December 15, 2015 

STATE OF TENNESSEE 

DEPARTMENT OF ENVIRONMENT AND CONSERVATION 

DIVISION OF AIR POLLUTION CONTROL 

WILLIAM R. SNODGRASS TENNESSEE TOWER 

312 ROSA L. PARKS AVENUE, 15TH FLOOR 

NASHVILLE, TN 37243 

Mr. Bob Rogers, Technical Manager 

Air Pollution Control Program 

Shelby County Health Department 

814 Jefferson Avenue 

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 3 year 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 a way that is understandable for 

a member of the public who is not familiar with ozone air quality data or ozone 

design values. This is a critical section as it encompasses air quality 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 are two tables labeled VI. 

4. We recommend a footnote be added to the bottom of Table V to correspond with 

"Effective Model Year2

" in the table 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 

general trend. We recommend adding an explanation that discusses the 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." We 
Bob Rogers, Manager 

Air Pollution Control Program 

December 15, 2015 

Page 2 of 2 

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 set for 2012 as discussed and agreed to at the August 51

h MATS meeting 

(we note that a base year MVEB is optional)? 

9. Caution should be exercised if the Fuels Wizard 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 or developed? We recommend adding text to describe this in the document 

for the MPO's use in conformity determinations. Details on how future year onroad 

emissions were developed should also be included in the document. 

10. We recommend including a list of frequently used acronyms at the beginning of the 

document. 

We look forward to receiving the final draft for the Air Board's consideration sometime in the 

near future. 

Sincerely, 

w~?U~ 

Michelle Walker Owenby 

Division Director 

Air Pollution Control