Shelby County Redesignation Request

and

Maintenance Plan

(SCRRAMP-2015)

for the

2008 Eight-Hour Ozone

National Ambient Air Quality Standard

Prepared by:

Shelby County Health Department

Pollution Control Section

814 Jefferson Avenue

Memphis, Tennessee 38105
Table of Contents

1. Petition for Redesignation 1

2. 2011 Emission Inventory 2

3. Attainment Determination 2

A.) Air Quality 2

B.) Environmental Justice 5

C.) Weather Analysis 6

4. SIP Approval 6

5. Emissions Reductions 8

A.) Permanent and Enforceable Improvements in Air Quality 8

i.) On-Road Mobile Sources 8

ii.) Non-Road Mobile Sources 10

iii.) Point Sources 11

B.) Other Measures 12

i.) Consent Decrees 12

ii.) Voluntary Efforts 12

6. Clean Air Act Section 110 and Part D Requirements 13

7. Maintenance Plan 14

A.) Base Year Inventory and Future Projections 15

B.) Motor Vehicle Emission Budgets 19

C.) Air Quality Monitoring Network 20

D.) Emission Inventory 20

E.) Stationary Source Control 20

F.) Voluntary Measures 21

G.) Contingency Provisions 21
Attachments

Attachment I - Technical Support Material (folder)

A. Historical Ozone WX Comparison (Analysis of Ozone Concentrations...in the Memphis Metropolitan Area)

1. Historical Ozone WX Comparison.pdf

2. Graphs for WX-O3 Comparison.xls

B. 2012 Shelby County, TN Emission Inventory Calculation Methodology (folder)

1. 2012 Shelby County, TN Emission Inventory Calculation Methodology.pdf

2. AEO Fuel Consumption data for East South Central Sector.xls

3. Tennessee Employment Estimates by Sector Category.xls

4. 2010-2050 Shelby County Population Projections_byUTKdataCenter.xls

5. Biogenic.pdf

C. Emission Inventory and Methodology Tables

1. 2012 2017 2020 and 2027 Onroad Mobile Source Emissions Summary ...of NOx CO VOC Final.xls

2. 2012 2017 2020 and 2027 NOx and VOC EI Summaries and Budgets (Final).xls

3. 2012 2017 2020 and 2027 Shelby County TN Emissions Summary of NOX CO VOC for all Categories FINAL.xls

4. 2012 2017 2020 and 2027 Nonroad Mobile Equipment Emissions Summary.xls

5. 2012 Shelby County TN Airport Emissions Estimates... of NOx CO VOC Final.xls

6. 2012 Shelby County TN Area Source Emissions Estimates... of NOx CO VOC Final.xls 

7. 2012 Shelby County TN Commercial Marine Vessel Emissions Estimates ...of NOx CO VOC Final.xls

8. 2012 Shelby County TN Locomotive Emissions Estimates ...of NOx CO VOC Final.xls

9. 2012 Shelby County TN Point Source Emissions Estimates ...of NOx CO VOC Final.xls

10. Proposed TVA Nat Gas EGU Plant.xls

11. 2014 8-hr O3 Ambient Data for Maintenance Submittal.xls

12. Monitoring – Memphis MSA Ozone Monitors.pdf

13. Monitoring – Memphis TN-MS-AR MOA ltr 2015-02-16.pdf

14. Monitoring – Memphis TN-MS-AR MOA.pdf

15. Shelby NONROAD2008_MySQL Input files.zip

16. Shelby NONROAD2008_MySQL Output files.zip

17. 2012 Nonroad Fuel Default.xls

18. 2017 Nonroad Fuel Def.xls

19. 2020 Nonroad Fuel Def.xls

Attachment II MOVES2014 O3 Input Files (folder)

1. 2012 Shelby County TN AvgSpeedDistibution.xls

2. 2012 Shelby County TN Fuel Input.xls

3. 2012 Shelby County TN HourVMTFraction.xls

4. 2012 Shelby County TN HPMSVTypeVMT.xls

5. 2012 Shelby County TN IM.xls

6. 2012 Shelby County TN MOVES MYSQL Inputs.zip

7. 2012 Shelby County TN Ramp Fraction.xls

8. 2012 Shelby County TN RoadTypeDistribution.xls

9. 2017 Shelby County TN AvgSpeedDistibution.xls

10. 2017 Shelby County TN Fuel Inputs w RVP Adjustments.xls

11. 2017 Shelby County TN HourVMTFraction.xls

12. 2017 Shelby County TN HPMSVTypeVMT.xls
13. 2017 Shelby County TN MOVES MYSQL Inputs.zip

14. 2017 Shelby County TN Ramp Fraction.xls

15. 2017 Shelby County TN RoadTypeDistribution.xls

16. 2020 Shelby County TN AvgSpeedDistibution.xls

17. 2020 Shelby County TN Fuel Input w RVP Adjustments.xls

18. 2020 Shelby County TN HourVMTFraction.xls

19. 2020 Shelby County TN HPMSVTypeVMT.xls

20. 2020 Shelby County TN MOVES MYSQL Inputs.zip

21. 2020 Shelby County TN Ramp Fraction.xls

22. 2020 Shelby County TN RoadTypeDistribution.xls

23. 2027 Shelby County TN AvgSpeedDistibution.xls

24. 2027 Shelby County TN Fuel Input w RVP Adjustments.xls

25. 2027 Shelby County TN HourVMTFraction.xls

26. 2027 Shelby County TN HPMSVTypeVMT.xls

27. 2027 Shelby County TN MOVES MYSQL Inputs.zip

28. 2027 Shelby County TN Ramp Fraction.xls

29. 2027 Shelby County TN RoadTypeDistribution.xls

30. Shelby County TN Age Distribution.xls

31. Shelby County TN DayVMTFraction.xls

32. Shelby County TN Meteorology.xls

33. Shelby County TN MonthVMTFraction.xls

34. Shelby County TN Sourcetype Population.xls

Attachment III - MOVES2014 O3 Output Files (folder)

1. 2012 Shelby County TN MOVES Output.xls

2. 2017 Shelby County TN MOVES Output.xls

3. 2020 Shelby County TN MOVES Output.xls

4. 2027 Shelby County TN MOVES Output.xls

5. 2012 Shelby County TN MOVES MYSQL Output.zip

6. 2017 Shelby County TN MOVES MYSQL Output.zip

7. 2020 Shelby County TN MOVES MYSQL Output.zip

8. 2027 Shelby County TN MOVES MYSQL Output.zip

Attachment IV - Intergovernmental Consultation (folder)

1. Public Notice.pdf

Attachment V Public Participation (folder)

1. Public Notice.pdf

Attachment VI Supplemental Support Documents (folder)

1. TN Code Annotated Section 68-201-115 Local Progams.pdf

2. 2008-2010 Certificate of Exemption.pdf

3. 2010-2012 Certificate of Exemption.pdf

4. 2012 Title V Emissions Statements.pdf

5. 2012 Title V Emissions Statements 2.pdf

6. 2012 Title V Emissions Statements 3.pdf

7. 2012-2014 Certificate of Exemption.pdf

8. 2014-2016 Certificate of Exemption.pdf

9. Proposed TVA Nat Gas EGU Plant.pdf
10. Source 00045 Cargill – Idling 2015-01-29.pdf

11. Source 00045 Cargill – Idling 2015-03-29.pdf

12. Source 00045 Cargill – Idling 2015-03-13.pdf

13. Source 00045 Cargill – Permit Emission Summary 2014-09-30.pdf

14. Source 00045 Cargill – Permit title page.pdf

Attachment VII 2011 Emissions Statements (folder)

A. 2008 Ozone NAAQS 2011 EI & Statements 2014 Submittal (folder)

1. ATT01 SC 2011 Shelby County Point Source Emission Inventory Questionnaires.zip

2. ATT02 SC 2011 Pt. Srce Emission Statements(folder)

a. 2011 Certified Emissions Statements – Major Sources.pdf

3. ATT03 SC Local Reporting Requirements (folder)

a. Arlington 8-5(16) Reporting Requirements.doc

b. Bartlett 05(16) Reporting Requirements.doc

c. Collierville 8-304(16) Reporting Requirements.doc

d. Germantown 9-21(16) Reporting Requirements.doc

e. Lakeland 9-6(16) Reporting Requirements.doc

f. Memphis 16-98 Reporting Rrequirements.doc

g. Millington 20-1(16) Reporting Requirements.doc

h. Shelby County 14.5-30 Reporting Requirements.doc

4. ATT04 SC 2011 Nonpoint (folder)

a. 2011 Nonpoint Emissions Inputs and Estimates.xls

5. ATT05 SC 2011 NonRoad Equipment (folder)

a. 2011 NonRoad2008a Model Inputs.pdf

b. 2011 NonRoad2008a Model Inputs Emissions Estimates.xls

6. ATT06 SC 2011 NonRoad Commercial Marine Vessels (folder)

a. 2011 NonRoad CMV Emissions Inputs and Estimates.xls

7. ATT07 SC 2011 NonRoad Locomotive (folder)

c. 2011 NonRoad Locomotive Emissions Inputs and Estimates.xls

8. ATT08 SC 2011 NonRoad Aircraft and GSE (folder)

a. 2011 NonRoad Aircraft and GSE Emissions Estimates.xls

9. ATT09 SC 2011 OnRoad (folder)

a. 2011 Shelby OnRoad Emissions Summary.xls

b. 2011 Shelby AVFT Inputs.xls

c. 2011 Shelby AvgSpeedDistribution Inputs.xls

d. 2011 Shelby DayVMTFraction Inputs.xls

e. 2011 Shelby Fuel Formulation Inputs.xls

f. 2011 Shelby Fuel Supply Inputs.xls

g. 2011 Shelby HourVMTFraction Inputs.xls

h. 2011 Shelby HPMSVMTFraction Input.xls

i. 2011 Shelby Meteorology Inputs.xls

j. 2011 Shelby MonthVMTFraction Inputs.xls
k. 2011 Shelby Ramp Fraction Inputs.xls

l. 2011 Shelby RoadTypeDistribution Inputs.xls

m. 2011 Shelby SourceTypePopulation Inputs.xls

n. 2011 Shelby withIM Inputs.xls

o. 2011 Shelby withoutIM Inputs.xls

10. ATT10 SC 2011 Biogenic (folder)

a. Biogenic Emissions Estimates.xls

11. ATT11 SC QAPP (folder)

a. QAPP Approval ltr 2012-05-31.pdf

b. SCHD-PCS EI QAPP.pdf

12. ATT13 SC 2011 Emissions Inventory Summary (folder)

a. Shelby county 2011 Emission Inventory Summary.xls

13. 2008 O3 NAAQS 2011 EI & Statements 2040717 Submittal.pdf

14. Shelby County 2011 Shelby Emissions Inventory Calculation Methodology.pdf
LIST OF ACRONYMS

Acronym Definition

ADEQ Arkansas Department of Environmental Quality

AEO Annual Energy Outlook

AERR Air Emissions Reporting Requirement

AIRS Aerometric Information Retrieval System

APC Division of Air Pollution Control, Tennessee Department & Conservation

CAA Clean Air Act

CAIR Clean Air Interstate Rule

CD Consent Decree

CERR Consolidated Emissions Reporting Rule

CFR Code of Federal Regulations

CMV Commercial Marine Vessel

CO Carbon Monoxide

CTG Control Technology Guidance

DV Design Value

DVMT Daily Vehicle Miles Traveled

EIIP Emission Inventory Improvement Program

EIQ Emissions Inventory Questionnaire

EPA U.S. Environmental Protection Agency

oF Degrees Fahrenheit

FR Federal Register

GHG Greenhouse Gas

GVWR Gross Vehicle Weight Rating

HC Hydrocarbons

HPMS Highway Performance Monitoring System

IAC Interagency Consultation

I/M Inspection and Maintenance

MACT Maximum Achievable Control Technology

MSA Metropolitan Statistical Area

MDEQ Mississippi Department of Environmental Quality

MOA Memorandum of Agreement

MOVES EPA‟s Motor Vehicle Emission Simulator model

MPO Memphis Metropolitan Planning Organization

MVEB Motor Vehicle Emissions Budget

MY Model Year

NAAQS National Ambient Air Quality Standard

NEI National Emission Inventory

NLEV National Low Emission Vehicle

NOAA National Oceanic and Atmospheric Administration

NOx Nitrogen Oxides

NSPS New Source Performance Standards

OBD On-Board Diagnostics

O3 Ozone

ppb parts per billion
ppm Parts per million

PSD Prevention of Significant Deterioration

QA/QC Quality Assure/Quality Controlled

RACT Reasonably Available Control Technology

RFP Reasonable Further Progress

RVP Reid Vapor Pressure

SAF Seasonal Activity Factor

SCC Source Classification Code

SCHD-PCS Shelby County Health Department – Pollution Control Section

SIP State Implementation Plan

TCM Transportation Control Measure

TDEC Tennessee Department of Environment and Conservation

TDM Travel Demand Model

TN-AR-MS Tennessee -Arkansas-Mississippi

TPD Tons Per Day or tons/day

TVA Tennessee Valley Authority

ULSD Ultra Low Sulfur Diesel

VMT Vehicle Miles Traveled

VOC Volatile Organic Compounds

WAF Weekly Activity Factor
1

1. Petition for Redesignation

The Pollution Control Section of the Shelby County Health Department (Department), through the 

Tennessee Air Pollution Control Board representing the Governor of the State of Tennessee, is 

formally petitioning the United States Environmental Protection Agency (EPA) to redesignate 

Shelby County, Tennessee to attainment of the 2008 National Ambient Air Quality Standard 

(NAAQS) for ozone (O3) pursuant to Section 107(d)(3) of the 1990 Clean Air Act Amendments 

(CAA).

In 2008, EPA promulgated a revised O3 standard that set the NAAQS at 0.075 ppm. Shelby 

County in Tennessee, Crittenden County in Arkansas, and the northern urbanized portion of Desoto 

County in Mississippi were designated as the Memphis TN-MS-AR non-attainment area of the 

2008 O3 NAAQS effective July 20, 2012 (77 FR 30088) with a classification of marginal, as air 

quality monitors for the area indicated 8-hour average ozone design value (DV) concentrations 

exceeded the standard. With this designation, the three county area was originally required to attain 

the standard by December 31, 2015, but a court challenge to the designation rule changed the 

statutory attainment date to July 20, 2015.

Air quality data through the end of 2014 shows all area O3 monitors are now registering DVs below 

the O3 NAAQS which makes the area eligible to petition EPA for a redesignation to attainment. 

The Department has been in contact with State air agencies, local transportation planners and the 

EPA during the development of this petition. During early discussions with the surrounding states, 

it was decided that, due to differences in population, industrial development, transportation 

planning and the political boundaries, each area would develop its own petition. Similar petitions 

are being prepared by Arkansas and Mississippi for their respective portions of the nonattainment 

area. These petitions are expected to be submitted to EPA within a few weeks of this submittal. 

With the exception of shared air quality data, the Department requests that EPA evaluates each 

petition on its own merits such that a deficiency in one petition which can be determined to have no 

relevant effect in the other two jurisdictions will not delay processing of the other petitions.

Section 107(d)(3)(E) of the CAA specifies the requirements for redesignation of nonattainment 

areas. A primary guidance relied on in preparing and processing redesignation requests is a 1992 

EPA memorandum issued by the then Director of the EPA‟s Air Quality Management Division, 

John Calcagni and titled “Procedures for Processing Requests to Redesignate Areas to Attainment” 

(the Calcagni memo). This petition generally follows the format of the Calcagni memo with two 

additional requirements not directly addressed in the memo. Those are the inclusion of the CAA 

Section 182(a)(1) inventory and the development of the Motor Vehicle Emission Budget. The 

other requirements for redesignation of a nonattainment area include: 

1. The EPA has determined that the NAAQS has been attained;

2. The applicable implementation plan has been fully approved by EPA under section 

110(k);

3. The EPA has determined that the improvement in air quality is due to permanent and 

enforceable reductions in emissions;

4. The State has met all applicable requirements for the area under Section 110 and Part D; 

and
2

5. The EPA has fully approved a maintenance plan, including a contingency plan, for the 

area as meeting the requirements of Section 175A.

2. 2011 Emission Inventory

The 2011 emission inventory for Shelby County is included here as Attachment VII to satisfy the 

requirement of CAA Section 182(a)(1) and the O3 implementation rule (80 FR 12264). This 

inventory was developed in accordance with the Air Emissions Reporting Rule (AERR) 

requirements and has been submitted into the National Emission Inventory (NEI) database. 

This is the baseline inventory required by all nonattainment areas. Its purpose is to set an O3 

precursor emission baseline for an area to develop subsequent rules in an attainment plan. Since the 

Memphis TN-MS-AR nonattainment area was classified as marginal nonattainment of the O3 

NAAQS, there is no requirement to develop attainment plans.

The inventory to be incorporated into the State Implementation Plan (SIP) is the 2012 attainment 

inventory found in the Maintenance Plan portion of this document as that is what the 10 year 

maintenance plan will rely on in future years. Note that though both inventories relied on the most 

current available data, in the interim between compiling the 2011 and 2012 inventories, the local 

Metropolitan Planning Agency (MPO) developed updated model inputs for analyzing on-road 

emissions. Therefore no comparison should be made between the on-road emissions from these 

inventories.

3. Attainment Determination

A.) Air Quality 

Crittenden County Arkansas and Shelby County Tennessee share a common border and are 

separated by the Mississippi River. DeSoto County Mississippi and Shelby County share a common 

border but are not otherwise separated by topography. The area is located in the lower Mississippi 

river valley. There is very little variation in topography ranging from flat delta to low rolling hills. 

Crittenden, DeSoto, and Shelby counties are a part of the Memphis, TN-AR-MS metropolitan 

statistical area (MSA), which includes three counties in Tennessee, five counties in Mississippi, and 

one county in Arkansas. According to data from the U. S. Census Bureau for 2013, the MSA has a 

population of 1,341,746. Shelby County is mostly urbanized and, with 939,465 residents, accounts 

for 70% of the MSA population. Crittenden County is mostly rural except for a small urbanized 

area on the east side of the county and has a population estimate of 49,746. With the exception of a 

significant urbanized area just south of Shelby County in DeSoto County, Mississippi (population 

168,240), the remainder of the MSA is almost completely rural. Previous studies have shown area 

emissions generally follow population distribution.

Since the 1970‟s, the area has experienced a general decline in its manufacturing base. However, 

during this same period it has grown to become a major distribution center. The area lies at the 

intersection of two major interstates and is home to the world‟s second busiest cargo airport, the 

third largest rail center in the U.S. and the fourth largest inland port in the U.S.
3

In years past, Shelby County has attained the NAAQS for particulate matter, carbon monoxide, 

lead, and for multiple O3 standards, most recently attaining the 1997 8-hour O3 NAAQS of 0.08 

parts per million (ppm) on February 3, 2010 (75 FR 56, January 4, 2010). In 2008 EPA 

promulgated a revised standard that set the 8-hour O3 NAAQS at 0.075 ppm. Shelby, DeSoto, and 

Crittenden Counties were designated marginal non-attainment of the O3 NAAQS effective July 20, 

2012 (77 FR 30088), as air quality monitors for the area indicated 8-hour average ozone design 

value (DV) concentrations exceeded the standard. A monitor DV is an average of the fourth 

highest annual O3 value at a monitor over the most recent past three years. An area‟s DV is the

highest monitor‟s DV in the area.

At the end of 2014, data from O3 monitors in the Shelby/DeSoto/Crittenden nonattainment area 

indicate attainment of the O3 NAAQS. The monitors recording this data are subject to quality 

control standards set forth in 40 CFR 58. Shelby County O3 monitoring data for 2014 has been 

submitted to EPA and has been certified as accurate. The 2014 O3 data from the monitors in 

Crittenden County Arkansas and DeSoto County Mississippi has also been submitted to EPA and 

certified as accurate. The most recent three years of monitoring data (2012–2014) is presented in 

Table I showing the 3-year design value data for all of the nonattainment monitors. 

Table I: Memphis, TN-MS-AR Non-Attainment Area Ozone Design Value

State County Site Name Monitor ID

Design Value

2012 2013 2014

TN Shelby Frayser 47-157-0021 0.079 0.077 0.073

TN Shelby Edmund Orgill Park 47-157-1004 0.078 0.074 0.070

TN Shelby Shelby Farms 47-157-0076 N/A 0.078 0.073

MS Desoto Hernando 28-033-00002 0.074 0.070 0.069

AR Crittenden Marion 05-035-0005 0.079 0.076 0.071

*NOTE: The 1st full year of operation of the Shelby Farms monitor was 2011 meaning no design value was 

available at this monitor in 2012
4

Figure 1 depicts the DV of the nonattainment area by showing the highest DV recorded at any area 

monitor for each year from 2005 to 2014. The DV for each monitor for 2005 to 2014 is shown in 

Figure 2. Not only did the area achieve compliance with the standard in 2014, the final DV is at 

such a level as to allow a substantial safety margin moving into the 2015 monitoring season. For 

the area to record a violation in 2015, monitors would have to record O3 levels not seen since 2002.

Figure 3 is a map of the Memphis MSA ozone monitors.

Figure 1

0.086

0.0877

0.0897

0.0823

0.0773

0.0757

0.077

0.0797 0.0787

0.0737

0.06

0.07

0.08

0.09

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

Ozone-ppm

Year

Memphis Metro Area 8-hour Ozone Design Value

Highest 3-yr Average of the 4th Highest

High

Figure 2

0.06

0.065

0.07

0.075

0.08

0.085

0.09

0.095

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

Ozone-ppm

Design Value Year

Memphis Metro Area 8-Hr Ozone Design Values Per Monitor 2005-

2014 (ppm)

Frayse

r

Orgill

Herna

ndo

Mario

n
5

Figure 3 – Map of the Memphis MSA Ozone Monitors

B.) Environmental Justice

SCRAAMP 2015 does not relax control measures on existing sources and therefore will not cause 

emissions increases from those sources. Thus, no adverse human health or environmental effect on 

any individuals, including minority or low-income populations associated with this redesignation 

request. The area has demonstrated that it has met the 2008 8-hour ozone standard through 

permanent and enforceable measures and limitations. The maintenance plan actually projects a 

decline in emissions following the redesignation, and that the area will continue to meet this 

NAAQS. 
6

C.) Weather Analysis

Weather has long been known to have been a driving force along with emissions in the 

production of ground-level ozone. Over the past decade, there have been vast reductions in both 

the overall ground-level ozone concentration levels as well as the number of days when the 8-

hour daily ozone maximum has exceeded the National Ambient Air Quality Standard (NAAQS). 

The Department conducted an analysis (Analysis of Ozone Concentrations Between Select Days 

During 2005-2006 and Recent Years (2012-2014) Using Comparative Weather Conditions in the 

Memphis Metropolitan Area) to determine if recent weather conditions were the root cause in the 

reduction of ground-level ozone. The analysis can be found in Attachment I. 

The investigation focused on the isolation of the days with the highest 8-hour ozone maxima in 

2005-2006 and determining comparative weather conditions in recent years (2012-2014) with 

those historic days in order to later compare ozone concentrations on an equal footing. Overall, 

the study found that the ozone concentrations in 2005-2006 were significantly higher (an average 

increase of 51.3% using methods developed for this specific analysis) than the comparative days 

in recent years (2012-2014). This strongly suggests that factors other than weather conditions 

were the driving force behind the reduction in ozone concentrations and number of days 

exceeding the 8-hour ozone NAAQS over the last decade. Known emission reductions are the 

most likely reason for the substantial improvement in air quality for the Memphis metropolitan 

area.

4. SIP Approval

Regulations for Memphis and Shelby County were originally approved by the EPA on May 31, 

1972 (37 FR 10842) as an appendix to the Tennessee SIP. The SIP contained a section that 

recognized the Department as the agency with authority for the control of air pollution in Shelby 

County and included a control strategy demonstration along with the Department‟s regulations. In 

1978, a portion of the City of Memphis was designated nonattainment for carbon monoxide and all 

of Shelby County was designated nonattainment for ozone. Nonattainment plans, along with new 

control strategy demonstrations, were developed for Memphis and Shelby County and in 1980 and 
7

1981 (45 FR 8004, 45 FR 53809, and 46 FR 43970), the EPA approved those plans. The 

Department revised the regulations in several administrative and substantive areas. The 

Department adopted certain portions of the State regulations, revised old regulations and recodified 

the air pollution control section of Memphis and Shelby County Codes accordingly. On July 7, 

1986, the State of Tennessee submitted to the EPA Memphis and Shelby County regulations (Board 

Order 17-86) as a revision to the SIP. The EPA placed the regulations on hold until the federally 

approved SIP for Tennessee and Memphis could be compiled. The EPA compared the federally 

approved State regulations and the federally approved Memphis regulations to determine the 

approvability of the revised Memphis regulations. The EPA's direct final approval/disapproval of 

the 1986 submittal was formalized in the Federal Register (54 FR 25456, June 15, 1989) and 

became effective on August 14, 1989.

EPA concluded that the control strategy demonstration was adequate in protecting the National 

Ambient Air Quality Standards. Consequently, the EPA approved the local regulations as a transfer 

of enforcement authority rather than as a substantive revision to the SIP. The EPA used the 

following conditions and conclusions to arrive at the above procedure:

The local regulations must be equal to the corresponding federally approved State 

regulation

The local regulations cannot be treated as separable from the SIP, which the State submits 

and implements, but must be considered part of the SIP

As Tennessee State law requires that a local regulation be equivalent to or not less stringent 

than the corresponding state regulation, the State of Tennessee must certify to the EPA that 

each regulation has been reviewed by the State and found to meet this requirement

Tennessee must retain overall authority and responsibility for developing and implementing, 

including enforcing, the SIP

The Tennessee Code Annotated, Section 68-201-115 (see Attachment VI), requires geopolitical 

areas within Tennessee that desire to have their own air pollution control programs to adopt 

regulations as stringent as State of Tennessee regulations. After review by and upon the 

recommendation of the Tennessee Air Pollution Control Division, the Tennessee Air Pollution 

Control Board issues a certificate granting this authority but subject to limitations as established by 

the Board. This authority continues to be granted to Shelby County and all included municipalities 

every two years, the most recent certificate having been issued for the 2014-2016 period. Copies of 

these recent certificates are also found in Attachment VI.

Regulatory changes made by the State of Tennessee will be adopted by reference by the Department 

when and where applicable prior to the granting of authority by the Tennessee Air Pollution Control 

Board to the Department as provided by the Tennessee Code Annotated and the Certificate of 

Exemption process. Where such authority is not transferred it remains with the State of Tennessee.

There are no local SIP elements that are subject to disapproval; a finding of failure to submit or 

implement a SIP; or partial, conditional, or limited approval.
8

5. Emissions Reductions

Measured reductions in ozone concentrations in the area are largely attributable to reductions from 

emission sources of volatile organic compounds (VOC‟s) and nitrogen oxides (NOx), which are 

precursors in the formation of ozone. Results of several local modeling studies show that between 

10 to 30 percent of measured O3 concentrations are the result of local emissions. The remainder is 

from emission sources outside of the area as well as natural background concentrations. However, 

standard practice is to only take credit for emission reductions within a nonattainment area.

To determine permanent and enforceable emission reductions, the Calcagni memo directs that “the 

state should estimate the percent reduction (from the year that was used to determine the design 

value for designation and classification) achieved from Federal measures such as the Federal Motor 

Vehicle Control Program and fuel volatility rules as well as control measures that have been 

adopted and implemented by the state”. The relevant time period for this analysis would be any of 

the three years that resulted in the nonattainment DV; 2009-2011, and the three years that resulted 

in having a DV meeting the NAAQS; 20012- 2014. The marginal O3 nonattainment classification 

has no requirement to adopt an attainment SIP, so no new state or local rules have been 

implemented during this period. The marginal classification assumes existing rules in place that 

continue to result in emission reductions will be sufficient to return an area to attainment within the 

expected time period. In submission of this request, Shelby County demonstrates that this has 

occurred. 

A.) Permanent and Enforceable Reductions in Emissions

i.) On-Road Mobile Sources

Inventory analysis shows the majority of NOx emissions in the area are attributable to mobile 

sources. Significant reductions in emissions have occurred and will continue to occur from on-road 

mobile sources. Federal requirements for cleaner cars and trucks have contributed to the lessening 

of pollution from these sources. 

Tier 1 standards under the National Low Emission Vehicle (NLEV) program were implemented 

from 1999 to 2001 for light duty cars and trucks. Tier 2 standards added additional reductions and 

covered a larger class of vehicles. The Tier 2 standards were implemented in different classes of 

vehicles from model years 2006 through 2009. In addition to the new technology standards, Tier 2 

required the reduction of sulfur in gasoline from up to 300 parts per million (ppm) to 30 ppm 

beginning in January 2006. This also resulted in reduced emissions from the existing older fleet of 

vehicles already on the road by improving the operation of catalytic converters. Also, beginning in 

model year 2007, all on-road diesel engines were required to meet new standards designed to 

reduce particulate matter emissions by 90% and NOx emissions by 95%. Finally several federal 

rules have been issued for highway motorcycles implementing changes from model year 2006 

through 2010 to reduce emissions of VOCs and NOx from those vehicles.

As the older more polluting fleet has been replaced with cleaner vehicles, on-road emissions have 

decreased on a grams per mile basis as well as in total. Emission from on-road sources are 

estimated through the use of locally gathered information from the Memphis Area MPO on vehicle 
9

population and miles driven, as well as other inputs, combined with EPA‟s Motor Vehicle 

Emission Simulator (MOVES) model. Emission reduction estimates for Shelby County alone from 

2009 to 2012 are 2.05 tons per day (tpd) for NOx, representing a 4.7% reduction, and 0.54 tpd for 

VOCs, representing a 3% reduction. It should be noted that this occurred during an economic 

recovery period where VMT was reported to increase by 9.3%. It is certain that similar substantial 

on-road emission reductions are occurring in all surrounding areas. 

The Maintenance Plan portion of this petition contains a Motor Vehicle Emission Budget (MVEB) 

that must be approved by EPA and must be used by local planners to periodically demonstrate that 

transportation changes and plans conform to the requirements of the CAA. This budget is based on 

the 2012 attainment emission inventory year. A conformity determination means that during the 

life of the maintenance plan, on-road emissions are not allowed to exceed the base year MVEB.

Effective in 2005, the Tennessee Air Pollution Control Board promulgated a statewide motor 

vehicle anti-tampering rule. This rule, defined in the Tennessee Department of Environment and 

Conservation, Chapter 1200-3-36, Motor Vehicle Tampering, was promulgated to reduce excess 

air pollution caused by tampering with a motor vehicle‟s emissions control system. The rule 

defines tampering as modifying, removing or rendering inoperative any air pollution emission 

control device, which results in an increase in emissions beyond established federal motor 

vehicle standards. Below is Table II, which is adapted from a 2013 EPA publication titled “2009-

2011 Compliance Report – Vehicle and Engine Compliance Activities” (EPA-420-R-13-006) 

which describes the variety of recent on-road mobile source rules.

Table II

Affected Industry

Sector/Category On-Road Mobile

Program/Rulemaking Description

Effective

Model

Year2

Light-Duty 

Vehicles

Tier 2 Emission Standards and Gasoline Sulfur Fuel Control –Strengthened 

emission standards for light-duty vehicles and significantly reduced sulfur levels in 

gasoline

On-Board Diagnostics (OBD) – Established new emissions system monitoring 

requirements for light duty diesel vehicles

Revisions to Motor Vehicle Fuel Economy Labeling – Updated EPA method for 

determining fuel economy label values to better represent typical driving patterns 

and more accurately estimate actual consumer fuel economy

Mobile source Air Toxics – Set standards to lower gasoline benzene content, 

reduce cold temperature exhaust emissions, and reduce evaporation and 

permeation from portable fuel containers

Clean Alternative Fuel Vehicle and Engine Conversions3 - Updated anti-tampering 

provisions applicable to manufacturers of clean alternative fuel conversion systems 

for highway vehicles and engines

Light-Duty Greenhouse Gas (GHG) Emission Standards – Established the first 

mobile-source emission standards for greenhouse gases including carbon dioxide, 

methane, and nitrous oxide

Revisions and Additions to Motor Vehicle Fuel Economy Label –Redesigned label 

provides new information on vehicle fuel economy, energy use, fuel costs, and 

environmental impacts for conventional and advanced technology vehicles

2004

2005

2008

2010

All4

2012

2013

Highway Highway Motorcycle Exhaust Emissions-
10

Affected Industry

Sector/Category On-Road Mobile

Program/Rulemaking Description

Effective

Model

Year2

Motorcycles Class I and II: Established more stringent HC and added new optional hydrocarbons 

+ oxides of nitrogen (HC + NOx) standards; Added Class 1a (<50cc)

 Class III: Established new Tier 1 HC + NOx standard

 Class III: More stringent Tier II HC + NOx standard

Highway Motorcycle Permeation Emissions-Established new evaporative/permeation 

standards for fuel tanks and lines

2006

2006

2010

2008

Heavy-Duty 

Highway Engines 

and Vehicles

Light Heavy-Duty OBD –Established OBD monitoring requirements for heavyduty chassis certified vehicles, and for engines certified for use in heavy-duty 

vehicles between 8,500 and 14,000 pounds gross vehicle weight rating (GVWR)

Heavy-Duty Highway Rule– Established more stringent exhaust emission 

standards for heavy duty vehicles and engines; required Ultra Low Sulfur Diesel 

(ULSD) fuel (15 ppm sulfur maximum)

Heavy-Duty Engines OBD Rule–New OBD monitoring requirements for engines 

certified for use in Heavy-duty vehicles above 14,000 pounds GVWR

Heavy-Duty GHG Standards–Established first emission standards for greenhouse 

gas pollutants from heavy-duty engines and heavy-duty vehicles

2004

2007

2010

2014

2 Effective model year refers to the first year of a new program. Many programs are phased in over multiple model years.

ii.) Non-Road Mobile

A wide variety of Federal non-road mobile source initiatives have occurred resulting in reduced 

emissions. These measures continue to be phased in which will result in more emission reductions 

from non-road mobile sources in the future. No attempt has been made to quantify recent local 

emissions reductions from these measures, but future projects show significant reductions from this 

source category. This category covers everything from small gardening equipment through barge 

and locomotive engines. Data concerning non-road mobile source emissions can be found in 

Attachment I. Table III is adapted from the previously mentioned EPA publication and contains 

information about recent non-road mobile rules that have, and will continue to result in emission 

reductions from this source category. 

Table III

Affected Industry 

Sector/Category Non-road Mobile

Program/Rulemaking Description

Effective 

Model 

Year

Nonroad 

Compression 

Ignition 

Engines & 

Equipment

Construction 

& 

Agricultural

Tier-3/Interim Tier 4 – Established more stringent emission standards 

for engines between 37 and 560 kilowatts (50 and 750 hp)

Tier-4 Nonroad Diesel Rule –Established more stringent emissions 

standards for all engines greater than 19 kilowatts (25 hp) and lowered 

nonroad diesel fuel sulfur to 15 ppm maximum

2006

2010

Marine 

Diesel 

Engines

Tier 3 and Tier 4 Emission Standards for Marine Diesel Engines –

Established more stringent emission standards for newly built and 

remanufactured engines

2009

Locomotives

Tier 3 and Tier 4 Emissions for Locomotive Diesel Engines Established 

more stringent emission standards for newly built and remanufactured 

engines

2011

Nonroad 

Spark 

Small Spark 

Ignition 

Control of Emissions From Nonroad Spark Ignition Engines and 

Equipment –Established more stringent exhaust emission standards for 
11

Affected Industry 

Sector/Category Non-road Mobile

Program/Rulemaking Description

Effective 

Model 

Year

Ignition 

Engines &

Equipment

Engines 

(Small SI)

Class I (MY2012) and Class II (MY2011) engines below 19 kilowatts;

 and fuel permeation standards for all engines below 19 kilowatts 2011

2012

Marine 

Spark 

Ignition 

Engines 

(Marine SI)

Control of Emissions From Nonroad Spark Ignition Engines and 

Equipment –Established first federal exhaust emission standards for 

sterndrive and inboard Marine SI engines and increased the stringency 

of exhaust emission standards for outboard and personal watercraft 

engines. Established new evaporative emission standards for all Marine 

SI engines

2010

Large Spark 

Ignition 

Engines

(Large SI)

New Emissions Standards for Large SI Engines – Established new 

emission standards, diagnostic capability and portable Emission testing 

provisions

 Tier 1

 Tier 2

2004

2007

Recreational Vehicles

New Exhaust Emission Standards for RVs –

 Tier 1

 Tier 2

 Tier 3

 New permeation standards for fuel components

2006

2006

2010

2012

2008

Aircraft5

Established more stringent NOx exhaust emission standards for aircraft 

engines

Established new NOx emission standards for aircraft, engines consistent

with international standards

2005

2012

iii.) Point Sources

Shelby County continues to experience significant reductions in regulated air pollutant emissions 

from permitted industrial sources. From 2004 to 2014, reported industrial emissions fell by nearly 

30%. Some of this change is from changes in the mix of local sources with older facilities ceasing 

operation and newer, cleaner facilities moving in, and some of the change comes simply from 

industry efforts to operate in a more environmentally responsible way. However, a substantial 

portion of these reductions are a result of the implementation of new federal rules and activities in 

the area.

New and modified rules that have recently been implemented and have had an effect on local 

sources of O3 precursor emissions include Standards of Performance for New Stationary Sources 

(NSPS) rules found at 40 CFR Part 60, and National Emission Standards for Hazardous Air 

Pollutants (MACT) found at 40 CFR Part 63. 
12

B) Other Measures

i) Consent Decrees

In addition to new rules being implemented, in recent years, other federal actions have led to 

significant permanent reductions in point source O3 precursor emissions at three local facilities.

In 2006, EPA entered into a Consent Decree (CD) with Cargill Corn Milling. The CD required 

Cargill to install new control equipment and to conduct studies to optimize other existing controls. 

The controls specifically targeted emissions of VOCs and NOx. The CD involved multiple Cargill 

facilities across the country and it allowed the company some flexibility in achieving total 

reductions across all affected facilities. Though reduced maximum emission limits for NOx were 

placed on several large fuel burning sources, it appears the addition of new fuel burning control 

units may have offset these reductions such that facility-wide NOx emissions remained stable. 

However, when fully implemented, the additional VOC controls resulted in a total actual reduction 

of VOC emissions of 994 tons per year (tpy) between 2009 and 2014. The requirements of the CD 

have been incorporated into the company‟s recently renewed Title V major source operating permit.

Valero Refining entered into a CD with EPA on November 20, 2007, which required extensive 

emission controls to be installed progressively until December 31, 2013. The CD resulted in 

reductions of multiple pollutants, but regarding NOx sources, it required the retirement of 4 large 

legacy boilers and additional controls on a 5th production unit. Together, these resulted in actual 

NOx reductions of 236 tpy from 2007 through 2014. 

There are two actions, which when combined, have resulted in significant NOx reductions from the 

Tennessee Valley Authority‟s Allen Fossil Plant (TVA-Allen). EPA‟s Clean Air Interstate Rule 

(CAIR) updated and expanded the NOx Budget Trading Program set up as a result of the 1998 NOx

SIP call and required additional NOx reductions in 2009 through 2014. This rule gives allocations 

to states and allows trading among plants within the state, so it is not necessarily an enforceable 

reduction at any given plant. However, on April 14, 2011, TVA entered into a CD to resolve 

allegations of New Source Review violations. The CD requires system-wide annual limitations for 

NOx beginning in 2011 with further reduced limits through 2017. It also requires TVA to 

surrender NOx allowances from the TVA system for 2011 and subsequent years that TVA does not 

need in order to meet its own federal and/or state Clean Air Act regulatory requirements for that 

calendar year. In addition, the CD requires continuous operation of the installed selective catalytic 

reduction system at Allen. This greatly reduced TVA‟s flexibility to allow NOx emissions to rise at 

any given plant. TVA Allen reported 8061 tons of NOx emitted in 2008 and 2606 tons in 2009, the 

first year of CAIR. 2009 through 2011 emissions averaged 2548 tpy. After the CD, emissions for 

2012 through 2014 averaged 1908 tpy.

ii) Voluntary Efforts

Due in large measure to local political leadership, there has been a sharp increase in interest and 

application of sustainable practices in recent years. Many public, private and non-profit 

organizations are actively involved in projects ranging from massive infrastructure improvements 

to small alternative energy projects. 
13

In 2008, over 130 residents of the City of Memphis and Shelby County developed the Sustainable 

Shelby Implementation Plan. The plan was completed in early 2009 and laid out 151 strategies for 

a greener, smarter, and more sustainable future in Memphis and Shelby County. The strategies 

focused on areas such as neighborhood planning, energy efficiency and renewable energy, resource 

conservation, recycling, transportation, and community health amongst other issues. The Office of 

Sustainability was formed to oversee the strategies set and to report progress on these initiatives to 

the public. In April 2011, City of Memphis Mayor A C Wharton, Jr. and Shelby County Mayor 

Mark Luttrell, Jr. formed the Memphis and Shelby County Office of Sustainability. The Office is 

located in the joint City/County Division of Planning and Development.

The completed and ongoing projects are too numerous to list here and some of the projects do not 

directly result in improved air quality. But taken together, they represent a shift in the public‟s 

attitude to not only expect, but also to participate in projects and practices that are more 

environmentally acceptable than past practices. Two global measures that represent the success of 

these initiatives are a report that from 2009 through 2013, total annual energy consumption in 

Shelby County was reduced by 16.45%, and that from 2008 through 2013, bicycle use as a measure 

of transportation mode share increased by nearly 500%.

More detailed information can be found in the 2014 Sustainable Shelby Progress Report: 

http://www.sustainableshelby.com/sites/default/files/Implementation%20Plan/Sustainable%20Shel

by%20Progress%20Report%202014.pdf

6. Clean Air Act Section 110 and Part D Requirements

As previously noted in Section 3 of this petition, with the exception of certain administrative 

portions of the local codes, Shelby County and the associated municipalities adopt the State of 

Tennessee Air Pollution Control Rules by reference. The Department has worked closely with 

TDEC‟s Division of Air Pollution Control to harmonize state-level rules to reflect requirements 

within the County.

With respect to Section 110(a)(2) requirements, these are general requirements that have been in 

force and in place at the State and local level for many years. And, as noted earlier, no portion of 

these plans is currently subject to disapproval; a finding of failure to submit or implement a SIP; or 

partial, conditional, or limited approval.

Part D became effective as part of the 1990 amendments and consists of several subparts where 

subpart 1 provides general requirements for all nonattainment areas and the other subparts are 

pollutant-specific. In this case, subpart 2 contains the additional provisions for ozone 

nonattainment areas. Note, that in some cases, the subpart 1 general requirements may be 

subsumed within, or superseded by, the more specific subpart 2 requirements.

Under the marginal nonattainment classification in subpart 2, there is no requirement to develop 

and submit an attainment plan as required for more polluted areas under Section 172(c). This 

leaves Section 173, Permit Requirements, and Section 176, Limitations on Certain Federal 

Assistance (generally referred to as „conformity‟). Soon after the 1990 amendments, Shelby 
14

County, along with the state, adopted all new permitting requirements under part D. These have 

been periodically updated since then, but remain affective and in force. Also, the State has 

approved conformity provisions found at Tennessee Rule 1200-03-34 which has been adopted into 

local regulations.

Plan Submissions and Requirements for Marginal Areas: Section 182(a)

1) Inventory: An inventory was prepared for 2011, but the Department failed to finalize it 

through all administrative steps. Before that was completed, the area recorded clean data 

and resources were redirected to preparing an redesignation request and maintenance plan. 

It is noted the two year inventory requirement is meant to be used to develop Reasonable 

Further Progress (RFP) plans for areas classified moderate and higher. For redesignation, 

the Calcagni memo states that the requirements for an emission inventory will be satisfied 

by the inventory requirement of the maintenance plan. Since the 2012 inventory discussed 

in the maintenance plan is the area‟s „attainment inventory‟, The Department requests that 

this is the inventory that should be identified in the SIP.

2) SIP Corrections

a. RACT Corrections: All required VOC RACT corrections were approved by EPA 

on June 17, 1994 (59 FR 18310). Changes and additions to those rules occurred 2 

years later as a result of operation of the approved maintenance plan for the 1979 1-

hr. O3 NAAQS. 

b. Savings Clause for Vehicle Inspection and Maintenance: Though the City of 

Memphis operated a vehicle inspection and maintenance (I/M) program for many 

years, its purpose was for control of carbon monoxide (CO), not O3. There was 

never any CAA or plan requirement to have a county-wide I/M program for the 

control of O3.

c. Permit Programs: Shelby County is subject to Tennessee‟s fully-approved part D 

NSR permitting program, most recently updated on February 7, 2012 (77 FR 6016).

3) Periodic Inventory:

a. General Requirements: Shelby County is submitting a 2011 inventory and a 2012 

base year inventory with this petition and is committed to continue preparing and 

submitting a comprehensive triennial emission inventory in compliance with the 

AERR.

b. Emissions Statements: The emission statement requirements were initially 

approved on February 16, 1995 (60 FR 3352). We note the State rule was amended 

on March 5, 2015 (80 FR 11887). This change not only added emissions statements 

requirements for East Tennessee counties, it also clarified some of the language. 

During the local update process, this clarified language will be adopted.

7. Maintenance Plan

In accordance with Sections 107(d)(3)(E) and 175A, the following demonstrates maintenance of the 

O3 NAAQS throughout the maintenance period. This plan sets forth measures to be carried out 

after a redesignation request is approved by the EPA to prevent deterioration of the area‟s air 

quality. The Department has developed this plan to demonstrate maintenance of the O3 NAAQS 

from approval of the plan through 2027. During these years, the plan contains commitments to 
15

continue existing programs and to implement programs and measures depending upon emission 

inventory and air quality monitoring results. Provisions of this plan assure both an on-going effort 

to maintain the NAAQS and the obligation to implement new measures in the event of unforeseen 

developments.

A) Base Year Inventory and Future Projections

An attainment year inventory can be developed for any of the three years in which an attaining 

design value is computed. 2012 was chosen as the attainment year inventory for the Memphis 

TN-AR-MS nonattainment area after consultation with the surrounding states, EPA regions 4 and 

6, and the Memphis area MPO. Use of 2012 as the attainment year is believed to be 

representative of emissions during the three-year attainment period of 2012-2014. This inventory 

represents a comprehensive and accurate inventory of actual emissions from all sources of VOCs 

and NOx for 2012 within Shelby County. Future year emissions were projected from the 2012 

base year for 2017, 2020 and 2027.

Point Sources

The base-year point source emissions inventory is based on the 2012 Shelby County, Tennessee 

Emissions Inventory Questionnaire (EIQ) which is an annual emissions inventory survey conducted 

by the Department. The EIQ process is as follows, an EIQ containing data submitted the previous 

year is sent to the designated facility contact via e-mail. All facilities receiving the EIQ are required 

to update the data and return the information to the Department in an electronic format 

accompanied by a hardcopy printout. 

While emissions are reported in the EIQ on an annual basis, facilities are required to account for 

summer operations by providing the annual throughput, the seasonal throughput percentage, and the 

weekly operations schedule. In addition, it is understood that summer season percentage constitutes 

25% of the year. Taking all of these factors into account, typical summer/O3 season day emissions 

are determined in tons per day using the following equation:

Summer Season Day Emissions (tons per day) = ((Annual Throughput x SAF)/ (WAF x Weeks per Year))

Where:

SAF = Seasonal Throughput Percentage/ Percentage of Months Associated with Summer

WAF = Weekly Activity Factor (The Number of Days of operation per Week)

Nonpoint Sources

The 2012 base-year nonpoint source emissions inventory was developed using the methodologies 

provided in the Emissions Inventory Improvement Program (EIIP), Procedures for the Preparation 

of Emissions Inventories for Carbon Monoxide and Precursors of Ozone (Procedures Manual), as 
16

well as the methodologies developed by E.H. Pechan & Associates, Inc. (Pechan) for the USEPA 

and used in the 2008 NEI.

Nonpoint sources are sources of emissions too small to be inventoried individually but which 

collectively contribute significant emissions. Nonpoint sources include smaller stationary point 

sources not included in the point source inventory, such as, printing establishments, dry cleaners, 

and auto refinishing companies; as well as, non-stationary sources. 

Nonpoint source emissions are estimated by multiplying an emission factor by an activity factor 

that is representative of the nonpoint source category. An activity factor is any parameter 

associated with the activity level of a source that can be correlated with the air pollutant 

emissions from that source, such as production, number of employees, or population. Double 

counting of emissions can occur when there is overlap between point and nonpoint emissions 

categories. To avoid double counting in this emissions inventory, overlap categories were 

identified and point subtraction was performed where needed.

To characterize nonpoint source emissions that result from summertime operations, the following 

equation was used to estimate typical summer day emissions in ton per day:

Summer Season Day Emissions (tons per day) = ((Annual Throughput x SAF)/ (WAF x Weeks per Year))

Where:

SAF = Seasonal Throughput Percentage/ Percentage of Months Associated with Summer

WAF = Weekly Activity Factor (The Number of Days of operation per Week)

Non-road Mobile Sources

Nonroad mobile sources represent a large diverse set of off-road vehicles and non-stationary 

equipment. For the purpose of developing emission estimates, nonroad vehicles and equipment are 

grouped into four source category types, as follows: 

1.) non-road equipment – such as, agriculture, construction, lawn and garden, and recreational, 

2.) aircraft – commercial, military, and private aircraft, 

3.) commercial marine vessels – typically towboats, crew boats, and refueling boats (vessels 

other than recreational)

4.) locomotives – Class I line haul, switchyard, and passenger. 

With the exception of aircraft, commercial marine vessels, and locomotives, emissions estimates 

for non-road mobile equipment sources were generated with EPA‟s NONROAD2008 model, which 

includes estimates for growth based on expected future economic conditions as well as national 

controls. Aircraft emissions estimates were projected to 2012 by applying growth factors to

EPA‟s 2011 National Emission Inventory. Commercial marine vessel emissions estimates were 

developed from information obtained in the 2012 Waterborne Commerce, which is a reference 

source provided by the US Corp of Engineers, in combination with technical incite from US Corp 

of Engineers personnel and EPA emissions factors. Locomotives emissions estimates were 

generated from a 2012 survey of railroad companies operating in Shelby County. If railroad 

company officials fail to respond, locomotive emissions estimates were flat-lined based on previous 

submittal. Files containing non-road mobile source data are found in Attachments I.
17

On-road Mobile Sources

The on-road mobile source emissions inventory was developed with EPA‟s Motor Vehicle 

Emissions Simulator model (MOVES2014), using input data provided by the Memphis area 

Metropolitan Planning Organization (MPO). The 2012 base-year on-road mobile inventory was 

developed in accordance with the guidance provided in the document titled, “MOVES2014 

Technical Guidance: Using MOVES to Prepare Emissions Inventories in State Implementation 

Plans and Transportation Conformity, EPA-420-b-15-007”. For the 2012 model run, the RVP input 

parameter was set to the summertime regulatory limit of 7.8.

Future Year Projections

In accordance with Section 175 A of the CAA, the 2012 base year emissions estimates were 

projected to 2017, 2020, and 2027. These future year projections indicate that the emissions of 

VOC and NOx in Shelby County, Tennessee will remain below the estimates determined for the 

2012 attainment base year, and thus, will demonstrate maintenance of the NAAQS for at least 10 

years after redesignation. The methodologies used to develop all of the emission inventory 

categories is provided in the document titled “2012 Shelby County TN Emissions Inventory 

Calculation Methodology” which is provided in Attachment I of this document. A brief discussion 

of the future year projection methodology is provided below.

Future year point source emissions estimates for 2017, 2020, and 2027 were projected with growth 

factors developed from the United States Department of Energy, 2014 Annual Energy Outlook 

(AEO projections and the University of Tennessee, Data Center, 2014 Econometric Model 

Forecast. As a conservative measure, a value of 1 was substituted for all negative growth factors.

Files containing point source data can be found in Attachment I. 

Similarly, future year nonpoint source emissions estimates for 2017, 2020, and 2027 were projected 

with growth factors developed from the United States Department of Energy, 2014 Annual Energy 

Outlook (AEO) projections and the University of Tennessee, Data Center, 2014 Econometric 

Model Forecast. As a conservative measure, a value of 1 was substituted for all negative growth 

factors. Files containing nonpoint source data can be found in Attachment I. 

With the exception of nonroad mobile equipment, which utilized NONROAD2008 to generate

emissions estimates for future-year 2017, 2020, and 2027, the future-year emissions estimates for 

the nonroad mobile categories of aircraft, commercial marine vessels, and locomotives were 

projected with growth factors developed from the United States Department of Energy, 2014 

Annual Energy Outlook (AEO) projections. Files containing nonroad mobile source data can be 

found in Attachment I. 

Future-year on-road mobile source emissions estimates for 2017, 2020, and 2027 were generated 

with MOVES2014. For the 2017, 2020, and 2027 model runs, the RVP input parameter was set to 

9.0. The future year fuels were selected by exporting the default fuel specifications for Shelby 

County, Tennessee from the MOVES2014 fuel input screen panel, making the appropriate RVP 

adjustments, and then consulting with the MOVES Team via EPA Region 4 to determine if the 

fuels selected and adjustments performed were appropriate. Files containing on-road mobile source 

data are found in Attachments II through III. 
18

Though all details of the base year and future projected inventory can be found in the attachments, it

is important to point out several details regarding the on-road mobile analysis. In the MOVES 

model, the 2012 base year inventory is set to record the effects of a tailpipe only I/M program 

within the Memphis city limits and of the federally required summer gasoline volatility standard of 

7.8 Reid Vapor Pressure (RVP) while the future years are run with both of these measures removed 

from the model.

The City of Memphis closed the Inspection and Maintenance (I/M) program in July of 2013. This 

program was a requirement of the CO maintenance plan and was never relied on for ozone control. 

In fact, the area‟s second 10-yr CO maintenance plan clearly demonstrated it was not necessary for 

continued maintenance of that standard. However, though it was never incorporated as a 

Transportation Control Measure (TCM) in the 1997 8-hour O3 NAAQS maintenance plan, the CO 

plan relied on continuation of the program in modeling the on-road MVEBs. The shut down of the 

program required Shelby County to submit an amended O3 maintenance plan to account for the 

loss of expected emission reductions from the program. That amended SIP traded excess emissions 

that were available for stationary source offsets from a recently shuttered manufacturing facility in 

exchange for the predicted rise in emissions from closing the program. This permanently removed 

those excess emissions from the local nonattainment offset „bank‟, making them unavailable for use 

as emission offsets for nonattainment stationary source permitting. Details on that SIP amendment 

are available at the following website: https://xfer.shelbycountytn.gov/. To access it, enter 

“public” for the username and password in the Serv-U login screen panel and then left-click on 

“Login”. With the website open, select the folder “Pollution Control – Air Program” and then 

select the sub-folder “Shelby County Maint. Plan Rev. 2014-05-01”. In that amendment, it was 

necessary to adjust the MVEB used for conformity to update the inventory based on the new 

MOVES model rather than the old MOBILE6 model, as well as to account for the minor changes in 

the on-road and point source categories affected by the shut down of the local I/M program. At the 

time of preparation of this document, that SIP amendment has not yet been approved. 

With Stage 1 vapor controls on gasoline distribution and the proven widespread use of onboard 

refueling vapor recovery (ORVR) (77 FR 28772), the emission reductions due to lower vapor 

pressure summertime gasoline has become negligible and it is believed the requirement is no longer 

cost-effective. Shelby County intends to work with the State of Tennessee to prepare a petition in 

the near future to remove the reduced fuel vapor pressure requirement in Shelby County and the 

affected middle Tennessee counties. By modeling future year on-road emissions with the 7.8 RVP 

summer gasoline standard relaxed to 9.0 RVP, this offers a more conservative estimate of actual 

expected emissions thereby making the maintenance demonstration more robust.
19

The Shelby County base year and future year emission inventory estimates are presented in Table 

IV.

Table IV

Summer Season Tons Per Day

Shelby County Volatile Organic Compounds Emission Inventory

Type Year Area Non-Road On-Road Point Total

Base Year 2012 44.04 28.44 19.01 9.30 100.79

Interim Projection 2017 45.33 21.32 11.22 6.64 84.51

Interim Projection 2020 45.53 19.76 8.75 6.22 80.26

Maintenance Year 2027 46.30 19.33 5.81 6.24 77.69

Shelby County Nitrogen Oxides Emission Inventory

Base Year 2012 4.11 35.93 61.56 13.87 115.47

Interim Projection 2017 4.18 32.09 31.30 13.45 81.01

Interim Projection 2020 4.24 30.57 22.42 8.34 65.56

Maintenance Year 2027 4.34 29.77 12.51 8.43 55.05

B) Motor Vehicle Emissions Budgets

The transportation conformity rule found in 40 CFR Part 93 requires specific emission budgets to 

be defined for the on-road mobile sources portion of the Shelby County emission inventory. These 

budgets are to be used by transportation authorities to assure that transportation plans, programs, 

and projects are consistent with, and conform to, the maintenance of acceptable air quality in 

Shelby County throughout the term of the maintenance plan. Section 93.118(b) states in part:

Consistency with the motor vehicle emissions budget(s) must be demonstrated for each year 

for which the applicable (and/or submitted) implementation plan specifically establishes 

motor vehicle emissions budget(s), for the attainment year (if it is within the timeframe of 

the transportation plan), for the last year of the transportation plan's forecast period, and for 

any intermediate years as necessary so that the years for which consistency is demonstrated 

are no more than ten years apart, ...

Under 40 CFR 93.101, the safety margin is the difference between the attainment level and the 

projected level, from all sources, of emissions in the maintenance plan. The attainment level of 

emissions is the 2012 base year inventory. The available safety margin for a pollutant in any future 

year is the difference in the total inventory for each pollutant from the base year to the future year 

projections. Using allocations from the safety margin, different MVEBs may be set at different 

years over the course of the maintenance plan if needed to balance out expected increases and 

decreases in source category emissions in a manner to help insure no future year total inventory will 

exceed the base year attainment inventory and to insure no future year on-road emissions as 

determined by periodic conformity determinations will exceed the MVEB for that year. Since

significant emission reductions will occur in both on-road and point source categories over the life 

of the maintenance plan, no reallocation of a safety margin is needed. Therefore, after consultation 

with the local MPO and Tennessee State Air Program, it was decided the safety margin attributable 

to on-road reductions in NOx and VOC emissions will be allocated to the on-road projections for 

2027. In particular, 49.04 tpd of NOx and 13.19 tpd of VOC will be allocated to the 2027 MVEB 

resulting in a balance of 11.38 tpd of NOx and 9.91
20

tpd of VOC remaining in the safety margin. The MVEBs for VOCs and NOx are presented below 

in Table V.

Table V

Summer Season Tons Per Day

Volatile Organic Compounds On-Road Emission Budget 

Year Area NonRoad

OnRoad Point Total Safety 

Margin

On-Road 

Safety 

Margin 

Allocation

On-Road 

Budget

Remaining

Safety 

Margin 

2012 44.04 28.44 19.01 9.30 100.79 N/A N/A 19.01 N/A

2027 46.30 19.33 5.81 6.24 77.69 23.10 13.19 19.01 9.91

Nitrogen Oxides On-Road Emission Budget

2012 4.11 35.93 61.56 13.87 115.47 N/A N/A 61.56 N/A

2027 4.34 29.77 12.51 8.43 55.05 60.42 49.04 61.56 11.38

C. Air Quality Monitoring Network

The existing Shelby County ozone air quality monitoring network will continue to be operated in its 

present configuration. Any change will be in accordance with the Memorandum of Agreement 

(MOA) finalized on June 20, 2008 between the Shelby County Government, Arkansas Department 

of Environmental Quality (ADEQ) and the Mississippi Department of Environmental Quality 

(MDEQ) and as discussed in a letter dated February16, 2015. This MOA is in accordance with 40

CFR 58 Appendix D, Section 2(e) and is located in Attachment I along with a map showing area 

monitor locations in the Memphis MSA (see file re: Monitoring) and the aforementioned 2015 

letter. 

D. Emission Inventory

In order to track the progress of the maintenance plan, emission inventories of actual emissions for 

Shelby County will be performed using the latest emission factors, models and methodologies to 

include area, non-road mobile, on-road mobile and point sources of VOC and NOx. The major 

point source inventory will be updated annually while the full inventory will be updated every three 

years in accordance with the AERR beginning no later than the 2015 emission year.

E. Stationary Source Control

After redesignation to attainment, sources wishing to expand or locate in Shelby County will 

continue to undergo new source review requirements, except under PSD requirements for 

permitting in attainment areas found at Tennessee Rule 1200-3-9-.01 (4) and all existing stationary 

source controls will remain in force. Companies will continue to be sought for the purpose of 

voluntarily reducing VOC and/or NOx emissions where possible.

In addition to maintaining the point source regulatory program, there are developments at two local 

industrial sites which will result in significant reductions in point source O3 precursor emissions. 
21

Cargill Corn Milling (source # 00045) is in the process of shutting down almost all of its local 

operations which in 2014 emitted 743 tons of VOC and 525 tons of NOx. At the time of 

preparation of this document, the company had not yet surrendered its permit or submitted a 

modification application, but it is in the process of disassembling and removing large emission 

source equipment. Also, TVA has announced plans to shut down TVA-Allen (source #00528) by 

the end of 2018 to finalize compliance with the CD. They have submitted an application to build a 

new natural gas-fired combined cycle turbine generating unit in place of the Allen plant. This is 

expected to result in NOx emission reductions in excess of 1000 tons per year. 

F. Voluntary measures

Many of the projects mentioned in Section 5. B) ii.)of this document are ongoing and are expected 

to further help reduce local harmful emissions through energy conservation efforts and 

transportation-related projects

The Department maintains a meteorologist on staff to produce local air quality forecasts. These 

forecasts have been recognized by the states of Tennessee, Arkansas and Mississippi as the primary 

forecasts for the region and use them to conduct outreach to the counties surrounding Shelby 

County. Whenever the Department forecasts ozone levels above the NAAQS, an air quality alert is 

issued and the following actions take place:

The Department has developed a good working relationship with the local media and the air 

quality alert is typically included as part of the area‟s weather reports across multiple media 

platforms.

All open burning permits issued by the Department are suspended until the forecast shows 

improvement. During the summer season, holders of such permits are required to contact 

the office on a daily basis to determine if burning will be allowed.

Air quality alerts are posted on the Intelligent Transportation System boards located on the 

expressway system in Shelby County encouraging motorists to take actions to reduce 

emissions.

The Department has adopted a provision included in all stationary source permits for 

emergency power generators that prohibit their operation for maintenance and testing on air 

quality alert days. There are several very large stand-by power generation installations in 

Shelby County.

Besides these provisions, the Department will continue to look into effective ozone alert day 

measures and will continue an aggressive public education and outreach program begun in 2009. 

The Department will continue to work with State and local agencies to encourage adoption of 

measures to reduce ozone formation at all times, but especially during air quality alerts.

G. Contingency Provisions

Section 175A requires a maintenance plan to include contingency provisions to promptly correct 

any violation of the NAAQS which occurs after redesignation of an area to attainment. In addition, 

in order for an area to take early action to address potential violations of the NAAQS before they 

occur, it is recommended that contingency provisions will be enacted when specified action levels 
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indicate the need. Shelby County is adopting a two-phase approach to addressing ozone related air 

quality problems in the area. Each phase includes increasingly aggressive provisions to be 

implemented in the event of specified indicators.

Phase 1 of the plan addresses potential future problems as a result of unanticipated increases in 

local emissions. This will be implemented when the certified triennial emissions inventory of 

VOCs or NOx (summer season tons per day) exceeds the 2012 base year attainment inventory by 

ten percent (10%) or more and any area monitor has recorded at least one exceedance of the O3 

NAAQS according to certified data during the most recent monitoring season. On this occurrence, 

the Department will conduct an investigation into the possible causes to determine if they are 

attributable to reporting errors or a non-recurring anomaly in the local emission profile. The 

investigation will last no longer than three months when the results will be reported to the EPA and 

the Tennessee Air Pollution Control Division.

If the investigation reveals the data are valid and are not due to unusual circumstances, further 

action is required. Following consultation with the Tennessee Air Pollution Control Division and 

the EPA, the Department will seek to expand voluntary programs and develop regulations for 

submission to the Shelby County Commission or Tennessee State Air Board, as appropriate, to 

address the causes of concern. Proof of adoption of such regulations will be submitted to the EPA 

within nine months after the end of the investigation. All regulatory programs will be implemented 

within eighteen to twenty-four months after verification of a monitor exceedance by certified data. 

Such measures could include, but are not limited to:

Programs or incentives to decrease motor vehicle use;

Programs to require additional emissions reductions on stationary sources;

Restrictions of certain roads or lanes for, or construction of such roads or lanes for use by, 

passenger buses or high-occupancy vehicles

Employer-based transportation incentive plans; and,

Additional programs for new construction of paths for use by pedestrian or non-motorized 

vehicles when economically feasible and in the public interest.

Phase 2 will be implemented when a monitored violation of the 2008 ozone NAAQS occurs in the 

nonattainment area according to certified data during the most recent monitoring season. Similar to 

Phase 1, on that occasion, the Department will conduct an investigation to determine if the cause of 

the violation can be attributed to errors or clearly identifiable exceptional events outside of local 

control. Prior to certification of the data, the Department will solicit the involvement of all State 

agencies having jurisdiction in the surrounding area. The investigation will last no longer than 

three months when the results will be reported to the EPA and the Tennessee Air Pollution Control 

Division.

If the investigation reveals the data are valid, further action is required. In addition to the 

provisions described in Phase 2, following consultation with the Tennessee Air Pollution Control 

Division and the EPA, the Department will seek to expand voluntary programs and develop 

additional regulations for submission to the Shelby County Commission and Tennessee State Air 
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Board, as appropriate, to address the causes of concern. All regulatory programs will be 

implemented within eighteen to twenty-four months after verification of a violation by certified 

data. Such measures will include all measures which were contained in the state implementation 

plan for the area before redesignation of the area as an attainment area, and may also include:

A Reasonably Available Control Technology (RACT) regulation for legacy major sources 

of NOx emissions in Shelby County.

Adoption of all industrial and commercial VOC controls as provided in final EPA-approved 

Control Technology Guidelines (CTGs) through the date of the recorded violation.

Within six months of the conclusion of the investigation, the Department will prepare regulations 

for submission to the Shelby County Commission or Tennessee State Air Board, as appropriate, to 

adopt these controls. The effective date of these controls will be targeted to be within eighteen to 

twenty-four months after verification of the triggering event.