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 of Florida'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 of the 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 of the 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 of Jacksonville 

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 Division 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 Region 4 SESD 
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 PM to, only apply to metropolitan statistical areas (MSAs), which are a subset of 

CBSAs. OMB currently defines 29 CBSAs in the state of Florida. 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 

3 
Key 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 

Micropolitan Statistical 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 Network Plans. The remainder of the 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 of the information required for 

approval by 40 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 of the 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 

A

QSID 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-St. Pinellas Sawgrass Lake Parkway 12-1 03-0027 N02, CO, Black Additional 

Petersburg- Near Road Carbon information 

Clearwater required for 

a roval 

Homosassa Springs Citrus Power Line Road - j 2-0 17-0006 so2 Additional 

source-oriented site near information 

Du

ke Energy Crystal required for 

River Sream Plant approval 

Orlando- Orange 1-4 Near Road 12-095-0009 N01.co. Site proposal 

Kissimmee- Continuous previously 

Sanford PMzs. approved 

l
Jacksonville 

Miami-Fort 

Lauderdale-West 

Palm Beach 

Miami-Fort 

Lauderdale-West 

Palm Beach 

Miami-Fort 

Lauderdale-West 

Palm Beach 

Duval 

Broward 

Palm Beach 

Palm Beach 

TBD 

UF Agricultural Research 

Center 

Royal Palm 

Lamstein Lane 

TBD Pb 

12-011-1002 Continuous 

PM25 

12-099-0009 OJ, PM2.s 

TBD 

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 

5 
AQI 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. PetersburgClearwater, 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 by the EPA's 

Office of Air Quality Planning and Standards. The St. Marks NCore site was established in 2014 as a 

rural NCore site. 

03 ,.1 ;,, ;, uirements 

40 ppendix D, Table D-2 

The stmc 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 of 40 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 

CBS As 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 of 40 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 
t 

aude

da

e

West Palm Beach and Tampa

St. Petersburg

Clearwater CBSAs. New sites in Miami

Dade 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 of the 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 of Air 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/ttna mt i lift les/nearroad/NearRoadT AD.pd f. 

7 
work with your agency as needed to facilitate the establishment of these 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 of the 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 
p

p

§ 

(

)(

), 

g

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 of the design criteria of 40 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/www 3 .epa. gov/airqua I ity/sul furd iox ide/pd fs/SO 2MonitoringT AD. 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 st

ate 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 network of 

manual PM to methods (at least one site) must be collocated. These collocation requireme

nts are assessed 

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 of the design criteria of 40 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 of Florida'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, PM

2.s monitoring is required at near·road monitoring sites in CBS As with 

populations greater than 2,500,000. PM

2.s monitoring will be required at a near-road monitoring site in 

CBS As 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 of the 

design criteria of 40 CFR Part 58. 

PM2.s Continuous Monitoring Requirements 

40 CFR Part 58, Appendix D, 4. 7.2 

Regulatory requirements for continuous PM

2.s monitoring require that ..... State, or where appropriate, 

local agencies must operate continuous PM2.s analy

zers equal to at least one-half (round up) the 

minimum required sites listed in Table 

D- 5 of this appendix. At least one required continuous analyzer 

in each MSA must be collocated with one of the required FRMIFEM/ARM [feder

al reference 

method/federal equivalent method/approved regional method] monitors, unless at least one of the 

required FRMIFEM/ ARM monitors is itself a continuous FEM or ARM monitor in which case no 

collocation requirement applies: · These minimum continuous PM2.s monitoring requirements are met in 
q

0 C

a

t 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). If an 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 of icepacks in shipment during the cooler months of the year. As FDEP discusses in 

the Network Plan, EPA defunded the Skyview site (AQS ID: 12-103-0026) as of January 2015. In 

addition, all of the state's CSN sites were impacted by the elimination of the PMz.s mass measurement, 

the reduction of carbon blank frequency, and the reduction in icepacks. 

Request for Waiver of Siting 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 of the 

relevant siting criteria requirements (e.g., measurements to trees or obstructions, etc.). 

ll 
Under 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 of the 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 of physical 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.