December 15, 2015 STATE OFTENNESSEE DEPARTMENT OF ENVIRONMENTAND CONSERVATION DIVISION OFAIR POLLUTION CONTROL WILLIAMR. SNODGRASSTENNESSEETOWER 312 ROSA L. PARKS AVENUE, 15TH FLOOR NASHVILLE, TN 37243

Mr. Bob Rogers, Technical Manager Air Pollution Control Program Shelby County Health Department 814 JeffersonAvenue Memphis, TN 38105
Subject: Comments on the Shelby County Redesignation Request and Maintenance Plan (SCRRAMP-2015) for the 2008 Eight-Hour Ozone National Ambient Air Quality Standard
Dear Mr. Rogers,
The Tennessee Department of Environment and Conservation's, Division of Air Pollution Control offers the following comments regarding the Shelby County Redesignation Request and Maintenance Plan (SCRRAMP-2015) for the 2008 Eight-Hour Ozone National Ambient Air Quality Standard: 1. We recommend Table 1 be revised for clarity as there are a number of rows that indicate a single year as well as a 3year design value. We recommend the table be simplified and broken into two tables. Additionally, we recommend explanatory text be included in the document explaining the tables in awaythat is understandablefor a member of the public who is not familiar with ozone air quality data or ozone design values. This is acritical section as it encompasses airquality data. 2. We recommend including a map showing the locations of the ozone monitors depicted in figure 2. 3

. We recommend a thorough review to ensure appropriate labeling of tables

. It appears that tables II through IV are missing, or the tables are not numbered correctly. It also appears there aretwo tables labeled VI. 4. We recommend a footnote be added to the bottom of Table V to correspond with "Effective Model Year2" in thetable header. 5. Table VI indicates a drop in VOC emissions between 2017 and 2020 for Area sources, but it is not clear what accounts for this drop

. It seems to differ from the generaltrend. We recommend adding an explanationthat discussesthe drop. 6. On page 14; in section 1 of the Section 182(a) discussion, it is mentioned that resources were redirected to preparing an "attainment demonstration." WeBob Rogers, Manager Air Pollution Control Program December 15, 2015 Page2of2 recommend the text be modified to state a "redesignation request and maintenance plan" instead. 7. We recommend the discussion on the bottom of page 19 regarding motor vehicle emissions budgets be revised to clarify what is "not necessary" as stated in the sentence beginning "This is not necessary

...". 8. Table VII no longer has MVEBs set for the base year, 2012

. Did the MPO request MVEBs be setfor2012 as discussed and agreed to atthe August 51h MATS meeting (we note that abase year MVEB is optional)? 9. Caution should be exercised ifthe FuelsWizard was used in MOVES2014; EPA has issued a notice that the Fuels Wizard does not work properly in MOVES2014 and should not be used. How were the future-year fuels with the RVP of 9.0 and 10.0 selected ordeveloped? We recommend adding textto describethis in the document for the MPO's use in conformity determinations. Details on howfuture year onroad emissionswere developed should also be included in the document. 10.We recommend including a list of frequently used acronyms at the beginning ofthe document.
We look forward to receiving the final draft for the Air Board's consideration sometime in the nearfuture. Sincerely,



# w~?U~ MichelleWalkerOwenby Division Director Air Pollution Control