SIP AMENDMENT

Mayor’s Briefing

August 30, 2013
Carbon Monoxide Nonattainment 

Background

 1978 - Memphis designated as a carbon monoxide (CO) 

nonattainment area

 Vehicle Emissions Testing (I/M) selected as means to 

reduce CO emissions in area

 Basic Tailpipe Testing is the approved test method

 1994 – Memphis redesignated as an attainment area for CO

 First 10 year maintenance plan required for redesignation.

 County-wide I&M is shown as a contingency measure in the 

maintenance plan if excessive CO recorded

 2004 - Second 10 Year Maintenance Plan submitted

 This Maintenance Plan removes all references to required 

I/M as a CO reduction stragegy or contingency measure.
Ozone Nonattainment 

Background

 2004 Shelby and Crittenden Counties 

designated as Moderate Nonattainment area 

for the 1997 Ozone Standard.

 Moderate areas above a certain population 

are mandated by Clean Air Act to have I/M 

Programs

 Later that year EPA approved lowering the 

ozone nonattainment designation level from 

moderate to marginal, eliminating regional I/M 

requirements. 
Ozone Nonattainment 

Background (Con’t)

 2010 EPA approves local request for 

redesignation to attainment

 The Maintenance Plan submitted with the 

redesignation request is part of the State SIP 

 The Maintenance Plan includes commitment 

to continue Memphis’ tailpipe only I/M program

 This SIP commitment was breached with the 

closure of the 4 vehicle inspection stations on 

June 28, 2013
Equivalent Reduction of Emissions

Ozone Only 

 Section 193 of the Clean Air Act reads, in part, : 

 No control requirement ... required to be adopted by a 

...plan in effect before November 15, 1990, in any area 

which is a nonattainment area for any air pollutant may 

be modified ... unless the modification insures 

equivalent or greater emission reductions of such air 

pollutant.

 As I/M is a pollution control requirement only in the 

Ozone Maintenance Plan, only reductions of pollutants 

considered ozone precursers are needed. These are: 

 oxides of nitrogen (NOx), and 

 volatile organic compounds (VOC)]
Computer Model Forecast

(MOVES)

2013 Inspection and Maintenance Program Comparison

Pollutant No I/M

(tons/day)

With I/M 

(tons/day)

Projected 

Increase

(tons/year)

VOC 14.15 13.77 139

NOx 31.20 31.20 0
Computer Model Forecast

(Mobile 6)

Inspection and Maintenance Program Projected 

Increases 

(Tons/Year)

CO 9,125

VOC 400
Source of Emission Reductions 

 Cleo plant closure occurred in mid – 2011

 EPA’s 3 Year “Design Value” for latest Marginal 

Ozone designation is based on 2009-2011period.

 “Banked Emissions” i.e. emissions available for 

industrial permitting use (off-sets) by other major 

VOC sources seeking to expand or locate in nonattainment area

 Using Cleo’s actual VOC emissions, not larger 

“permit allowable” emissions.

 239.1 tons in 2009

 254.5 tons in 2010
Similar Actions by EPA

 EPA is proposing to allow termination of certain I/M 

obligations in the Milwaukee area 

 Illinois EPA is proposing to reduce the scope of the 

I/M programs in the Chicago and East St. Louis areas 

in dropping the inspection of vehicles not equipped 

with On-board Diagnostic (OBD) computer ports. 

 Both of these actions relied on shutdown of stationary 

sources in order to provide “equivalent or greater 

reductions” for lost emissions reduction benefits from 

operation of the I/M programs. 
Voluntary Measures

 Health Dept. 

 Ozone Action Days 

 Diesel Retrofit Initiatives

 Vanpool/Rideshare Program

 Intelligent Transportation System

 Energy Use Reduction Projects

 Shelby Farms Visitor Center

 County Buildings

 Sears Crosstown 

 Renewable Energy Generation at City Facilities

 Alternative Fuels Programs 

 CNG Projects

 Electric Car Charging Stations

 Solar Projects
Voluntary Measures (Con’t)

 Enhanced Bicycle and Pedestrian Projects

 CMAQ Projects 

 Shelby County Signal Project 

 MATA Hybrid Bus Purchase 

 Coordinated Signal System and Selected 

Intersection Improvement Projects 

 City of Memphis - 50-Mile Connections 
Draft Time Table for Amendment

 Receive EPA draft comments (Day 0) 

 Meet with municipal mayors 

 Final Draft ready (Day 14)

 Public Release & Notice of SIP Public Meeting (Day 30)

 Community Informational Meetings 

 SIP Public Meeting (Day 61)

 MPO Review and Approval 

 Close Formal Public Comment Period – (Day 76)

 Local Air Board Final Review and Final Recommendation 

 State Air Board Meeting – (Earliest -12/11/13)

 Submission of SIP Amendment to EPA 
Conclusion

 EPA has up to one year to act on the SIP 

amendment request we submit.

 EPA can proposed approval, partial approval, 

or disapproval with that determination 

published in the Federal Register 

 Public will have 30 days to comment before 

EPA’s action can become final.

 Likely to be significant national interest in this 

amendment due to subject matter and strategy 

for offsets proposed.