# 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.