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Can fouling not occur within the tray holes?

Does fouling (hardness, in particular) not occur within the tray holes?

No, fouling CAN occur all over the trays, including the tray holes. In fact, massive fouling can bind the tray holes. The main thing to keep track of is sump back-pressure. When the back-pressure gets high enough to lower the air flow on the blower curve, the trays need to be cleaned.