM2.s, and PMto, only apply to metropolitan statistical areas (MSAs), which are a subset of CBSAs. OMB currently defines 29 CBSAs in the state ofFlorida. These CBSAs and the respective July 1, 2014, population estimates from the U.S. Census Bureau are shown in Table I. Table 1: Core Based Statistical Areas and July 1, 2014 Population Estimates

CBSA Name CBSA Type Population Miami-Fort Lauderdale-West Palm Beach, FL Metropolitan Statistical Area 5,929,819 Tampa-St
. Petersburg-Clearwater, FL Metropolitan Statistical Area 2,915,582 Orlando-Kissimmee-Sanford, FL Metropolitan Statistical Area 2,321,418 Jacksonville, FL Metropolitan Statistical Area 1,419.127 North Port-Sarasota-Bradenton, FL Metropolitan Statistical Area 748,708 Cape Coral-Fort Myers, FL Metropolitan Statistical Area 679,513 Lakeland-Winter Haven, FL Metropolitan Statistical Area 634,638 Deltona-Daytona Beach-Ormond Beach, FL Metropolitan Statistical Area 609,939 Palm Bay-Melbourne-Titusville, FL Metropolitan Statistical Area 556,885 Pensacola-Ferry Pass-Brent, FL Metropolitan Statistical Area 474,081 Port St. Lucie, FL Metropolitan Statistical Area 444,420 Tallahassee, FL Metropolitan Statistical Area 375,751 Ocala, FL Metropolitan Statistical Area 339,167 Naples-Immokalee-Marco Island, FL Metropolitan Statistical Area 348,777 Gainesville, FL Metropolitan Statistical Area 273,377 Crestview-Fort Walton Beach-Destin, FL Metropolitan Statistical Area 258,042 Panama City, FL Metropolitan Statistical Area 194,929 Punta Gorda, FL Metropolitan Statistical Area 168,474 Homosassa Springs, FL Metropolitan Statistical Area 139,377 Sebastian-Vera Beach, FL Metropolitan Statistical Area 144,755 Sebring, FL Metropolitan Statistical Area 98,236 The Villages, FL Metropolitan Statistical Area 114,350 Palatka, FL Micropolitan Statistical Area 72.143



### 3Key West, FL. Lake City, FL Okeechobee, FL. Clewiston, FL. Arcadia, FL Wauchula, FL 

### Proposed Monitoring Network Changes 40 CFR § 58.10(b), 58.14 Micropolitan Statistical Area 77,136 Micropolitan Statistical Area 67,857 Mi cropolitan Statistica l Area 39, 149 Micropolitan Statistical Area 38,505 Micropolitan Statistical Area 35,012 Micropolitan Statistical Area 27,469



### In the Network Plan, FDEP has proposed several new monitoring sites. The Daniela Banu NCore site in Broward County, the St. Marks NCore site, and the Orlando 1-4 near-road site have been approved by EPA in previous Net work Plans. The remainder ofthe Network Plan changes will require FDEP to submit additional information before they can be approved. FDEP is requesting to submit final proposals for these proposed network additions or discontinuations that include all ofthe information required for approval by40 CFR §58.10(b) or §58.14, as applicable. Once EPA Region 4 and FDEP are in agreement about the details of these sites, the proposals should be submitted as an addendum to the 2015 Network Plan or as part ofthe 2016 plan, and should be made available for public inspection before submittal to EPA for approvaL The following three proposed sites must begin operating in order for the FDEP monitoring network to meet minimum requirements : the MDX near-road site in Miami-Dade County, the Sawgrass Lake Parkway near-road site in Pinellas County, and the source-oriented S02 site near the Duke Energy Crystal River Steam Plant in Citrus County. A summary of the monitoring network changes proposed by**FDEP ~**  and EPA's responses are provided in Table 2. Table 2: Proposed Monitoring Network Changes

CBSAName County Site Name AQSID Pollutants EPA Action Miami-Fort Miami-Dade MDX Near Road 12-086-0035 N01
. co Additional Lauderdale-West information Palm Beach required for a roval Tampa-S t. Pinellas Sawgrass Lake Parkway 12-1 03-0027 N02, CO, Black Additional Petersburg- Near Road Ca rbon information Clearwater required for a roval Homosassa Springs Citrus Power Line Road

- j 2

-0 17-0006 so2 Additional source-ori ented site near information Duk e Energy Crystal required for River Sream Plant approval Orlando- Orange 1-4 Near Road 12

-095

-0009 N01.co. Site proposal Kissimmee- Continuous previously Sanf ord PMzs
. approved Meteorology Miami-Fort Broward Daniela Banu NCore 12

-011

-0034 Additional Site proposal la uderdale-West NCore-required previously Palm Beach parameters, Air approved Toxics

4CBSA Name Tampa

-St. Petersburg

Clearwater Tampa

-St. Petersburg

Clearwater Jacksonville

Miami-Fort Lauderdale

-West Palm Beach Miami-Fort Lauderdale

-West Palm Beach

M

iami-Fort Lauderdale

-West Palm Beach County Hillsborough
Hillsborough

Duval

Broward

Palm Beach

Palm Beach Site Name Apollo Beach
TBD
TBD

UF Agricultural Research Center Royal Palm

Lamstein Lane AQSID Pollutants TBD
TBD Pb
TBD Pb

12-011 - 1002 Continuous PM25
12

-099

-0009 OJ, PM2.s

TBD EPA Action Additional information required for a roval Additional information required for a ·

· - roval Additional information required for a roval Discontinuation, move to NCore. Change a roved. Proposed to move site to Lamstien Lane, additional information required for a roval Proposed to relocate from Royal Palm, additional information required for approval FDEP has also proposed to change the monitoring objective for several PM2.s and OJ sites in its network from population exposure to high concentration
. EPA understands that FDEP is making these changes in conjunction with its network assessment, and has identified these sites as high concentration based on analysis of several factors including historical data, local emissions, and meteorology. EPA approves the monitoring objective changes proposed in the Network Plan. 

### Operating Schedules 40 CFR § 

### 58.12 The monitoring network proposed in the Network Plan meets the required operating schedules for all continuous analyzers and all manual Pb, PM 10, PM2.s
. and PM2.s Speciation Trends Network (STN) monitors
. FDEP has not proposed any changes to its operating schedules in the Network Plan
. 

### Air Quality Index (AQI) Reporting 40 CFR § 

### 58.50



### 5AQI reporting is required in MSAs with populations over 350,000
. There are 12 MSAs in the state that are required to report an AQI: Miami-Fort Lauderdale

-West Palm Beach, Tampa-St. PetersburgC learwater, Orlando-Kissimmee-Sanford, Jacksonville, North Port-Sarasota-Bradenton, Cape Coral-Fort Myers, Lakeland-Winter Haven, Deltona-Daytona Beach-Ormond Beach, Palm Bay-MelbourneTitusville, Pensacola-Ferry Pass-Brent, Port St. Lucie, and Tallahassee. The Network Plan includes a link on Page 10 to the FDEP website where this information is available
. The AQI reporting requirements are currently being met. 

### National Core (NCore) Monitoring Network 40 

### CFR Part 58 Appendix D, 3.0 FDEP has designated three NCore sites: Sydney Road in Tampa (AQS ID : 12-057

-3002) , Daniela Banu in Broward County (AQS ID: 12

-011-0034). and St. Marks National Wildlife Refuge (AQS ID : 12-129- 0001). These sites satisfy the requirements for NCore monitoring and have been approved b y the EPA's Office ofAir Quality Planning and S t andards
. The St. Marks NCore site was established in 2014 as a rural NCore site
. 

### 03 ,.1 ;,, ; , uirements 40 ppendix D, Table D

-2 The stm c nf Florida's proposed 0 3 monitoring network meets the minimum requirements found in 40 CFR 

### Pn·· \ r p ·dix D, Table D-2 for all MSAs. Additionally, the proposed 03 monitoring network desr. work Plan meets all of the design criteria of40 CFR Part 58
. 

### CO Monitoring Requirements 40 

### CFR J>art 58, Appendix D, 4.2 Beginning January 1, 2015, CO monitoring was required at near-road monitoring sites in CBSAs with populations greater than 2,500,000
. CO monitoring will be required at a near-road monitoring site in C BSAs with populations greater than 1,000,000 beginning on January 1, 2017. The Network Plan indicates that CO monitoring is ongoing at the Hillsborough County near-road site in the Tampa-St. Petersburg· Clearwater CBSA, and the Broward County near-road site in the Miami-Fort LauderdaleMiami Beach CBSA. Therefore, the CO monitoring network described in the Network Plan meets all of the design criteria of40 CFR Part 58. 

### N02 Monitoring Requirements 40 

### CFR Part 58, Appendix D, 4.3 Ambient air monitoring network design criteria for N02 are found in Section 4
.3 of Appendix D to 40 CFR Part 58. Three types of N02 monitoring are required: near-road, area-wide, and Regional Administrator. These types of N02 monitoring are described in se ctions 4.3.2, 4.3.3, and 4.3
.4, respectively. Ambient air monitoring design crit eria for near-road N02 monitoring sites are found in section 4.3
.2 of Appendix D to 40 CFR Part 58
. Near-road monitoring stations are currently operating in the following


### 6CBSAs : Tampa-St. Petersburg-Clearwater (in Hillsborough County), Miami-Fort Lauderdale-West Palm Beach (in Broward County), and Jacksonville
. The Network Plan also includes proposed near-road sites in the following CBSAs: Tampa-St. Petersburg-Clearwater (in Pinellas County), Miami-Fort Lauderdale-West Palm Beach (in Miami-Dade County}, and Orlando-Kissimmee-Sanford (in Orange County). The Orlando near-road site was previously approved as part of the 2014 Network Plan. Second near-road monitoring sites were required to begin operation on January 1, 2015 in the MiamiFort Lauderdale-West Palm Beach and Tampa-St. Petersburg-Clearwater CBSAs. New sites in MiamiDade County and Pinellas County are proposed in the Network Plan to meet these requirements, but more information about these sites is required for approval. Once the details of these sites are finalized, the state will need to submit an addendum to the Network Plan containing these site proposals. The addendum must include all of the required information for proposed sites under 40 CFR §58
. 1 O(b), and should also include additional information about the proposed near-road monitoring sites
. Section 13
.5 of the near-road N02 Technical Assistance Document (TAD) 1 and Table 13
. 1 of the TAD discuss important site and road parameters when evaluating a near-road site. Using the TAD as a reference, additional information provided on near-road 

### NOz monitoring should include, at minimum, the following information for each site:
• Proposed AQS ID • Street address and site geographical coordinates (longitude and latitude) • Target road segment description including type of road • Site pictures facing 4-8 directions- N, S, E, W, NE, NW, SE, SW • Probable distance between the inlet probe and the outside nearest edge of the target road • Probable probe height of the inlet probe from ground level • Site property description including property owner and feasibility of site access • Roadway design and configuration • Presence of any roadside structures • Nearest wind rose representative of the site and orientation of the site with respect to the predominate wind direction • Traffic data and ranking information (see Table 6-3 ofthe Technical Assistance Document), as well as the source and vintage of the data • Sampling and analysis method(s) for each measured parameter • Operating schedules for each monitor at the site • Monitoring objective and spatial scale of representativeness for each monitor at the site. • MSA, CBSA, CSA or other area represented by the monitor • Other evidence that siting criteria are being met, including measurements to any nearby obstructions or trees. Once EPA Region 4 is in agreement with the proposed near-road sites, the state will need to make the information available for public inspection. Upon completion of the public inspection process, the Network Plan addendum will need to be submitted to EPA Region 4 for approval. We will continue to

1 Near-road N02 Monitoring Technical Assistance Document. Office ofAir Quality Planning and Standards, U
.S. Environmental Protection Agency, Research Triangle Park, North Carolina. EPA-454/B-12-002
. June 2012
. http :1/www
.epa.gov/ttnamti liftles/nearroad/NearRoadTAD.pdf.
7work with your agency as needed to facilitate the establishment ofthese sites as expeditiously as possible
. Section 4.3
.2 of Appendix D to 40 CFR Part 58 also requires CBSAs with populations between 500,000 and 1,000,000 people to operate a near-road NOz monitor starting in January 1, 2017
. Florida has five CBSAs with populations in this range: North Port

-Sarasota

-Bradenton, Cape Coral· Fort Myers, Lakeland-Winter Haven, Deltona-Daytona Beach-Ormond Beach, and Palm Bay

-Melbourne-Titusville. As a result ofthe 5-year NAAQS review cycle, the NOz monitoring requirements may be modified in 2016. The N02 near-road monitoring requirements may change for CBSAs with populations between 500,000 and 1,000,000 people, such as the Florida CBSAs listed above
. Ambient air monitoring network design criteria for area-wide N02 sites are found in section 4.3.3 of Appendix D to 40 CFR Part 58. The area-wide NOz monitoring network described in the Network Plan meets the requirements of Section 4.3.3 in all areas. These sites are summarized in Table 3. Table 3: Area-wide NOz Monitoring Sites

CBSA Name County Jacksonville Duval Miami-Fort Lauderdale- Broward Miami Beach Orlando

-KissimmeeSanford Tampa-St. PetersburgClearwater Orange Pinellas Site Name Kooker Park John U Lloyd State Park Winter Park Azalea Park AQSID 12-031

-0032 12-0 I 1-8002 12

-095-2002 12-103

-00 18
Ambient air monitoring network design criteria for Regional Administrator required NOz monitoring, often referred to as RA-40 monitoring, are found in section 4.3.4 of Appendix D to 40 CFR Part 58
. Under these provisions Regional Administrators must require a minimum of 40 additional NOz monitoring stations nationwide, with a primary focus on siting these monitors in locations to protect susceptible and vulnerable populations. EPA and FDEP have previously identified the monitor at the Coral Reef site (AQS ID: 12-086-0031) in Miami-Dade County as required under Section 4.3.4
. The full list of NOz monitors identified by the Regional Administrators can be found on EPA's website at http://www.epa.gov /ttnamti 1/<;vpop .html. 

### S02 Monitoring Requirements 40 CFR 

### Part 58, 

### Appendix D, 4.4 Ambient air monitoring network design criteria for SOz are found in Section 4.4 of Appendix D to 40 CFR Part 58. This section requires that "The population weighted emissions index (PWEI) shall be calculated by states for each core based statistical area (CBSA)
. . ." The S02 monitoring site(s) required in each CBSA will satisfy minimum monitoring requirements if the monitor(s) is sited within the boundaries of the parent CBSA and is of the following site type(s): population exposure, maximum concentration, source-oriented, general background, or regional transport. An SOz monitor at an NCore station may satisfy minimum monitoring requirements if that monitor is located within a CBSA with required monitors under Appendix D, 4.4
.



### 8FDEP is proposing a new site in the Homosassa Springs CBSA to meet the PWEI requirement (AQS ID: 12-017-0006). However, the Network Plan does not include all of the required information about this site for approval. FDEP will need to submit an addendum to the Network Plan that contains a full proposal for this site. The addendum must include all ofthe required information for proposed sites under 40 CFR §58.10(b). The addendum should also include supporting information about how the site location was selected, such as site photos, maps, wind roses, and information about the target source including any air modeling that was conducted to inform the site selection. The addendum should be made available for public inspection under40 CFR § 58.10(a)(l), and then submitted to EPA Region 4 for approval. All other applicable CBSAs in Florida are now meeting the requirements for S02 PWEI monitoring. EPA finalized the S02 Data Requirements Rule (DRR) (see 80 Federal Register, No. 162) on August, 21, 2015. This rule will require characterization of the air quality near sources with S02 emissions greater than 2,000 tons per year by conducting ambient air monitoring or modeling. We encourage your agency to begin having conversations with affected sources in your state to determine an agreed upon approach for meeting the DRR requirements. By January 15, 2016, FDEP must submit a final list to EPA Region 4 identifying the sources in the state around which S02 air quality must be characterized. For sources that FDEP decides to evaluate using ambient air monitoring, new site proposals must be included in the 2016 Network Plan. The location of these monitoring sites should be selected using the process outlined in the S02 NAAQS Designations Source-Oriented Monitoring Technical Assistance Document2

. 

### Pb Monitoring Requirements 40 CFR 

### Part 58, 

### Appendix D, 4.5 40 CFR Part 58, Appendix D, 4.5 requires that "At a minimum, there must be one source-oriented SLAMS [state and local air monitoring station} site located to measure the maximum Pb concentration in ambient air resulting from each non-airport Pb source which emits 0.50 or more tons per year and from each airport which emits 1.0 or more tons per year..." Monitoring is ongoing as required near Envirofocus Technologies Inc. in Tampa. FDEP has also submitted revised Pb emissions for one facility that had emissions greater than 0.5 tons per year in the 2011 National Emissions Inventory: IFF Chemical Holdings, Inc. in Jacksonville. EPA accepts these revised emissions calculations, and agrees that the actual Pb emissions from this source are below 0.5 tons per year. Therefore, Pb monitoring is not required near this source. 40 CFR Part 58, Appendix D, 3(b) requires that "NCore sites in CBSA with a population of 500,000 people (as determined in the latest Census) or greater shall also measure Pb either as Pb-TSP or PbPMJO." The Network Plan indicates that Pb-PMw sampling is ongoing at the Tampa NCore site (AQS ID: 12-057-3002) and will begin at the Broward County NCore site (AQS ID: 12-011-0034) soon. The Pb monitoring network described in the Network Plan meets all ofthe design criteria of40 CFR Part 58.

2 S02 NAAQS Designations Source-Oriented Monitoring Technical Assistance Document. U.S. EPA Office of Air Quality Planning and Standards Air Quality Assessment Division, Draft December 2013. hnp :1/www3.epa. gov/airquaI ity/sulfurd ioxide/pdfs/SO2Monit oringTAD. pdf
9

### PMto Monitoring Requirements 40 CFR Part 58, Appendix A, 3.3.1 40 CFR Part 58, Appendix D, 4
.6 and Table D-4 The state of Florida's PMw monitoring network meets the minimum requirements found in 40 CFR Part 58, Appendix D, Table D-4 for all MSAs. Also, all PM

### to collocation requirements for manual methods found in 40 CFR Part 58, Appendix A, Section 

### 3.3
. 1 are being met. Fifteen percent of each networ k of manual PM

### to methods (at least one site) must be collocated. These collocation requirements are asses sed at the primary quality assurance organization (PQAO) level. The state of Florida and all of its local agencies operate under a single PQAO (FDEP). The PM

### to monitoring network described in the Network Plan meets all ofthe design criteria of40 CFR Part 58
. 

### PMz.s Monitoring Requirements 40 CFR Part 58, Appendix A, 3.2.5 40 CFR Part 58, Appendix D, 4. 7 and Table D-5 The state ofFlorida's PM2.s monitoring network meets the minimum requirements found in 40 CFR Part 

### 58, Appendix 

### D, Table 

### D-5 for all MSAs. Also, all PM2.s collocation requirements found in 40 CFR Part 

### 58, Appendix A, Section 

### 3
.2
.5 are being met. Fifteen percent of each network of manual PM2
.s methods (at least one site) must be collocated. Beginning January 

### 1, 2015, PM2
.s monitoring is required at near· road monitoring sites in CBSAs with populati ons greater than 

### 2,500,000
. PM2
. s monitoring will be required at a near-road monitoring site in CBSAs with populations greater than 

### 1,000,000 beginning on January 

### 1, 2017. The Network Plan indicates that PM2
.s monitoring is ongoing at the Hillsborough County near-road site in the Tampa-St. Petersburg-Clearwater CBSA, and at the Broward County near-road site in the Miami-Fort LauderdaleMiami Beach CBSA
. The PM2
.s monitoring network described in the Network Plan meets all ofthe design criteria of40 CFR Part 58. 

### PM2.s Continuous Monitoring Requirements 40 CFR Part 58, Appendix D, 4.7.2 Regulatory requirements f or continuous PM2 .s monitoring require that
.. ...State, or where appropriate, local agencies must opera te continuous PM2.s analyzers equal to at least one-half (round up) the minimum required sites listed in Table 

### D

- 5 ofthis appendix. At least one required continuous analyzer in each MSA must be collocated with one of the required FRMIFEM/ARM [federal reference method/federal equivalent method/approved regional method] monitors, unless at least one of the required FRMIFEM/ ARM monitors is itselfa continuous FEM or ARM monitor in which case no collocation requirement applies : · These minimum continuous PM2
.s monitoring requirements are met in the all ofthe MSAs in the state. Also, the continuous PM2
.s collocation requir ements are met in all MSAs
. Therefore, the continuous PM2.s monitoring network described in the Network Plan meets all of the design criteria of40 CFR Part 

### 58
. 

### PM2.s Background and Transport Sites 40 CFR Part 58, Appendix D, 4.7.3


### 1040 CFR Part 58, Appendix D, 4.7.3 requires that "each state shall install and operate at least one PM2.s site to monitor for regional background and at least one 

### PMz.s site to monitor for regional transport." The Network Plan identifies the Interagency Monitoring for Protected Visual Environments (IMPROVE) PM2.s sites at the St. Mark's National Wildlife Refuge (AQS ID: 12-129-0001) and the Everglades National Park (AQS ID: 12-086-0030) as background sites and the IMPROVE PM2.s site at the Chassahowitzka National Wildlife Refuge (AQS ID: 12-017-9000) as a transport site
. Therefore, FDEP has satisfied the requirements of40 CFR Part 58 for background and transport sites.**P~b.s** 

### Continuous Federal Equivalent Methods 40 CFR § 

### 58.10(e) EPA regulations contain provisions for handling data collected using continuous PM2
.s FEMs. These procedures are found at 40 CFR § 58
. 1 0(e)
. Ifan agency can demonstrate that the FEM data are not of sufficient comparability to a collocated FRM, then the monitoring agency may request that the FEM data not be used in comparison to the NAAQS. In the Network Plan, FDEP has requested to maintain the NAAQS exclusion for its continuous 

### PMz
.s FEMs operated at two Palm Beach County sites (AQS IDs: 12

-099-0008 and 12-099-0009). EPA has reviewed the information submitted in the Network Plan, and approves these monitors for exclusion from NAAQS comparisons. 

### PM2.s Chemical Speciation Network EPA conducted an assessment of the PM2.s Chemical Speciation Network (CSN) in an effort to optimize the network and create a network that is sustainable going forward. As a result of this assessment, EPA defunded a number of monitoring sites, and at all sites eliminated the CSN PM25 mass measurement, reduced the frequency of carbon blanks, reduced sample frequency at some monitoring sites, and reduced the number oficepacks in shipment during the cooler months ofthe year. As FDEP discusses in the Network Plan, EPA defunded the Skyview site (AQS ID: 12-103-0026) as ofJanuary 2015
. In addition, all ofthe state's CSN sites were impacted by the elimination ofthe 

### PMz.s mass measurement, the reduction of carbon blank frequency, and the reduction in icepacks
. 

### Request for Waiver ofSiting Criteria On Page 38 of the Network Plan, FDEP requests a waiver of the monitor siting criteria for the Woodlawn PM10 site in St. Petersburg. The site has been operating in its current location since 1992. Recent improvements at the park where the site is located included the planting of trees that resulted in the monitor no longer meeting siting criteria. Given the information and rationale provided by FDEP, EPA is open to considering this request for a waiver
. However, more information will be needed for approval. Specifically, FDEP needs to identify which requirements in 40 CFR Part 58, Appendix E the site does not meet and thus are being requested by the state to be waived. Also, FDEP must provide current measurements or data, in the form ofthe relevant siting criteria requirements (e.g., measurements to trees or obstructions, etc.).



### llUnder 40 CFR Part 58, Appendix E, Section 10, waivers of siting criteria for new sites can be granted if either of the following criteria are met: 10
. 1.1 The site can be demonstrated to be as representative ofthe monitoring area as it would be if the siting criteria were being met. 1 0
. 1
.2 The monitor or probe cannot reasonably be located so as to meet the siting criteria because ofphysical constraints (e.g., inability to locate the required type of site the necessary distance from roadways or obstructions)
. The additional information requested above may be submitted in a separate letter, or in an addendum to the 2015 Network Plan.

12