Memorandum

To: Interagency Consultation Members 

From: Kenneth Monroe, P.E., PTOE 

Date: November 1, 2013 

Subject: SIP Revision Budget Years and Memphis MPO Conformity 

An Interagency Consultation group (IAC) meeting was conducted on October 31, 

2013 to discuss the revisions to the Memphis-Shelby County portion of the 

Tennessee State Implementation Plan (SIP) by the Shelby County Health Department 

(SCHD). The conference call was attended by the following: 

 Allison Fluitt, Kimley-Horn and Associates, Inc. 

 Carter Gray, Shelby County Government 

 Chris Boyd, Shelby County Health Department 

 Corbin Davis, Federal Highway Administration 

 Denis Fritchie, Shelby County Health Department 

 Dianna Smith, U.S. Environmental Protection Agency 

 Elton Holloway, Mississippi Department of Transportation 

 Jim Holt, Shelby County Health Department 

 John Lancaster, Memphis Area Transit Authority 

 Keith Head, Mississippi Department of Environmental Quality 

 Kenneth Monroe, Kimley-Horn and Associates, Inc. 

 Marc Corrigan, Tennessee Department of Environment and Conservation 

 Pragati Srivastava, Memphis Metropolitan Planning Organization 

 Randal Tatum, City of Memphis 

 Theresa Claxton, Federal Highway Administration 

 William Kenneth Dean, U.S. Environmental Protection Agency 

The need for the revision is, in part, the result of the termination of the City of 

Memphis’ Inspection and Maintenance (I/M) Program as a Control Measure. The 

revision will address Ozone and it precursors; Volatile Organic Compound (VOC) 

and Oxides of Nitrogen (NOx). Carbon Monoxide is not being addressed as part of 

the SIP revision. The current Motor Vehicle Emission Budget (MVEB) years for the 

precursors of Ozone are 2009, 2017, and 2021. 

When SCHD originally sought feedback from the Memphis MPO on the analysis 

years to be established in the revised SIP, two alternative analysis year scenarios 

were discussed as described below: 



125 North Main Street 

Suite 450 

Memphis, Tennessee 

38103

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TEL 901 576 7190 

FAX 901 576 7272 
Interagency Consultation Group, November 1, 2013, Pg. 2

 Alternative 1 – 2006, 2009, 2017, and 2021 

 Alternative 2 – 2006, 2015, 2017, and 2021 

The base attainment year of 2006 from the SIP would need to be revisited due to a 

change in the air quality modeling platform. The previous SIP was developed using 

EPA’s MOBILE software that has since been replaced with MOVES. The last year 

of the Ozone maintenance plan, which is 2021, would need to be reevaluated due to 

the change in the air quality model platform as well as the referenced change in 

emission control measures. 

The IAC group then discussed the need for developing motor vehicle emissions 

budgets (MVEBs) for years prior to 2021. It was stated that, unlike the conformity 

demonstration process, there is no minimum requirement for developing MVEBs that 

span 10 years or less in the SIP. So, a gap in years between MVEBs could be greater 

than 10 years in a SIP. 

The potential impacts to the planning processes of the Memphis MPO were then 

discussed. The current regional Long Range Transportation Plan (LRTP) and 

Conformity Demonstration were approved in March, 2012. The next LRTP and full 

conformity demonstration are due in March, 2016. The first interim year described 

in the next LRTP will likely be 2020 or beyond. With future year LRTP plan years 

beyond 2020, MVEB years earlier than 2021 will not provide useful information that 

will help guide transportation planning decisions presented in these documents. 

Fewer MVEB years prior to the last year of the Ozone maintenance plan year of 

2021 will also reduce the workload of the MPO in developing conformity 

documents. 

For these reasons, it was agreed by those on the call that the SIP would consist of a 

base analysis year of 2006 and a final year of 2021. 

The schedule for developing the SIP was then discussed. Revision of the SIP with 

new MVEBs is a trigger for conformity demonstration by the Memphis MPO, with a 

demonstration of conformity due 24 months from the issuance of the revised SIP. 

SCHD will prepare and distribute the revised SIP to State and Federal review 

agencies within 90 days. It is anticipated that the entire process will take one year 

for full approval.