00UNITEDSTATESENVIRONMENTALPROTECTIONAGENCYREGIONIX75HawthorneStreetSanFrancisco,CA.S4105·3901DEC11zuuMr.BradPoiriezAirPollutionControlOfficerImperialCountyAirPollutionControlDistrict150South9thStreetElCentro,California92243-2801DearMr.Poiriez:ThankyouforyoursubmissionoftheImperialCountyAirPollutionControlDistrict's(ICAPCD's)AnnualNetworkPlanforAmbientAirMonitoringinJuly2013.Wehavereviewedthesubmitteddocumentbasedontherequirementssetforthunder40CFR58.Basedontheprovidedintheplan,EPAapprovesallportionsofthenetworkplanexceptthosespecificallyidentifiedbelow.Pleasenotethatwecannotapproveportionsoftheannualnetworkplanforwhichtheinformationintheplanisinsufficienttojudgewhethertherequirementhasbeenmet,orforwhichthe·information,asdescribed,doesnotmeettherequirementsasspecifiedin40CFR58.10andtheassociatedappendices.EPARegion9alsocannotapproveportionsoftheplanforwhichtheEPAAdministratorhasnotdelegatedapprovalauthoritytotheregionaloffices.Accordingly,thefirstenclosure(A.AnnualMonitoringNetworkPlanItemswhereEPAisNotTakingAction)providesalistingofspecificitemsofyouragency'sannualmonitoringnetworkplanwhereEPAisnottakingaction.Thesecondenclosure(B.AdditionalItemsRequiringAttention)isalistingofadditionalitemsintheplanthatEPAwishestobringtoyouragency'sattention.Thethirdenclosure(C.AnnualMonitoringNetworkPlanChecklist)isthechecklistEPAusedtoreviewyourplanforoverallitemsthatarerequiredtobeincludedintheannualnetworkplanalongwithourassessmentofwhethertheplansubmittedbyyouragencyaddressesthoserequirements.Thefirsttwoenclosureshighlightasubsetofthemoreextensivelistofitemsreviewedinthethirdenclosure.Allcommentsconveyed.viathisletter(andenclosures)shouldbeaddressed(throughcorrectionswithintheplan,additionalinformationbeingincluded,ordiscussion)inyear'sannualmonitoringnetworkplan.onIf you have any questions regarding this letter or the enclosed comments, please feel free to contact me at (415) 947-4534

or Michael Flagg
at (415) 972-3372. Enclosures:

Sincerely, **vttt~**

'

- MeredithKmpius, **~** 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: Monica Soucier, ICAPCD Gayle Sweigert, California
Air Resources Board

00 0

A. 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. • System modifications
(e.g., site closures

or moves) are subject

to approval per 40 CFR 5 8.14( c). Information provided

in the plan was insufficient

for EPA to approve the system modifications listed in the plan per the applicable requirement. Therefore,

we are not acting on the following items
as part of this year's annual network plan: - Relocation

of Calexico Ethel - Shutdown

of Westmorland ozone monitor • EPA identified items
in your agency's annual monitoring 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 PM2.s sampling frequency

52
Not meeting requirement

in one instance Distance from trees

80
Not meeting requirement

in one instance PM1o sampling frequency

53 Insufficient information

to judge Designation

of primary

38 Insufficient information

to judge monitor Date of last PE audit

34 Insufficient information

to judge
in some instances Distance from furnace

or

81 Insufficient information

to judge incinerator
flue Document how agency will

26 Insufficient information

to judge provide for the review
of changes

to PM2.s network Parameter code

49 Incorrect information

in some instances Scale of representation

17 Insufficient information

to judge
or

incorrect

in some instances Site type

48 Incorrect information

in some instances Method code

43 Insufficient information

to judge Monitoring objective

47 Insufficient information

to judge Monitor type

46 Insufficient information

to judge Statement

of purpose

2 Insufficient information

to judge Start date

45 Insufficient information

to judge
in some instances Shared MSA monitoring

44 Insufficient information

to judge responsibilities Pb monitoring requirements

62 Insufficient information

to judgePb collocation

41 Insufficient information

to judge Groundcover

75 Incorrect information

irl some instances PM2.s collocation

37 Insufficient information

to j_u__Qge PM1o 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).

00 0

B. Additional Items Requiring Attention • [Row

6 ] If any system modifications

are approved between this plan and the next. please attach any associated documentation

to next year's plan. • [Row 50] The Brawley PM

1 o SSI and BAM1020

are both identified

as POC

1. • [Row 76] The probe heights

in the "station details"
do not match the heights above ground

in the "site survey reports"
for Niland, Westmorland,

El Centro, and Calexico Ethel. • [Row 77] The distance from supporting structures

in the "station details"
do not match the heights above platform

in the "site survey reports"
for Niland, Brawley, Westmorland,

El Centro, and Calexico Ethel.0 0

# 0 C. ANNUAL MONITORING NETWORK PLAN CHECKLIST 

## (Updated 11/26/2013)
Year: 2013 

## Agency: Imperial County 

## Air Pollution Control District 

# 0

40 CFR 58.10(a)(l) 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, SlN 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)(l) 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 (SlN/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.

. Yell 

## ow = 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) 

# oreen I =item requires attention in order to improve next year's plan (items listed in Enclosure B)

1

## ANP requirement 

# I Citation Was the info Does the 

## I Notes within 40 submitted? 1 

## If information CFRS8 yes, page #s. provided 3 

## meet Flag if 

## the req? 4 

## incorrecr? Submit plan by July 1st 58.10 (a)(1) y Statement of purpose for each monitor 58.10 (a)(l) N !Insufficient info 

### I Information not included 3. 

### I 30-day public comment 

### I inspection

**period~** 58.10 (a)(l), 58.10 (a)(2) 

### Y, 7/11/2013 Letter 

# I Y

4. 

### I Modifications to SLAMS network- case when we are 58.10 (a)(2) 

### Y, p.25-26 Insufficient info The plan identifies the proposed change to not approving actual system modifications (i.e., we 58.10(e) move the Calexico Ethel site to a nearby will do it outside the ANP process, location and changes to the Westmorland site, but no analysis was included. 

### EPA will not be approving the proposed modifications as part of the 2013 

### ANP review. to SLAMS network- case when we are 58.10(a)(2) 

### N/A N/A EPA will not be approving any system approving actual system modifications per 58.14(c) 58.10 (b)(5) modifications as part of the 2013 

### ANP review.

58.10 

### N/A N/A

58.10 (a)(5) 

### N/A N/A

N/A 50 2 monitoring Is not required

1 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. 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) 

# 0 2

# - ANP requirement Citation Was the info Does the Notes within 40 

## submitted? 1 

## If information CFRS8 

## yes, page #s. provided 3 

## meet Flag 

## if' the req? 4 

## incorrecr? 13 AQS site identification number for each site 58.10 (b)(1) Y, p.29-49 y 

### 14 Location of each site: street address and geographic 58.10 (b){2) Y, p.29-49 y 

### coordinates 15 Sampling and analysis method(s) for each measured 58.10 (b)(3) Y, p.29-49 y 

### parameter 16 Any proposals to 

### remove or move a monitoring 58.10 (b)(5) Y, p.25-26 y 

### station within a period of 18 months following plan submittal 17 Scale of representativeness for each monitor as 58.10(b)(6); Y, p.ll-13, p.29-49 Insufficient/ The site survey reports for Niland and Brawley defined in 

### Appendix D AppD Incomplete, p.40 Incorrect info do not contain scale of representativeness for the PM 10 

### BAM 1020s.
An "urban" scale for 0 3 

### and N0 2 

### at Calexico Ethel may be inappropriate, as concentrations at El Centro show that 0 3 

### concentrations vary over distances within the "urban" scale definition. Due to these differences in concentration, the Calexico Ethel site is most likely representative of a "neighborhood" scale. 18 Identification of sites suitable and sites not suitable 58.10 (b)(7) Y, p.29-49 y 

### for comparison to 

### the annual PM 2 

### .s 

### NAAQS as descn'bed 

### in Part 58.30 19 MSA. CBSA. CSA or other area represented by 

### the 58.10 (bX8) Y, p.29-49 y 

### monitor 20 Designation of any Pb monitors as either source- 58.10 (b)(9) N/A N/A Source oriented Pb monitori ng Is not required oriented or non-source-oriented 21 Any source-oriented Pb site for which a waiver 

### has 58.10 (b)(10) N/A N/A Source oriented Pb monitori n g Is not required been granted by EPA RA 22 Any Pb monitor for which a waiver 

### has been 58.10 (bX11) N/A N/A Source oriented Pb monitori n g is not required requested or granted by EPA RA for use ofPb-PM 10 

### in lieu ofPb- TSP 23 Identification ofrequired

**N~** 

### monitors as either near- 58.10 (b)(12) N/A N/A Near-road/Area-wide N0 2 

### monitoring Is not road or area-wide required



## 3

.I 

## ANP requirement Citation Was the info Does the Notes within 40 submitted? 1 

### If 

## information CFR58 yes, page #s. provided 3 

## meet Flag if 

## the req? 4 

## incorrecf? 24 Identification of any PM 2 

### .s FEMs and/or ARMs not 58.10 (b)(13) N/A N/A No PM 2 

### .s FEM monitors In Imperial County eligible to be compared to the NAAQS (Note 1: must 58.11 (e) include required data assessment) (Note 2: Required SLAMS must monitor PM 2 

### .s with NAAOScomparable monitor at the required sample frequency.)

25 For SPMs listed as non-regulatory, note the start 

### Date 58.20(c) N/A N/A No current PM 2 • 5 

### SPMs operating >24 months ofFRM/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 I 

### information that App A, C orE requirements were not met. 26 Document how states and local agencies provide for 58.10(c) N 

### Insufficient info Information not included the review of changes to a PM 2
. 5 

### monitoring network that impact the location of a violating PM 25 

### monitor. 27 Does the plan include a request for approval for and 58.11 (a) (2) N/A N/A The plan does not Include request for approval alternative to appendix A requirements for SPMs of an alternative to app. A for existing SPMs operating a FRMIFEM/ ARM which also

**mee~** 

### appendixE? 28 Precision/ Accuracy reports submitted to AQS 58.16(a); Y, p.27 y AppA, 1.3 and 5.1.1 29 Annual data certification submitted 58.15 Y. p.27 y App.A 

### 1.3 30 Frequency of flow rate verification for manual PM App A 3.3.2 Y, p.29-49 y samplers audit 31 Frequency of flow rate verification for automated PM AppA3.2.3 Y, p.29-49 y analvzers audit 32 · Frequency of one-point flow rate verification for Pb AppA Y,

**~.29-49** 

### y samplers audit 3.3.4.1 33 Frequency of one-point QC check (gaseous) App.A3.2.1 Y, p.29-49 y 34 Date of last Annual Performance Evaluation (gaseous) App

. A 3.2.2 Y, p.29-49 Insufficient info Dates for last PE audit for Westmorland, El Centro, and Calexico Ethel are from 2012. Information pertaining to 2013 PE audits was not included

. 

## 4 

# 0

# -- ' 

## ANP requirement Citation Was the info Does the Notes within 40 subJirltted? 1 

### If 

## information CFRS8 yes, page #s. provided 3 

## meet Flag if 

## the req? 4 

## incorrecr? 35 Dates oflast two semi-annual flow rate audits for PM AppA, 3.2.4 Y, p.29-49 

### y monitors and3.3.3

36 Dates of last two semi-annual flow 

### rate audits for Pb AppA Y, p.29-49 

### y monitors 3.3.4.1 

### 37 PM 2 5 collocation App A 

### 3.2.5 N, Y, p.18 NA Method codes and designation of a primary monitor are not included in the detailed site information. While the collocation requirements are applicable to the CARB PQAO, relevant information should also be included in the ICAPCD ANP.



### 38 Designation of a primary monitor if there is more than Need to N Insufficient info Information not included one monitor for a pollutant at a site

. determine collocation 39 Distance between coUocated monitors (Note: waiver App.A Y,p.48 

## v. 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) 

### 40 Manual PM 10 method collocation met? (note: App A 

### 3.3.1 N NA ICAPCD is part of the ARB PQAO, and relies on continuous PM 10 does not have this requirement) 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. However, collocated monitors within ICAPCD's network should still be identified in the

1-- 

### ·- ICAPCD network plan. 

### 41 Pb collocation AppA N Insufficient info ICAPCD is part of the ARB PQAO, and relies on 

### 3

. 3.4.3 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 docume_nt that 

## 5

## ANP requirement Citation Was the info Does the Notes 

## within40 submitted? 1 

### If 

## information CFRS8 yes, page #s. provided 3 

## meet Flag if 

## the req? 4 

## incorrecf? should address this. However, collocated monitors within ICAPCD's network should still be identified in the ICAPCD network plan. 42 PM 1 0- 2 

### .s collocation (note: only applies to Fresno and AppA3.3.6 

### N/A N/A PM10-z

. s is not required Phoenix NCore sites) 43 Instrument/monitoring method code for each monitor: App C 2.4

. 1.2 N Insufficient info Information not included 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) N Insufficient info Information not included an MSNCSA: does each affected State or local agency meet full monitoring requirements or is
an agreement between the affected agencies and the EPA Regional Administrator in place?

45 Start date for each monitor Required to Incomplete, p. 45 Insufficient info Start dates for collocated PM 2 . 5 FRM and determine if collocated non-FEM BAM 1020 were not other req. included (e.g., min# and colloc)
are met 46

. Instrument monitor type for each monitor Required to Y, p.16-18, p.29-49 Insufficient info In your next year's network plan, please clarify determine if whether the PM 10 SPMs at the Brawley and other req. Niland sites are FRMs, FEMs or ARMs. Note (e

. g., min# that if they are FRMs, FEMs or ARMs, and they and colloc) have operated for greater than 24 months, the are met data are considered regulatory.

**~** . 47

. Monitoring objective for each instrument App D 1.1 N Insufficient info Information on basic monitoring objectives for

. 58.10 (b)(6) each monitor was not included

- 

## - 48

. Site type for each instrument App D 1.1.1 Y, p.9-10, p
. 15-18, Insufficient/ The site survey reports in the plan contain a p.29-49 Incorrect info field of "Objective", which EPA is interpreting
as "site type", as some monitors are defined as "population exposure" in this field. Possible site types are: extreme downwind, highest
cone
. , max ozone cone., max precursor impact, population exposure , source oriented, upwind

-- - - 

## 6 

# 0'- ./

**~** 

## ANP requirement Citation Was the info Does the Notes within 40 submitted? 1 

### If 

## information CFR58 

## yes, page #s. 

## provided 3 

## meet Flag if 

## the req? 4

. 

## · incorrect 2 

## ? background, general/background, regional transport, welfare-related impacts, quality assurance, other

. The information in the site survey reports are not consistent with tables 1-3 on p.9-10. The following information should be corrected: 

## • The site types for Niland 0 3 and PM 10 are inconsistent throughout the ANP. 

## • The "support" site type for the Niland Site type for each instrument (continued) PM 10 BAM is inappropriate. 

# • The site types for Westmorland 0 3 and PM 10 are inconsistent throughout the ANP. 

# • The site types for Brawley PM 10 and PM 1
. 5 are inconsistent throughout the ANP. 

# • The "support" site type for the Brawley PM 10 BAM is inappropriate. 

## • The "typical concentration" site type for Brawley PM 10 is inappropriate. 

## • The site types for all El Centro monitors are inconsistent throughout the ANP. 

# • The "typical concentration" site types for El Centro CO, NO:u and PM 10 are inappropriate. 

## • Based on 2012 data, the "highest concentration" site type for El Centro PM 10 is inappropriate. 

## • The "support" site types for the Calexico Ethel PM 1 5 BAMs are inappropriate. 

## • The "state requirement" site type for the Calexico Ethel TSP monitor is inappropriate.

-- 

## 7

### ANP requirement

Instrument parameter code for each instrument

51 

### J Sampling season for ozone (note: 

### date of waiver approval must be included 

### if the sampling season deviates from requirement) Sampling schedule for PM 2 5 - applies to year-round and seasonal sampling schedules (note: date of waiver approval must be included if the sampling season deviates from requirement)

53J Sampling schedule for PM 10

forPb

Sampling schedule for PM1o.2.s



# 0 Citation 

## within 40 

## CFR58

Required to determine if other req. (e.g., 

### min# and colloc)
are met 

### Was the info submitted? 1 

### 1f 

## yes, page #s. Flag 

### if 

### incorrecr? Y, p. 16-17

158.10 (b)(4) 

## I Y, p.29-49

App D, 4.1(i)

58.10 (b)(4) Y,p.17-18, p.24-25, 58.12(d) p.29-49 AppD4.7 EPA flowchart j58

. 10(b)(4) Y, p.17

- 18, p
. 24,

58.12(e) p.29-49 App D4.6

58.10 (b)(4) Y,p.45 58.12(b) AppD4.5 58.10 (b)(4) 

### N/A 

### Does the information provided 3 

### meet the req? 4
Incomplete, Incorrect info



### IV

N

Insufficient info



## I V

I N/A 

### Notes

Parameter codes for N0 2 and 50 2 were not included. The parameter code of 85101 for the PM 10 BAM SPMs at Brawley and Niland are inappropriate, as the monitors have been operating for longer than 24 month.

Currently, the Calexico Ethel site is not meeting the required PM 2 . 5 sampling frequency. The Calexico Ethel site has been sampling at the incorrect frequency since 2010. The analysis in Section IV on PM 10 sampling frequency does not describe the methodology used to determine whether the requirement has been met. It is unclear how the data presented supports the conclusion that no .Jired.



## I PM10-z.s monitoring is not required



### 8

# - ANP requirement Citation Was the info Does the Notes within 40 submitted? 1 

### If 

## information CFR58 yes, page #s. provided 3 

## meet Flag if 

## the req? 4 

## incorrecr? 56 Minimum # of monitors for 0 3 

### [Note: should be App D, 4.1(a) Y, p.19-20 y 

### supported by MSA ID, MSA population, DV, # and monitors, and# required monitors] 

### (see footnote)' TableD-2 57 Identification of max.

**cone.~** 

### monitor(s) AppD4.1 (b) Y, p. 57 y 

### 58 Minimum. monitoring requirements met for near-road AppD4.3.2 Y, p.20 y 

### N0 2 (2014 start date) 59 Minimum

**mo~toring** 

### requirements met for area-wide AppD4.3.3 Y, p.20 y 

### N02 60 Minimum monitoring requirements met for RA-40 AppD4.3.4 

### N/A N/A RA-40 N0 2 

### monitoring Is not required. NO;z. 61 Minimum monitoring requirements .met for SO:z. AppD4.4 

# v, p. 21 y 

### [Note: Only monitors considered to be required SLAMs are eligtble to be counted towards meeting minimum monitoring requirements.] 62 Minimum monitoring requirements met for Pb [Note: App 04.5 N 

### Insufficient info Information not included Only monitors considered to be required SLAMs are 58.13(a) 

### eligible to be counted towards meeting minimum monitoring requirements.] 63 Minimum# of monitors for PM 2 .s 

### [Note 1: should be AppD, Y, p.22-23 y 

### 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 PM 2 

### .s 

### Network Clarifications: Provide a list Need to 

### N/A N/A Information not included of required sites if 

### it does not include all 

### SLAMS. assess several [Note: default will 

### assume all 

### SLAMS are considered requirements required sites.] 65 Required PM 2 .s 

### sites represent area-wide air 

### quality AppD 

# v, p.17-18, p.29-49 y 

### 4.7.1(b) 66 For PM 2 .s, is 

### at least one site at neighborhood or AppD Y, p.17-18, p.29-49 y 

### larger scale in 

### an area of expected maximum 4.7.1(b)(l) concentration 67 If 

### additional SLAMS PM 2 .s 

### required, is 

### there a site in AppD 

### N/A N/A Only one PM2.5 

### monitor is required In the El

__
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. 

## 9

## ANP requirement 

# I Citation within 40 CFRS8

1 4.7.1(b)(2) continuous 

# I AooD4.7.2 AppD4.7.3

met for I AppD4.7.4 AppD,4.6 (a) and Table D-4 AppD4.8

AppES



# 0 Was the info submitted? 1 

## If yes, page #s. Flag if 

## incorrecf?

V, p.45-49
V, p.23
V, p.23
V, 21-22



## · 1 N/A



### Y, 29-49 

## Does the I 

## Notes information provided 3 

## meet the req? 4

IV

I V

IV

IV

I N/A I PM 1 o-2.s monitoring is not required

N, Insufficient info 

## I The PM 2 5 and PM 10 monitors are within 10 meters of trees located to the east of the site at Calexico Ethel. Also, information was not included for the N0 2 , 0 3 , CO, and 50 2



# 0 10

## requirement Citation Wastheinfo within 40 submitted? 1 

### If 

## CFR58
· yes, page #s. Flag if

. 

## incorrecr? and4(b) 83 Probe material (if applicable) AppE9 Y, 29-49 

### 84 Residence time 

### (if applicable) AppE9 Y, 29-49



## Public Comments on Annual Network Plan Were comments submitted to the S!Uf agency during the public comment period? 

## No If no, skip the remainjng questions. If yes: • Were any of the comments substantive? o If yes, which ones? 

## Does the information provided 3 

## meet the req? 4



### y y



### 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? 

## Notes

• 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:



## 11,

.

. 0 0