# 2008 Ozone Standard Designation Recommendation for DeSoto County, Mississippi

Response to U.S. Environmental Pr otection Agency’s 120 Day Letter

Mississippi Department of Environmental Quality
Air Division February 2012Mississippi Department of Environmental Quality February 2012 - 2 - 

### Summary

In 2004, DeSoto County was excluded from the Memphis Non-Attainment Area as EPA determined that the county did not signifi cantly contribute to ozone levels in the Memphis area. Since that time, ozone concen trations have dropped significantly for all
of the monitors in the area and both Crittenden and Shelby Counties have subsequently attained the 1997 ozone standard. Therefore, this exclusion did not adversely effect the
ozone concentrations. Since the ozone leve ls have declined and DeSoto County is attaining the standard, there is no valid basis to reverse th e previous determination.

Based on current monitoring data, the Gove rnor of Mississippi recommended the designation of attainment for Desoto Count y. This recommendation is supported by current monitoring data, which shows that the Hernando monitor, located in DeSoto County, is attaining the standard of 75 ppb. The monitoring data shows that there has
been a decline in concentration at the DeSoto County Monitor since 2007 and that DeSoto County has been a ttaining the 2008 standard for the last 2 years. Pursuant to the Clean Air Act, Section 107(d )(1)(B)(ii), EPA is onl y required to use the Metropolitan Statistical Area as the presumptive boundary if the area will be designated as a Serious, Severe, or Extreme Area. Based on EPA’s proposed implementation rule, the Memphis Non-Attainment Area will likely be designated as Marginal. Therefore, EPA has discretion on the designation of the Memphis Non-Attainment Area.

On December 8, 2011 EPA recommended a partial non-attainment designation for DeSoto County. Due to the expedited revi ew process, EPA relied on older data and completed only a five factor analysis for their boundary recommendation.

In accordance with EPA policy 1 , there are nine factors to be considered in evaluating boundaries for designations of areas as non-at tainment. In this report, MDEQ has analyzed each of the nine fact ors using the latest data and an alysis. The analysis reveals overwhelmingly that DeSoto County does not contribute to violation of the ozone
standard in neither Crittenden C ounty, AR nor Shelby County, TN.

The first of the nine factors to consider is ai r quality data. Air mon itoring data shows that DeSoto County has attained the standard for th e last two years. Fu rthermore, all of the monitors in the proposed non-attainment designated area show a downward trend in ozone values. Accordingly, it is clear that DeSoto County does not contribute to the violations in Shelby or Crit tenden counties based on analysis of this first factor.

The second factor to be considered is em issions data. DeSoto County has only three facilities which are classified as major sour ces of emissions, while Shelby and Crittenden counties have exponentially more emission s ources. In addition, Shelby County has the Memphis International Airport, the number three rail center in the country and the International Port of Memphis. There ar e significant intermodal rail facilities in both Crittenden and Shelby counties. There are ni ne major truck centers in Crittenden County,

1 Meyers Memorandum, Area Designations for the 2008 Revised Ozone National Ambient Air Quality
Standards , Dec. 4, 2008six in Shelby County, and only one in DeSoto County. EPA erred in attributing only population based and general tra ffic factors as indicators of contribution, as the proof is overwhelming that the commerce activity in thes e areas is a much hi gher contributor with the emissions in closer proximity to the viol ating monitors than the emissions in DeSoto County. Thus, the complete anal ysis of this factor clearly supports that DeSoto County
does not contribute to the violations in Shelby or Crittenden Counties.

The third factor for consider ation is population density and degree of urbanization. In support of its proposed designation, EPA stat es that DeSoto County has the second highest population in the area; however, a broa der analysis reveals th at DeSoto County is a very, very distant second compared to Sh elby County. Further, the area of DeSoto County which is proposed to be included in the designated area is only moderately populated, and is a mere percentage of the to tal population and degr ee of urbanization of Shelby County. Based on this analysis, De Soto County does not contribute to the
violations of the ozone standard in Sh elby County, Tennessee or Crittenden County,
Arkansas.

The fourth factor for consideration is tra ffic and commuting patterns. An evaluation of
commuter traffic and Vehicle Mi les Traveled (VMT) reveals th at DeSoto County pales in comparison to the commuting within Shelby County. Further, Shelby and Crittenden counties are both dissected by I- 40, one of the busiest routes for heavy duty diesel trucks in the country. The percentage of traffic from heavy duty di esel trucks in Shelby County
and Crittenden counties is almost two and th ree times, respectively, higher than that of DeSoto County. Significantly, the Shelby C ounty Fraser monitor and the Crittenden County monitors are both in cl ose proximity to I-40. When the level of commerce traffic is properly considered in evalua ting this fourth factor, it is clear that DeSoto County does
not contribute to the violations of the oz one standard in Shelby County, Tennessee or Crittenden County, Arkansas.

The fifth factor to be considered is growth ra tes and patterns. EPA c ites a growth rate of 48% in Desoto County in the last decade, but th e use of a percentage based rate of growth is misleading when looking at the total popula tion in the entire Memphis MSA. Because of the relatively low 2000 population in Deso to County, even a 48% increase is still insignificant when compared to Shelby County and the entire Memphis MSA. Further, even while Desoto experienced this growth rate, the ozone values within the county, as well as the other monitors in the area, have steadily decreased. This plainly disproves EPA’s reasoning that Desoto’s gr owth rate contributes to viol ations of the ozone standard in Shelby and Crittenden counties.

The sixth factor to consider is meteorology. EPA relies in error on back tr ajectories to reach its determination that Desoto County should be included in the designated area; however, EPA failed to consider issues related to back trajectories specific to the Shelby County Fraser monitor. A more complete an alysis reveals that light winds and distant monitoring of those light winds cause the back trajectory analysis to be unreliable. Available modeling from Crittenden County, as well as EPA itself, reveals that Desoto

Mississippi Department of Environmental Quality February 2012 - 3 -County does not significantly contribute to ozone concentrations in Shelby County or
Crittenden counties.

The seventh factor to be considered is geography and topography. Analysis of the geography in the area does not reveal any cond itions which would a ffect the contribution of Desoto to the Shelby and Crittenden C ounty monitors. The topography of the area ranges from the flat lowland of the Mississippi Delta in the west to rolling hills in the central and eastern part of the MSA. This f actor does not appear to have a significant impact on the overall evaluation of the designation.

The eighth factor to be considered is juri sdictional boundaries. De soto County is in a different state with different governances than Shelby County, TN and Crittenden County, AR. Since the emissions in Desoto C ounty are such a small fraction of those in the other two counties, there is nothing Desoto County can do to impact violations in the other counties. If Desoto County were incl uded in the designation area, Desoto County and the State of Mississippi would be signifi cantly negatively impacted by a designation
over which it has no control and over which it has no regulatory authority to impact in any way. Based on consideration of this factor , it would be an error to include Desoto in the non-attainment designation.

The ninth and final factor for consideration is the level of emission sources. Considering the low emissions in Desoto County, there are few measures that co uld be applied that would yield significant reductions . The few facilities in th e county are well controlled. Further, both the county and the cities th erein have already undertaken voluntary measures to reduce mobile and area source emissions, which measures have had a positive effect in lowering ozone in Desoto County. The EPA failed to examine the level
of control of emissions in the area in making its proposed designation. MDEQ’s thorough analysis of this factor reveals that in addition to industry meeting strict standards, the citizens and leadership of Desoto County have been proactive in reducing
emissions. To now include Desoto in a non-at tainment designation after all they have done to successfully reduce emissions would be counterproductive in every sense of the
word.

MDEQ’s more thorough evaluatio n of all nine factors whic h EPA is to consider in determining boundaries for areas of non-attain ment reveals overwhelmingly that no part of Desoto County should be included in the designated area. Eight of the nine factors demonstrate powerfully that Desoto does not cont ribute to the violati ons of the standard in Crittenden and Shelby counties, and the ni nth factor bears no imp act either positively or negatively in the analysis. It would be an error to include De soto County in the area designated for non-attainment.

Mississippi Department of Environmental Quality February 2012 - 4 -Mississippi Department of Environmental Quality February 2012 - 5 - 

### Nine Factor Analysis

EPA recommends that the Metropolitan Statis tical Area (MSA) or Combined Statistical Area (CSA) serve as the starting point for de termining the geographic boundaries of an ozone non-attainment area. According to th e Clean Air Act, Sec tion 107(d)(1)(B)(ii), EPA is only required to use the Metropolit an Statistical Area as the presumptive boundary if the area will be designated as a Seri ous, Severe, or Extreme Area. Based in EPA’s proposed implementation rule, the Me mphis Non-Attainment Area will likely be designated as Marginal. Therefore, EP A has discretion on the designation of the Memphis Non-Attainment Area.

There are nine factors 2 that need to be evaluated in making the boundary determination.
These factors are:

• Factor 1: Air quality data

• Factor 2: Emissions data (location of sources and contribution to ozone concentrations)

• Factor 3: Population density and degree of urbanization (including commercial development)

• Factor 4: Traffic and commuting patterns

• Factor 5: Growth rates and patterns

• Factor 6: Meteorology (weat her/transport patterns)

• Factor 7: Geography/topography (mountain ra nges or other air basin boundaries)

• Factor 8: Jurisdictional bounda ries (e.g., counties, air distri cts, Reservations, metropolitan planning organizations)

• Factor 9: Level of control of emission sources

MDEQ has analyzed all factors us ing the latest data. Based on that analysis, eight of the nine factors clearly indicate that DeSoto County does not cont ribute to violation of the
ozone standard in neither Crittenden Count y, AR nor Shelby County, TN. The analysis reveals that the ninth factor, Geography, give s no evidence of contribution and is not a significant factor in the analysis.

2 See Footnote 1Mississippi Department of Environmental Quality February 2012 - 6 - 

### Factor 1: Air quality data

Table 1 shows the 4 th maximum concentrations for the 2008-2011 as well as the 2008- 2010 and 2009-2011 design values. DeSoto County ha s attained the standard for the last two years. Figure 1 shows a downward trend in ozone values for all of the monitors in
the area.

4 th Annual Maximum
8-hour Ozone County Site

2008 2009 2010 2011 3-Year Average
2008-2010 3-Year Average
2009-2011

DeSoto, MS Hernando 74 71 76 73 73 73 Shelby. TN Frayser 84 69 76 79 76 74 Shelby, TN Orgill Park 77 70 73 77 73 73 Crittenden, AR Marion 74 71 78 82 74 77 Table 1: Monitoring Data for the Memphis CSA 3



### Memphis Area 8-Hour Ozone Data 2001-2011

70 75 80 85 90 95 100

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011

YearDesign Value (ppb)

DeSoto Shelby - Orgill Shelby - Frayser Crittenden

Figure 1: Ozone Design Value Tre nds for monitors in the Memphis CSA 3

3 Mississippi Department of Environmental Quality , Shelby County Health Department, Arkansas Department of Environmental QualityEPA’s Technical Support Document (EPA-TSD ), attached as Appendix 1, says that a county (or partial county) should be designated if it contributes to a violation in a nearby county. Several recent air quality modeling studies have shown that Mississippi counties do not significantly contribute to ozone concentrations in Shelby County, TN or Crittenden County, AR. The “Analysis of Three 2005 Crittenden County Ozone Study (CCOS) Episodes Using Air Quality Modeling Tools” ( ADEQ, June 2007) report found that DeSoto County had an insignificant impact on the Shelby or Crittenden County
Monitors.

Additionally, the analysis EPA performed fo r Clean Air Interstate Rule (CAIR) and Cross-State Air Pollution Rule (CSAPR) di d not find any significant linkages for 8-hour ozone between Mississippi and Shelby County or Crittenden County. An analysis of the remaining factors also finds that DeSoto Count y does not contribute to the violations in Crittenden or Shelby Counties.

Since Desoto County is attaining the current stan dards and an analysis of data relevant to
the other factors finds that it does not contribut e to the violations in Shelby or Crittenden counties, DeSoto County, or any part thereo f, should not be included in the Memphis
Non-Attainment Area.

Mississippi Department of Environmental Quality February 2012 - 7 -

### Factor 2: Emissions data

Figure 2 is a detailed map of DeSoto, Shelby, and Crittenden Counties. Each of the four monitoring locations are marked with thei r corresponding ozone design values for 2008-
2010 and 2009-2011. There is one monitor in DeSoto County which is reading in
attainment of the 2008 ozone standard for both design values. There are two monitors in Shelby County. One monitor is in northern Shelby County and is reading in attainment for the 2008 ozone standard for both design values. The other monitor is within Memphis city limits near Interstate 240. This monitor is reading over the 2008 ozone standard for 2008-2010 but is under the limit for 2009-2011. The Crittenden County monitor is near the junction of Interstates 40 and 55 and meets the 2008 ozone standard
for 2008-2010 but is over the standard for 2009 to 2011.

The Memphis International Airport located approximately three miles south of the central business district of Memphis and is home to the main FedEx Express global "SuperHub", which processes a significant portion of the frei ght carrier's packages. The airport also serves as a hub for Delta Airlines. Memphis is the number three rail center in the United States with significant intermodal rail facil ities in both Crittenden and Shelby Counties.

The International Port of Memphis is 4th la rgest inland Port in the United States. The International Port of Memphis covers the Tennessee and Arkansas sides of the Mississippi River. The boundari es of the International Po rt of Memphis include the McKeller Lake/Presidents Island complex, th e West Memphis Har bor, the Rivergate Harbor, the Wolf River Harbor downtow n, and Fullen dock and harbor north of
downtown.

Major air emission sources for each county are represented on the map as well as major truck centers (truck stops). As shown by th e map, there are significantly more sources of emissions in Shelby County and in Crittenden County than in DeSoto County. There are
nine truck centers in Cri ttenden County, six in Shelby County, and one in DeSoto County. All of the truck centers in Crittenden County are located within five miles of the
ozone monitor. There are two locations in Crittenden County where major truck centers are too close to be accurately represented by separate markers. In these cases, the
number of truck centers located at thos e points are labeled on top of the marker.

Mississippi Department of Environmental Quality February 2012 - 8 -Figure 2: Monitor Locations in the Memphis CSA and Major Emission Sources

Mississippi Department of Environmental Quality February 2012 - 9 -Mississippi Department of Environmental Quality February 2012 - 10 - DeSoto County has a small number of major emission sources as shown in Figure 2. DeSoto County currently has two facilities that are classified as major sources of Nitrogen Oxides (NOx) and one facility classifi ed as major sources of Volatile Organic Compounds (VOCs). Charts 1 and 2 show the NOx and VOC emissions from all source categories in DeSoto, Shelby, and Crittenden Coun ties. These charts demonstrate that the total emissions from DeSoto County are sm all in comparison to those from Shelby County.

2008 NOx Emissions

0 5,000 10,000 15,000 20,000 25,000 30,000 35,000 40,000 45,000

Shelby Crittenden DeSotoNOx Emissions (tons)

Area

Point

Non-Road
Mobile
On-Road
Mobile

Chart 1: NOx and VOC Emission Comparison for Memphis CSA 4

4 U.S. Environmental Protection Agency, 2008 National Emissions Inventory (NEI)Mississippi Department of Environmental Quality February 2012 - 11 - 2008 VOC Emissions

0 5,000 10,000 15,000 20,000 25,000 30,000

Shelby Crittenden DeSotoVOC Emissions (tons)

Area

Point

Non-Road
Mobile
On-Road
Mobile

Chart 2: NOx and VOC Emission Comparison for Memphis CSA 5

The EPA-TSD identifies that mobile and area source emissions are the primary contributors of ozone precurso rs in the area. However, it incorrectly identified population based and general tr affic factors as the indica tors of contribution. The Memphis area is a very busy fr eight hub that results in a hi gh level of commerce based emissions. Interstate 40 runs through Shel by and Crittenden Countie s and is one of the
busiest interstates in the nation for heavy duty diesel truck traffic.

The Memphis/ West Memphis area is the numbe r three rail center in the United States with significant intermodal rail facilities in both Crittenden and Shelby Counties. West Memphis Arkansas also has the highest diesel sa les in the nation with nine truck centers. Many of the truck centers are grouped together and in close proximity to the Crittenden County monitor. Note from Figure 2 the proxim ity of the violating monitors to Interstate 40 and railroad lines. In addition, the Missi ssippi River carries a high volume of barge traffic that generates emissions and runs between Shelby and Critt enden Counties, both of which have river ports. The Memphis Airpor t is also the number one freight airport in
the nation that has aircraft related emissions and generate s a lot of truck traffic. Emissions from these sectors are not populat ion based and are not centered in DeSoto County. This commerce activity is a much higher contributor with the emissions in closer proximity to the violating mon itors than emissions in DeSoto County.

The overwhelming evidence of the emissions da ta demonstrates that DeSoto County does
not contribute to violations of the ozone standard in Shelby County, TN or Crittenden County, AR and should not be included in the Memphis Ozone Non-Attainment Area.

5 See Footnote 5Mississippi Department of Environmental Quality February 2012 - 12 - 

### Factor 3: Population density and degree of urbanization

The EPA-TSD states that “ areas of dense population or commercial development are an indicator of area source and mobile source NOx and VOC emissions that may contribute to

ozone formation. ” DeSoto County is also cited as having the second highest in population in the area. Chart 3 and 4 show the populat ion density and degree of urbanization for DeSoto, Shelby and Crittenden Counties. While DeSoto County is second, it is a very, very distant second compared to Shelby Count y. As noted in Chart 3, DeSoto County is not densely populated. The s outhern portion of the county is largely rural with the northern portion being a modera tely populated suburban area.

2010 Population Density

0 200 400 600 800 1,000 1,200 1,400

Shelby Crittenden DeSotoPopulation/square mile

Chart 3: Population De nsity of Memphis CSA 6

6 2010 U.S. CensusMississippi Department of Environmental Quality February 2012 - 13 - 2010 Total Population and Degree of Urbanization

0 100,000 200,000 300,000 400,000 500,000 600,000 700,000 800,000 900,000 1,000,000

Shelby Crittenden DeSotoPopulation

Urban Population Rural Population Non-Specified Chart 4: Total Population and Degree of Urbanization for Memphis CSA 7

Based on the analysis of the population de nsity and degree of urbanization, DeSoto County does not contribute to violations of the ozone sta ndard in Shelby County, TN or Crittenden County, AR and should not be included in the Memphis Ozone NonAttainment Area.

7 See Footnote 7Mississippi Department of Environmental Quality February 2012 - 14 - 

### Factor 4: Traffic and commuting patterns

The overall amount of traffic from Mississippi Counties in the CSA is much smaller than that of Shelby County. Likewise, the nu mber of commuters from the Mississippi Counties is much less than those from Shelby County. The amount of traffic is measured in Vehicle Miles Traveled (VMT) and is developed by the Mi ssissippi and Tennessee Departments of Transportation. Chart 5 compares the traffic data for the Counties in the Memphis CSA.

2010 County Population and Vehicle Miles Traveled

0 100,000 200,000 300,000 400,000 500,000 600,000 700,000 800,000 900,000 1,000,000

Shelby Crittenden DeSotoPopulation

0 1,000 2,000 3,000 4,000 5,000 6,000 7,000 8,000 9,000 10,000Vehicle Miles Traveld (million miles)

Population VMT

Chart 5: 2010 Population and Traffic Data 8
, 9

8 See Footnote 7

9 U.S. Department of Transportation, Federal Highways Administration, Highway Performance Monitoring SystemMississippi Department of Environmental Quality February 2012 - 15 - Commuting Patterns

0 50,000 100,000 150,000 200,000 250,000 300,000 350,000 400,000 450,000DeSotoCrittendenShelbyResidence County

Commuters DeSoto

Shelby

Crittenden

Chart 6: Commuting Patterns for Memphis CSA 10

Because commuting data is not yet available for the 2010 census, data from the 2000 census was used to determine the commuting patterns. Chart 6 summarizes this
information and shows that while there is some commuting between the Mississippi Counties and Shelby County, it pales in co mparison to the commuting within Shelby County. The majority of all commuters remain in their perspective counties for their
travel.

10 2000 U.S. CensusMississippi Department of Environmental Quality February 2012 - 16 - Figure 3: Average Daily Heavy Du ty Diesel Truck Traffic (2007) 11

Of particular significance is the concentra tion of heavy duty diesel truck in Shelby and
Crittenden Counties versus that of DeSoto County. Heavy duty diesel truck emissions are a significant source of NOx emissions. Figure 3 shows the truck traffic along the interstates across the southeast portion of the country.

Interstate 40 traverses from Wilmington, NC , across Tennessee and Arkansas (including Shelby and Crittenden Counties), to the west coast. I-40 is one of the busiest routes for heavy duty diesel truck traffi c in the nation. Along I-40 over 50% of the traffic in Crittenden County 12 and 35% in Shelby County 13 is from heavy duty diesel trucks. In DeSoto County 14 , 18% of the rural inters tate traffic along I-55 is from heavy duty diesel trucks, which is slightly below the national rural interstate average 14 of 19%. It should be

11 U.S. Department of Transportation, Federal Highways Administration, Office of Freight Management, Average Daily Long-Haul Truck Traffic on National Highway System , 2007

12 Arkansas State Highway and Transportation Department, 2010 Truck Percentages on the State Highway System Map

13 Memphis MPO, Travel Demand Model

14 U.S. Department of Transportation, Federal Highways Administration, Highway StatisticsMississippi Department of Environmental Quality February 2012 - 17 - noted that, as seen in Figure 2, the Shel by County - Frayser mon itor and the Crittenden County Monitor are both in clos e proximity to Interstate 40.

There are few local controls that can signi ficantly reduce vehicle emissions. However,
national vehicle emissions standards that EPA has implemented are resulting in significant reductions. MDEQ c ontracted with a consultant to model 2010 and 2020 peak hour on-road mobile emissions for DeSoto, Shelby and Crittenden Counties. The final report for the modeling is attach ed in Appendix 2 and the results are presented in Table 2. It is projected that there w ill be in an approximately 64% reduction in on-road mobile
NOx emissions and a 56% reduction from on -road mobile VOC emissions across the three counties due to road and traffic impr ovement and emission reductions from tighter
vehicle emission standards and fleet turnover. Th ese reductions will result in decreases in
ozone levels in the future and are independent of the ozone designations.

County 2010 to 2020 NOx Reductions (%) 2010 to 2020 VOC Reductions (%) Shelby 63.68 56.26

Crittenden 65.63 58.40

DeSoto 63.55 55.25 Table 2: Projected Peak-Hour On-Road Mobile-Source Emissions Reductions 15

Based on the analysis of the traffic and commuting patterns, DeSoto County does not
contribute to violations of the ozone st andard in Shelby County, TN or Crittenden County, AR and should not be included in the Memphis Ozone Non-Attainment Area.

15 Mississippi Department of Environm ental Quality, Neel -Schaffer, Inc., On-Road Mobile-Source Emissions Forecast For Desoto County, Mississippi (2010 to 2020) , 2012Mississippi Department of Environmental Quality February 2012 - 18 - 

### Factor 5: Growth rates and patterns

DeSoto County has experienced moderate grow th, approximately 5% per year sine 2000. However, the growth rate has slowed significantly since 2006. The EPA-TSD cites a growth rate of 48% over the last decade, but using a percentage base d rate is misleading because of the counties relatively low 2000 population. The real increase in numbers is 53,000 people over the last decade. Compar ed to the population of Shelby County (927,000) or the entire Memphis MSA ( 1,316,000), the growth is not significant.

DeSoto County Growth versus Ozone Design Values

70 75 80 85 90 95 100

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011
YearDesign Value (ppb)

100,000 125,000 150,000 175,000 200,000DeSoto County Population

DeSoto Shelby - Orgill Shelby - Frayser Crittenden DeSoto Population
Chart 7: DeSoto County Growth versus Ozone Design Values 16

In addition, while DeSoto County has experien ced this growth, the ozone values in the County, as well as other monitors in the area, have steadily decreased. Chart 7 shows the growth trend and the ozone values since 2000. If the growth and population in DeSoto County were a contributing factor, then it be evidenced by increased ozone readings by the DeSoto County monitor.

Based on the analysis of the growth rate and patterns, De Soto County does not contribute
to violations of the ozone standard in Shelby County, TN or Crittenden County, AR and should not be included in the Memphis Ozone Non-Attainment Area.

16 See Footnotes 3 and 7

### Factor 6: Meteorology (weather and transport)

Back Trajectories

In the EPA Technical Support Document, EPA used the NOAA HYSPLIT model to run 24-hour and 72-hour back traject ories at the Frayser – Shelby County ozone monitoring site during ozone exceedance days for the pe riod of 2006 – 2010. The results seemed to indicate that many of the back trajectory centerlin es passed through DeSoto County. However, the following issues should have been considered when performing such an analysis:

• On most days, 24-hour back trajectories were less than 200 miles long for the Frayser site during the period of 2006-2010.

• This indicates that the average wind speeds were less than 8 mph.

• When there is a light wind regime wind di rections can vary significantly at the
surface.

• HYSPLIT uses surface and upper air wi nd conditions to calculate back trajectories. In this case, surface wi nds from the Memphis NWS station were used, but the closest upper-air wind data site is located in Little Rock, Arkansas - ~130 miles from Memphis.

• HYSPLIT is not accurate under light wind conditions because of the light wind direction variability.

Because of these issues, a back trajectory analys is is unreliable in determining if transport was occurring on the ozone exceedance days. Ther efore, it should not have been used as
a factor in the determin ation of the Memphis Non-Attainment Area boundary.

Modeling

In the past, there have been air quality m odeling studies that s how that Mississippi counties do not significantly contribute to oz one concentrations in Shelby County, TN or Crittenden County, AR. The “Analysis of Three 2005 Crittenden County Ozone Study (CCOS) Episodes Using Air Quality Modeling Tools” ( ADEQ, June 2007) report found that DeSoto County had an insignificant impact on the Shelby or Crittenden County
Monitors. This can be seen in Chart 8.

Mississippi Department of Environmental Quality February 2012 - 19 -Mississippi Department of Environmental Quality February 2012 - 20 - Contribution to Ozone from Regions

0 10 20 30 40 50 60

SW Ind Area Rest of Memphis Rest of Shelby County Crittenden County DeSoto County OtherOzone Contribution (ppb)

Crittenden County Monitor Shelby County - Frayser Monitor

Chart 8: Contribution to Ozone from Regions 17

In addition, the analysis that EPA performed for Clean Air Interstate Rule (CAIR) and Cross-State Air Pollution Rule (CSAPR) di d not find any significant linkages for 8-hour ozone between Mississippi and Shelby Count y or Crittenden County. These rules were developed to particularly a ddress the contribution of emi ssions from upwind states to
downwind non-attainment or maintenance areas . While the rules address the emissions from Electric Generating Units, the analysis to determine contribu tion included emissions from all source categories.

Therefore, the available modeling data indicates that DeSoto County does not significantly contribute to ozone concentrations in Shelby County or Crittenden County. Based on the analysis of the meteorology, b ack trajectories, and modeling, DeSoto County does not contribute to violations of the ozone sta ndard in Shelby County, TN or Crittenden County, AR and should not be included in the Memphis Ozone NonAttainment Area.

17 Arkansas Department of Environmental Quality, Analysis of Three 2005 Crittenden County Ozone Study (CCOS) Episodes Using Air Quality Modeling Tools , June 2007

### Factor 7: Geography and topography

The Mississippi counties in the Memphis MSA ar e located in northwes tern Mississippi.
DeSoto and Tunica counties bord er the Mississippi River. DeSoto and Marshall Counties border Tennessee while Tate is directly sout h of DeSoto County. The topography of the area ranges from the flat lowland of the Missi ssippi Delta in the west to rolling hills in the central and eastern part of the MSA. Analysis of the geography and topography does not show a DeSoto County contribution to vi olations of the ozone standard in Shelby County, TN or Crittenden County, AR and should not be factored in to include DeSoto County in the Memphis Ozone Non-Attainment Area.



### Factor 8: Jurisdictional boundaries

DeSoto County is in a separate state with different governances than Shelby or Crittenden County. The DeSoto County monitor is attaining the standard. The emissions in the County are a small fraction of those in Sh elby County and the evidence indicates that they are not contributing the violations in other counties. If Desoto County were included in the non-attainment area, neither DeSoto County nor Mississippi would be able to impact the monitors by controlling emissions and would have no authority to
control emissions in the other states. DeSoto County and th e State of Mississippi would be significantly negatively impacted by a de signation over which it has no control and over which it has no regulatory au thority to impact in any way.

DeSoto County was excluded from the Mem phis Non-Attainment Area in 2004 because it was determined that the county did not sign ificantly contribute to ozone levels in the Memphis area. Ozone concentrations have dr opped significantly for all of the monitors in the area since the designation and bot h Crittenden and Shelby Counties have subsequently attained the 1997 ozone standa rd. Therefore, this exclusion did not adversely effect the ozone concentrations. Since the ozone levels have declined and DeSoto County is attaining the standard, ther e is no valid basis to reverse the previous
determination.

Based on the precedence set by EPA in 2004 and the fact that DeSoto County has no control or authority over emissions impacting other monitors, it is illogical to include DeSoto County in the Memphis Non-Attain ment Area. Therefore, DeSoto County
should be excluded from the non-attainment designation.

Mississippi Department of Environmental Quality February 2012 - 21 -

### Factor 9: Level of contr ol of emission sources

Considering the low air emissions in DeSoto County, there are few measures that could be applied that would yield significant re ductions. Overall, the few facilities in Mississippi are well controlle d. Southaven Power is a newe r gas cogeneration plant that meets BACT standards, Rexam Beverage Ca n has VOC capture and control devices to control emissions beyond NSPS requirements, and Texas Gas has voluntarily opted to include operational restricti ons in its permit that reduces NOx emissions during Ozone
Season.

There have also been measures taken to reduce mobile and area source emissions in DeSoto County. Mississippi has revised th e Air Pollution Regulations to prohibit all open burning on Ozone Action Days. Open Burn ing is banned on all days in Hernando. Also, DeSoto County and the ci ties within the county have en acted strict idle reduction policies to reduce mobile source emissions from the county. The program to develop Idle Reduction Policies in DeSoto County and samp le policies from within the county are shown in Appendix 2.

Additionally, ninety-three of DeSoto County’s school buses have been retrofitted with diesel oxidation catalysts (DOC). All of DeSoto County's buses have either DOCs installed or other technologies to meet current diesel emission standards. In the surrounding counties, MDEQ has retrofitted an additional 57 buses with DOCs. Furthermore, there have been nine MDEQ Diesel Emission Reduction Projects reflecting 35 pieces of diesel equipment in and around DeSoto County. Private companies have spent over $100,000 of their own money as matching funds for these projects.

The DeSoto Planning Commission began the Ozone Action Group to engage public and private groups in finding emission reductions and providing public outreach. This group meets monthly to promote and encourage beha vior by the general public that will result in beneficial emission reductions. MDEQ , DeSoto County Ozone Action Group, and the DeSoto County Planning Commission have engaged in numerous outreach events throughout the county. A puppet show was also developed as an additional outreach tool for schools and public outreach. Outreach activities are listed in Appendix 4.

The Mississippi Department of Transportation (MDOT) has spent over $1 million in the Safe Routes to School program, sidewalks, and bike path improvements in DeSoto County and has conducted an I-69 Corridor Alternatives Analysis to study preferred mass transit options for DeSoto County.

The EPA-TSD fails to examine the level of c ontrol of emissions in the area. A proper
examination of this factor shows that in addi tion to industry that m eets strict standards, the citizens and leadership of DeSoto County have also been proactive in reducing
emissions.

As shown in this section, DeSoto County, MD EQ, and their strategic partners have been proactive in reducing emissions in the county. An arbitrar y decision by EPA to include

Mississippi Department of Environmental Quality February 2012 - 22 -DeSoto County in a non-attainment area would hinder these efforts. Therefore, DeSoto County should be excluded from the Memphis Non-Attainment Area.



### Conclusion

Based on the analysis of the nine factor s specified by EPA to be considered in determining the boundaries of the area to be de signated as non-attainment, the evidence is overwhelming that Desoto does not contribute to the violatio n of standards in Crittenden County, AR, and Shelby County, TN. Eight of th e nine factors fall in favor of excluding Desoto County from the area of non-attainment, and the ninth factor bears no impact on the analysis. Desoto was properly excluded fr om the designation in 2004, and since that time, has only improved upon its efforts to c ontrol and reduce emissions in the county.
EPA should re-evaluate its decisi on in light of the additional information provided in this report, and should exclude Desoto County from the designated area.

Mississippi Department of Environmental Quality February 2012 - 23 -

# Appendix 1: EPA’s Technical Support Document - Mississippi Area Designations for the 2008 Ozone National Ambient Air Quality Standards

Mississippi Department of Environmental Quality February 2012 - 24 -1 

### Mississippi Area Designations f

or the
20 08 Ozone National Ambient Air Quality Standard s

The table below identifies the areas and associated counties or parts of counties in Mississippi that EPA intends to designate as nonattainment for the 2008 ozone national ambient air quality standards (2008

ozone NAAQS). In accordance with section 107(d) of the Clean Air Act, EPA must designate an area (county or part of a county) “nonattainment” if it is violating the 2008 ozone NAAQS or if it is contributing to a violation of the 2008 ozone NAAQS in a nearby area. The technical analyses supporting the boundaries for the individual nonattainment areas are provided below.

Intended Nonattainment Are as in Mississippi

Area Mississippi ’s Recommended
Nonattainment Counties EPA’s Intended Nonattainment
Counties Memphis, TN

- MS

- AR * None DeSoto(partial)

* Memphis , TN

- MS

- AR is a multi

- state nonattainment area. Table 1 below identifies t he counties in the
other states that EPA intends to designate as part of the nonattainment area.

EPA intends to designate the remaining counties in Mississippi that are not listed in the table above as

“ unclassifiable/ attainment ” for the 20 08 ozone NAAQS

.

The analysis below provides the basis for intended nonattainment area boundar ies. It relies on our analysis of whether and which monitors are violating the 20 08 o zone NAAQS

, based on certified air quality monitoring data from 2008

- 2010 and an evaluation of wh ether nearby areas are contributing to
such violations. EPA has evaluated contribution s from nearby areas based on a weight of evidence analysis considering the factors identified below and other relevant information. EPA issued guidance

on December 4, 2 008 that identified these factors as ones EPA would consider in determining nonattainment area boundaries and recommended that states consider these factors in making their designations recommendations to EPA. 1

1. Air quality data (including the design value calculated for each Federal Reference Method monitors or Federal Equivalent Method (FEM) monitor in the area);
2. Emissions and emissions

- related data ( including location of sources and population, amount of
emiss ions and emissions controls, and urban growth patterns) ; 3. M eteorology (weather/transport patterns) ; 4. G eography and topography (mountain ranges or other basin boundaries) ; 5. J urisdictional boundaries (e.g., counties, air districts, existing nonattainment areas, Indian
country , metropolitan planning organizations (MPOs))

Ground

- level ozone generally is not emitted directly into the air, but is created by chemical reactions between oxides of nitrogen ( NOx) and volatile organic compounds (VOC) in the presence of sunlight.

Because NOx and VOC emissions from a broad range of sources over a wide area typically contribute to
violations of the ozone standard s , EPA believes it is important to consider whether there are contributing emissions from a broad geographic area. Accordingly, EPA chose to examine the 5 factors with respect

1 The December 4, 2008 guidance memorandum “Area Designations for the 2008 Revised Ozone National Ambient Air Quality Standards” refers to 9 factors. In this technical support document we have grouped the emissions

- related factors together under the headin g of “Emissions and Emissions

- Related Data

, ” which results in 5 categories of factors.2

to the larger of the Combined Statistical Area (CSA) or Core Based Statistical Area (CBSA) associated with the violating monitor(s )

. 2 All data and information used by EPA in this evaluation are the latest available to EPA and/or provided to EPA by states or tribes.

In EPA’s designations guidance for the 2008 ozone NAAQS EPA recommended examining
CSA/CBSA s because certain factors use d to establish CSAs and CBSAs are similar to the factors EPA is using in this technical analysis to determine if a nearby area is contributing to a violation of the 20 08 ozone NAAQS. Congress required a similar approach in 1990 for areas classified as ser ious or above
for the 1

- hour ozone standard and EPA used the same basic approach in the designation process for the
1997 o zone NAAQS. Where a violating monitor is not located in a CSA or C BS A, EPA ’s guidance recommended using the boundary of the county co ntaining the violating monitor as the starting point for considering the nonattainment area’s boundary.

2 Lists of CBSAs and CSAs and their geographic components are provided at www.census.gov/popu lation/www/metroareas/metrodef.html . The lists are periodically updated by the Office of Management and Budget. EPA used the most recent update, based on 2008 population estimates, issued on December 1, 2009 (OMB Bulletin No. 10

- 02).3

Technical Analysis for Memphis , TN

- MS

- AR

Figure 1 is a map of the Memphis , TN

- MS

- AR intended nonattainment area. The map provides other relevant information including the locations and design values of air quality monitors , county and other jurisdictional boundaries, relevant statistical area boundaries, the nonattainment area boundary for 1997 ozone NAAQS, and major transportation arteries.

Figure 1. TN

- MS

- AR Nonattainment Area

For purposes of the 1997 8

- hour ozone NAAQS, portions of this area were designated nonattainment. The boundary for the nonattainment area for the 1997 o zone NAAQS included the entire counties of Crittenden County, Arkansas, and Shelby County, Tennessee.

I n March 2009, Mississippi recommended that DeSoto County, Mississippi be designated as a
nonattainment area separate from the Memphis nonattainment area for the 2008 ozone NAAQS based on air quality data from 2006

- 2008. Mississippi provided an update to the original recommendation in October 2011 based on air quality data from 2008

- 2010, and preliminary data from 2009

- 2011. In its updated recommend ation, Mississippi recommended that all counties in the State be designated4

attainment for the 2008 ozone NAAQS. Letter from Haley Barbour, Governor of the State of Mississippi to A. Stanley Meiburg, Acting Regional Administrator, US EPA Region 4 (March 3, 2009) and Gwendolyn Keyes Fleming, Regional Administrator US EPA Region 4 (October 27, 2011) (on file with US EPA Region 4). Also, i n March 2009, Tennessee recommended that Shelby County be designated “nonattainment” for the 2008 8

- hour ozone standard ba sed on air quality data from 2006

- 2008. Letter from James H. Fyke, Commissioner, State of Tennessee Department of Environment and Conservation to A. Stanley Meiburg, Acting Regional Administrator, US EPA Region 4 (March 10, 2009) (on file with US EPA Regi on 4). Tenn essee provided an update to its original recommendation in November 2011 based on preliminary 2009

- 2011 air quality data. In Tennessee’s updated recommendation, the state did not provide a specific update to its 2009 recommendation for the

Mem phis TN

- MS

- AR but stated that all other counties (with the exception of those recommended for Knoxville) should be designated unclassifiable/attainment

. Letter from Robert J. Martineau Jr, Commissioner, State of Tennessee Department of Environment and Cons ervation to Gwendolyn Keyes Fleming, Regional Administrator, US EPA Region 4 (November 8, 2011) (on file with US EPA Region 4).

Additionally, in March 2009, Arkansas recommended that Crittenden County, Arkansas be designated
nonattainment based on 2006

- 2 008 air quality data. Arkansas did not update its 2009 ozone
recommendation. T hese data are from FEM monitors sited and operated in accordance with 40 CFR
Part 58. Letter from Mike Beebe, Governor of the State of Arkansas to Lawrence E. Starfield, Acting Regional Administrator, US EPA Region 6 (March 10, 2009) (on file with US EPA Region 6).

After considering these recommendations and based on EPA's technical analysis described below, EPA intends to designate one county in Arkansas, one county (partial) in Mississippi

, and one county in Tennessee (identified in Table 1 below) as nonattainment for the 2008 ozone NAAQS as part of the Memphis, TN

- MS

- AR multi

- state nonattainment area.

Table 1. State's Recommended and EPA’s Intended Designated Nonattainmen t Counties for Memphis

, TN

- MS

- AR

.

Memphis , TN

- MS

- AR State

- Recommended
Nonattainment Counties EPA Intended
Nonattainment Counties
Arkansas Crittenden Crittenden Mississippi None DeSoto (partial)

Tennessee None Shelby

Factor Assessment



### Factor 1: Air Quality Data

For this factor , we considered 8

- hour o zone design values (in parts per billion (ppb)) for air quality
monitors in counties in the Memphis, TN

- MS

- AR area based on data for the 2008

- 2010 period (i.e., the 2010 design value, or DV) , which are the most recent years with fully

- certified air quality data

. A
monitor’s DV is the metric or statistic that indicates whether that monitor attains a specified air quality
standard. The 2008 o zone NAAQS are met at a monitor when the annual f ourth

- highest daily maximum
8

- hour average concentration, averaged over 3 years is 75 ppb or less

. A DV is only valid if minimum data completeness criteria are met. See 40 CFR part 50 App endix P . Where several monitors are located in a county (or a des ignated nonattainment area or maintenance area ), the DV for the county or
area is determined by the monitor with the highest level.5

The 2010 DVs for the o zone NAAQS for counties in the Memphis and nearby surrounding area are shown in Table 2

.

Table 2. Air Quality Data 3

. County State Recommended
Nonattainment? 2008

- 2010 Design Value (ppb) Crittenden, AR Yes 74

DeSoto , MS No 73 Shelby, TN No 76

Shelby County , Tennessee shows a violation of the 2008 ozone NAAQS, therefore this county is included in the nonattainment area. A county (or partial county) must also be designated nonattainment if it contributes to a violation in a nearby area. Each county without a violating monitor that is located near a county with a violating monitor has been evaluated , as discussed below, based on the five factors
and other relevant information to determine whether it contributes to the nearby violation

.



### Factor 2: Emissions and Emissions

- Related Data

EPA evaluated emissions of ozone precursors ( NO x a nd VOC ) and other emissions

- related data that provide information on areas contributing to violating monitors.

Emissions Data

EPA evaluated county

- level emission data for NO x and VOC derived from the 200 8 National Emissions Inventory (NEI), version 1.5

. This is the most recently available NEI. (See http://www.epa.gov/ttn/chief/net/2008inventory.html ) Significant emissions levels in a nearby area indicate the potential for the area to co ntribute to observed violations. We will also consider any additional information we receive on changes to emissions levels that are not reflected in recent inventories. These changes include emissions reductions due to permanent and enforceable emissions controls that will be in place before final designations are issued and emissions increases due to new

sources. The precursor emission source

- category percentages used below and throughout the document
were derived from emissions data from the 2008 NEI v ersion 1.5 referenced above.

Table 3 shows emissions of NO x and VOC ( given in tons per year (tpy)) for violating and nearby
counties that we considered for inclusion in the Memphis, TN

- MS

- AR area.

Table 3. Total 2008 NO x and VOC Emissions.

County State Recommended

Nonattainment NO
x (tpy) VOC (tpy) Crittenden, AR Yes 4,047 3,805 DeSoto, MS No 5,080 5,222 Fayette, TN No 2,385 1,406
Marshall, MS No 1,769 1,527

3 Only counties in the Memphis CBSA that have ozone monitors are included in this table.6

Shelby, TN No 39,519 27,929
Tate, MS No 3,102 1,392 Tipton, TN No 2,119 2,251
Tunica, MS No 1,598 1,096

Areawide: 59,619 44,628 *Counties that EPA intends to designate as nonattainment are shown in bold.

DeSoto County contributes about 9 percent NOx and 12 percent VOC precursor emissions in the CBSA. The County’s 5,080 NOx emissions are mostly comprised of 45 percent area sources, 35 percent mobile sources. DeSoto County’s total VOC emissions include 44 percent area sources and 34 percent mobile

sources.

Shelby County contributes about 66 percent of the NOx and 63 percent of the VOC precursor emissions
in the CBSA. Shelby makes up 23 percent of the entire CBSA NOx emissions and 22 percent of the area’s VOC emissions. Of the county’s 39,519 NOx emissions, 35 percent are from point and mobile emissions and 20 percent from area source emissions. The County’s 27, 929 VOC emissions include 36 percent mobile sources and 32 percent area sources

.

Crittenden County contributes less than 10 percent of the precursor CBSA emiss ions. Of the County’s total NOx emissions listed in Table 1, 45 percent are from mobile sources and 34 percent from area sources. The County’s total VOC emissions include 35 percent from area sources and 31 percent from mobile sources. Only 5 percent of the County’s NOx emissions are from point sources. Both Crittenden and DeSoto Counties represent less than 1 percent of the entire area’s NOx and VOC point source
emissions

Fayette and Tipton Counties in Tennessee and Marshall, Tate, and Tunica counties in Mississippi all contribute 5 percent or less NOx and VOC precursor emissions in the CBSA.

Together, Crittenden, DeSoto and Shelby Counties account for 82 percent of the NOx emissions and 83 percent of the VOC emissions for the 8

- county area. The em issions from Fayette and Tipton Counties in Tennessee and Marshall, Tate and Tunica Counties in Mississippi are not thought to contribute to the violations of the 2008 ozone NAAQS that have been observed by monitors in Shelby County, Tennessee
and Crittend en County, Arkansas

.

Population density and degree of urbanization

EPA evaluated the population and vehicle use characteristics and trends of the area as indicators of the probable location and magnitude of non

- point source emissions . These include ozo ne

- creating
emissions from on

- road and off

- road vehicles and engines, consumer products, residential fuel combustion, and consumer services. Areas of dense population or commercial development are an indicator of area source and mobile source NOx and VOC emissions that may contribute to ozone formation. Rapid population or VMT growth (see below) in a county on the urban perimeter signifies increasing integration with the core urban area, and indicates that it may be appropriate to include the

area associa ted with the area source and mobile source emissions as part of the nonattainment area.
Table 4 shows the population, population density, and population growth information for each county in
the area.7

Table 4 . Population and Growth.

County State

Recommended
Nonattainment? 2010

Population 2010

Population Density (1000 pop/sq mi) Absolute

change in population (2000

- 2010) Population

% change (2000

- 2010) Crittenden,
AR Yes 50,902 0.08 (75) <1 % DeSoto, MS No 161,252 0.32 52,584 +48% Fayette, TN No 38,413 0.05 9,313 +32%
Marshall, MS No 37,144 0.05 2,093 +6% Shelby, TN No 927,644 1.18 29,393 +3%
Tate, MS No 28,886 0.07 3,444 +14% Tipton, TN No 61,081 0.13 9,545 +19%
Tunica, MS No 10,778 0.02 1,557 +17%

Areawide: 1,316,100 0.28 107,854 +9% *Counties that EPA intends to designate as nonattainment are shown in bold.

Source s : U.S. Census Bureau population estimates for 20 10 as of August 4, 2011 ( http://factfinder2.census.gov/faces/tableservices/jsf/pages/productview.xhtml?pid=DEC_10_PL_GCTP L2.STO5&prodType=table )

DeSoto County, Mississippi is moderately populated in the northern portion of the county and mostly rural in the remaining portion of the County. DeSoto County contains 12 percent of the CBSA population, but experienced 48 percent growth from 2000

- 2010. Tate, Tunica and Marshall Counties in Mississippi all make up 3 percent or less of the CBSA population and are sparsely populated.

Shelby County, Tennessee is densely populated containing 70 percent of the CBSA population. From
2000

- 2010, the County on ly had 3 percent growth in population. Fayette and Tipton County in Tennessee had moderate growth from 2000

- 2010 but are sparsely populated.

Crittenden County, Arkansas had less than 1 percent population growth from 2000

- 2010 and contains only 4 percent of the CBSA population. The County is mostly rural with little urbanization.

The attachment to this document contains Figure 2, Memphis Area Ozone and Ozone Precursor Monitoring Network, and Figure 3, Population Density Change Percentage Between 2000 and 2010 Census for Memphis Ozone and Ozone Precursor Monitoring Network, which present graphical information on population density and growth for the Memphis area.8

Traffic VMT D ata and C ommuting P atterns

EPA evaluated the total VMT for each county in the Memphis CBSA. In combination with the population/population density data and the location of main transportation arteries (see above), this information helps identify the probable location of non

- point source emissions. A county with high

VMT is ge nerally an integral part of an urban area and indicates the presence of motor vehicle emissions that may contribute to ozone formation that contributes to nonattainment in the area. Rapid population or VMT growth in a county on the urban perimeter signifie s increasing integration with the core urban area, and indicates that the associated area source and mobile source emissions may be appropriate to
include in the nonattainment area. Table 5 shows total 2008 VMT for each county.

Table 5

. Traffic and VMT Data

County State Recommended

Nonattainment? 2008 VMT (million miles) Crittenden, AR Yes 903 DeSoto, MS No 1,629 Fayette, TN No 573
Marshall, MS No 725 Shelby, TN No 8,789
Tate, MS No 376 Tipton, TN No 401
Tunica, MS No 337

Areawide: 13,733 *Counties that EPA intends to designate as nonattainment are shown in bold. * MOBILE model VMTs are those inputs into the NEI version 1.5.

DeSoto County has the second highest VMT in the Memphis CBSA (12% of the total Memphis CBSA). Additionally, DeSo to County has a 48 percent growth in population from 2000

- 2010 with approximately 35 and 34 percent of the County’s NOx and VOC emissions (respectively) deriving from mobile

sources.

Shelby County is the only county in the Memphis CBSA violating the 2008 ozone NAAQS with 2008

- 2010 air quality data and is considered the core CBSA county, with 64 percent of the VMT in the Memphis CBSA; Approximately 35 percent of Shelby County’s NOx emis sions and 34 percent VOC
emissions are from mobile sources.

Crittenden County , has less than 10 percent of the CBSA VMT (third highest in the Memphis CBSA).
From 2000

- 2010, Crittenden County had less than 1 percent population growth with 45 percent and 31 percent of the County’s NOx and VOC emissions(respectively) deriving from mobile sources.

The remaining counties in the Memphis CBSA all have low total population and population growth with little urbanization and low precursor emission contribution s uggesting negligible contribution of population

- based emissions.9 

### Factor 3: Meteorology (weather/transport patterns)

For this factor, EPA analyzed 30

- years of National Weather Service (NWS) wind speed and wind direction data collected at the Memphis Inte rnational Airport (NWS Station 13893) to help determine transport patterns and source contributions

. EPA assessed wind direction and speed for the 2008

- 2010 “ozone season” (March through October) in the Memphis CBSA as well as on days when area ozone
moni tors exceeded the 2008 ozone NAAQS. Additionally, EPA evaluated wind back trajectories (which are an analysis of meteorological patterns) specifically on days when the current ozone design value monitor in Shelby County (Frayser monitor) exceeded the 2008 NAAQS. These analyses were
conducted to better understand the fate and transport of precursor emissions contributing to ozone
formation

.

EPA’s analysis of the NWS data indicate predominate south and south

- southwest component for the Memphis CBSA. How ever, an examination on days when monitors in DeSoto County (Hernando) exceeded the 2008 ozone NAAQS suggested a northerly component. Additionally, on days when monitors in Shelby County exceeded the 2008 NAAQS, the data indicated a southerly wind compone nt.

Figure 2 , Memphis Area Ozone and Ozone Precursor Monitoring Network, and Figure 4 present graphical information on 24

- hour back trajectories for exceedances in 2008

- 2010 at the Frayser monitor, locations of major stationary sources, and locations of ambient monitors with their design values. An examination of the meteorological data indicates that, for the 2008

- 2010 days with ozone concentrations
above 75 ppb at the Memphis 2008

- 2010 Design Value site (Frayser monitor) , the wind back trajectories pri marily go back through Shelby County, TN ( on 10 out of 10 days ) and DeSoto County, MS ( on 7 out of 10 days ), with back trajectories going back through Crittenden County, AR on only 1 out of 10 days. As mentioned in Factor 1, the Shelby County monitor is t he only monitor in the Memphis CBSA with a
2008

- 2010 violation of the 2008 ozone NAAQS.

Since the 2008

- 2010 data is only for three years and has only 10 exceedance days, we evaluated more years to better understand the meteorological transport conditions that exist during ozone exceedances. Normally when we are developing a conceptual model understanding of what yields ozone exceedances in an area we will evaluate 5 to 10 years worth of meteorological data. Therefore we decided to evaluate all days that h ad ozone exceedances at the Design Value monitor (Frayser) for the 2006

- 2010 period. The 2006 and 2007 years had more meteorology that was conducive for ozone formation than the years of 2008, 2009, and 2010. Figure 5 in the attachment to this document i ncludes 72

- hour back trajectories
for 2006

- 2010 ozone exceedances at the Frayser monitor using the National Oceanic and Atmospheric Administration Hybrid Single Particle Lagrangian Integrated Trajectory Model (NOAA HYSPLIT). To
further understand the mete orological transport conditions within the regional area around Memphis, we
also evaluated24

- hour back trajectories for the 2006

- 2010 time

- periods using the NOAA HYSPLIT model. The results of these back trajectories are included in the attachment to this document as Figure 6 with a further zoom in view in Figure 7.

Evaluation of Figures 6 and 7 further support s our previous conclusions based on the 2008

- 2010 back trajectories when the Memphis area Frayser monitor has ozone exceedances. The 2006

- 2010 data further supports that most of the centerlines of the back trajectories passes through Shelby County TN, and many of the back trajectory centerlines pass through DeSoto county in northern Mississippi with smaller percentage passing through Crittenden County , Arkansas.

EPA’s meteorological assessment of the area monitors ozone exceedances and specifically the wind back trajectory analysis at the Frayser monitor indicate that Shelby County is likely an emission10

contributor to exceedances of the 2008 NAAQS at the Frayser m onitor. Furthermore, the assessment also suggests that DeSoto and Crittenden Counties should be considered for potential inclusion in the intended Memphis nonattainment area.



### Factor 4: Geography/topography (mountain ranges or other air basin boundaries)

The geography/topography analysis evaluates the physical features of the land that might affect the airshed and, therefore, the distribution of ozone over the area

.

The Memphis area does not have any geographical or topographical barriers lim iting air pollution transport within its air shed. Therefore, this factor did not play a significant role in this evaluation

.



### Factor 5: Jurisdictional boundaries

Once we identified the general areas we anticipated we would recommend for nonattainment, we then
consider ed existing jurisdictional boundaries for the purposes of providing a clearly defined legal boundary and to help identify the areas appropriate for carrying out the air quality planning and
enforcement functions for nonattainment areas. E xamples of jurisdictional boundaries include existing/prior nonattainment area boundarie s for ozone or other urban

- scale pollutants, county lin es, air
district boundarie s, township boundarie s, area covered by an MPO , state lines, Reservation boundarie s, and urban growth boundaries. Where existing jurisdictional boundaries were not adequate or appropriate to describe the nonattainment area, other clearly defined and permanent landmarks or geographic c oordinates were considered.

The Memphis Area MPO is comprised of two study areas; the Memphis Urban Area MPO and the West Memphis MPO. Both organizations are considered multi

- jurisdictional agencies responsible for the implementation and coordination of urban transportation planning and establishing transp ortation conformity infrastructure within their respective boundaries. The Memphis Urban jurisdiction is comprised of all of Shelby County, Tennessee, the western four miles of Fayette County, Tennessee and the northern twelve miles of DeSoto County. The portion of the Memphis Urban MPO in DeSoto County captures the more urbanized portion of the county that has experience continuous growth as well as the ozone air quality monitor. The West Memphis jurisdiction is comprised of the current and potential fut ure urbanized portion of Crittenden County (including the ozone air quality monitor) with the following legal description:

That area west from the Mississippi River along the southern right of way line of County Road 18 (Miller Road and Caldwell Road) to the western right of way line of County Road 205 (Hinkley Road); then north along said right of way line and continuing north to the intersection of the southern right of way line of the St. Louis

- Southwestern Railroad; then in a southwesterly
direction a long said right of way line to the intersection of eastern right of way line of State Highway 147; then north along said right of way to the intersection of the southern right of way line of State Highway 131; then west along said right of way line to the western right of way line of County Road 51(Eubank Road); then north along said right of way line to U.S. 70; then continuing north along the western right of way line of County Road 25 (Katie Goodhope) to the northern right of way line of County Road 12 ( Buck Lake Road); then east along said northern right of way line to State Road 306; then continuing east along the northern right of way line of State Road 306 to the western right of way line of County Road 165; then north along said right of way line to the northern right of way line of County Road 168; then northeasterly along said11

right of way line to the intersection of the northern right of way of County Road 172; then east along said right of way line to the intersection of the western right of way l ine of County Road 5; then north along said right of way line to the intersection of the northern right of way line of James Mill Road; then east along said northern right of way line to the Mississippi River being the eastern boundary of the study area.

Memphis, TN

- MS

- AR Area has previously established nonattainment boundaries associated with both
the 1

- hour ozone and 1997 8

- hour ozone NAAQS. The Memphis nonattainment boundary for the 1

- hour ozone NAAQS included Shelby County, Tennessee in its entirety . Whereas the Memphis nonattainment boundary for the 1997 8

- hour ozone NAAQS included Crittenden County, Arkansas and Shelby County, Tennessee in their entireties. Tennessee has recommended a different boundary for the 2008 ozone NAAQS for their portion of this A rea. Arkansas recommended the same as the previous boundary for their portion of this A rea. In addition, t here is current infrastructure for meeting the transportation conformity requirements in Shelby County and the urbanized portions of DeSoto County and Crittenden County since both the Memphis Urban area and West Memphis MPO are currently implementing these requirements for the 1997 8

- hour ozone standard.

Even though, DeSoto and Crittenden Counties do not have violating monitors for the 2008 ozone NAAQS based on air quality data from 2008

- 2010, our analysis suggest that both are likely contributing to the violation in Shelby County due to potential population

- based emissions from mobile sources (VMT) and area source, meteorology and population growth.



### Conclusion

Based on the assessment of the factors described above, EPA has preliminarily concluded that the following counties should be included as part of the intended Memphis nonattainment area because they are either violating the 2008 ozone NAAQS o r contributing to a violation in a nearby area: Crittenden County, Arkansas, and Shelby County, Tennessee in their entireties, and the portion of DeSoto County that is included in the Memphis MPO bo undary. Two of these counties (i.e., Crittenden County, Arkansas and Shelby County, Tennessee) are included in the Memphis nonattainment area for the 1997 ozone NAAQS. One of the air quality monitors in Shelby County indicates violation of the 2008 ozone NAAQS based on 2010 DVs, therefore this county is preliminarily included in the nonattainment area. Crittenden County, Arkansas, and DeSoto County, Mississippi are nearby counties that do not have monitors indicating a violation of the standard based on 2010 DVs . However, EPA has preliminarily
concluded that these counties (or portions thereof) contribute to the ozone concentrations in violation of the 2008 ozone NAAQS through population

- based emissions from mobile and area sources (e.g.,
vehicles and ot her small area sourc es) and county VMT

.

Source category emissions data indicate that mobile sources and area sources are the primary contributors to ozone formation in the Memphis CBSA. Thus, population

- based emissions such as total population or population growth, and precursor emission transport would indicate a county with contribution in the Memphis Area.

The population in DeSoto County , Mississippi has grown steadily from 2000

- 2010 (particularly the northern portion) with a 48 percent increas e , even though it only makes up 12 percent of the total population in the CBSA . The C ounty also has the CBSA’s second highest VMT. More than 30 percent of the County’s NOx and VOC emissions are from mobile sources and over 40 percent from area12

sources. I n addition, meteorology suggests that DeSoto County is likely contributing to the violation in Shelby County due to potential southerly transport of mobile and area emissions.

Shelby County, Tennessee dominates the CBSA in terms of urbanization, precursor emission contribution and transport which indicate population

- based emission (mobile and area sources) contribution to its own violating monitor. Although the County population growth was less than 5 percent from 2000

- 2010, it is densely populated with 7 0 percent of the CBSA population and five times DeSoto County’s population. Shelby County makes up over 60 percent of the Area’s NOx and VOC emissions. The County’s has over 30 percent of the County’s NOx and VOC emission coming from mobile sources and p oint sources. Meteorological analysis also indicates that Shelby County is contributing to its own violation as well as other monitors in the Memphis CBSA.

Crittenden County, Arkansas makes up less than 5 percent of the CBSA population with less than a 1 percent population growth from 2000

- 2010. Crittenden County is mostly rural with the least urbanization compared to Shelby and DeSoto Counties. The County contributes less than 10 percent of the CBSA NOx and VOC precursor emissions. However, Crittenden County has over 40 percent of its NOx emission deriving from area sources which is considered a primary contributor to the formation of ozone in the Memphis area. EPA is proposing to include all of Crittenden County in the 2008 ozone Memphis nonattainment area because the county was included in its entirety in the 1997 ozone Memphis nonattainment area and because Arkansas recommended inclusion of the county in its entirety.

The remaining Tennessee (Tipton, Fayette) and Mississippi (Marshal, Tate, and Tuni ca) counties all have low population and urbanization, and precursor emission contribution and transport suggesting negligible contribution to the violating county. With the exception of those counties that comprise the Memphis, TN

- MS

- AR 1997 8

- hour ozone boundary and the portion of DeSoto County, Mississippi
discussed in this TSD for inclusion

, EPA preliminarily concludes that the remainder of the counties in
the C B SA do not contribute to the violations at the monitors in the CBSA and therefore are not be ing considered as part of the nonattainment a rea

.13 

### ATTACHMENTS

Figure 2. Memphis Ozone and Ozone Precursor Monitoring Network, with Population Density.

Figure 3. Population Density Change Percentage Between 2000 and 2010 Census for Memphis Ozone
and Ozone Precursor Monitoring Network.

Figure 4. Overlay of 24

- hour HYSPLIT back trajectories of all 75 ppb exceedances at the Frayser
monitor for the 2008

- 2010 period

.

Figure 5. NOAA HYSPLIT MODEL 72

- Hour Back Trajectory Frayser Exceedances (2006

- 10)

.

Fig ure 6. NOAA HYSPLIT MODEL 24

- Hour Back Trajectory Frayser Exceedances (2006

- 10)

.

Figure 7. NOAA HYSPLIT MODEL 24

- Hour Back Trajectory Frayser Exceedances (2006

- 10)

- Zoom
View

.14

Figure 2. Memphis Ozone and Ozone Precursor Monitoring Network, with Population Density15 Figure 3 . Population Density Change Percenta ge Between 2000 and 2010 Census for Memphis Ozone and Ozone Precursor Monitoring Network16 Figure 4

- Overlay of 24

- hour HYSPLIT back trajectories of all 75 ppb exceedances

at the Frayser monitor for the 2008

- 2010 period.17

Figure 5

. NOAA HYSPLIT MODEL 72

- Hour Back Trajectory Frayser Exceedances (2006

- 10)18

Figure 6

. NOAA HYSPLIT MODEL 24

- Hour Back Trajectory Frayser Exceedan ces (2006

- 10)19 Figure 7

. NOAA HYSPLIT MODEL 24

- Hour Back Trajectory Frayser

Exceedances (2006

- 10)

- Zoom View

# Appendix 2: Mississippi Department of Environmental Quality, Neel-Schaffer, Inc.: On-Road
Mobile-Source Emissions Forecast For Desoto County, Mississippi (2010 to 2020)

Mississippi Department of Environmental Quality February 2012 - 25 -

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# Appendix 3: Idle Reduction Policies in DeSoto County

Mississippi Department of Environmental Quality February 2012 - 26 -

## DeSoto County Anti-Idling Program

Proposal The purpose of the DeSoto County Anti-Idling Pr ogram is to protect public health and the environment in DeSoto County by voluntarily restricting the amount of time that county and municipal non-emergency vehicles, schoo l buses, and commercial vehicles idle. Vehicles that require unavoi dable idling to provide a se rvice or function would be
exempt.

The DeSoto County Anti-Idling Program is a unique collaborative effort to reduce
vehicle emissions while conser ving fuel and lessen vehicle wear and tear. Any current anti-idling policies in the count y or municipalities could be integrated into the DeSoto County Anti-Idling Program. The Mississippi Department of Envir onmental Quality will partner in this program and provide any assi stance needed. Additionally, EPA is actively promoting anti-idling programs and will collaborate with this program.

Background
The United States Environmental Protection Agency sets National Ambient Air Quality Standards (NAAQS) for the protection an d well being of human health and the environment. DeSoto County is currently desi gnated as attainment of all Environmental Protection Agency’s NAAQS. However, effo rts must be made for DeSoto County to continue to enjoy good air quality.

Vehicle emissions have a significant impact on human health and our environment. Vehicle emissions contain nitrogen oxide s and volatile organics compounds which
contribute to ozone formation as well as fine particulates. Vehicles contribute one third of the nitrogen oxides and one fourth of the volatile organics emissions in Mississippi. Reducing emissions from vehicles are important to assure NAA QS continue to be met. Limiting the amount of time in which vehicles id le is one of the tools to lower emissions. A vehicle can use up to one gallon per hour when idling and produce up to 135 grams per hour of nitrogen oxides and 6.5 grams per hour of volatile organics.

An anti-idling program would provide an easy, cost-effective policy to assist in maintaining the air quality of DeSoto County and to reduce the exposure of people to the potential health impacts of ve hicle emissions. It would also reduce fuel consumption and
vehicle wear and tear which would crea te a cost savings for the county and municipalities. EPA is activel y promoting anti- idling programs.

Goal The goal is for all county and municipal govern ments, school bus fleets, and commercial fleets participating in the DeSoto County Anti-Idling Program to voluntarily adopt a policy restricting non-emergency vehicles from unnecessary idling. Vehicles that require unavoidable idling to provide a servi ce or function would be exempt.

Mississippi Department of Environmental Quality February 2012 - 27 -

# DeSoto County Anti-Idling Policy

1.0 Purpose:

DeSoto County, Mississippi is com mitted to reducing unnecessary county and municipal vehicle/equipment id ling as a means of reducing air pollution and fuel expense.

The purpose of this policy is to es tablish guidelines for unnecessary idling of county and municipal vehicles a nd equipment. Limiting idling times reduces air pollution and c ontributes to healthier work environments and
the efficient use of count y/municipality resources.

2.0 Scope:

This policy applies to all staff opera ting vehicles and equipment owned or leased by DeSoto County and the municipalities within the county.

3.0 Definitions:

3.1 Idling:

the operation of a vehicle or equipment while they are not in motion and not being used to operate auxiliary equipment that is essential to the operation of the vehicle or equipment.

3.2 Fuels:

includes all vehicles or equipment th at run on fossil fuels which include gasoline, diesel, propane, hydrogen, and natural gas.

3.3 Vehicles:

any self-propelled mechanized equipm ent that is used for transporting persons or commodities on public roads utilizing fossil fuels.
4.0 Procedures:

4.1 Manufacturer’s Guidelines (Recommendations):

Always follow the manufacturer’s guidelines and recommendations for idling unless otherwise specified.

4.2 Initial Warm-Up:

Idle times up to three (3) minutes are allowed for vehicles during their initial shift warm up and at subseque nt times when the vehicle is being restarted after a prolonged period of shut down that results in vehicle conditions similar to those pr ior to initial shift warm up.

4.3 Operation of Equipment in the Field:

Mississippi Department of Environmental Quality February 2012 - 28 -4.3.1 Gasoline and Alternative Fuel Vehicles

No operator shall idle the engine of a gasoline-fueled vehicle in excess of one (1) minute if the ve hicle is stopped for a foreseeable period of time. Operators making multiple or frequent stops that require their vehicle to be statio nary for time periods of several minutes may idle up to three (3) minutes in such circumstances.

4.3.2 Diesel-Fueled Vehicles/Equipment

No operator shall idle the engine of a diesel-fueled vehicle in excess of three (3) minutes if the vehicle is stopped for a foreseeable period of time. Di esel-fueled vehicles/equipment should only be turned off after enough time has passed to allow the proper circulation and cooling of th e engine oil, coolant, and turbo chargers, not to exceed three (3) minutes.

4.3.3 When engines must be left r unning for any reason, the operator
must remain with the vehicle.
5.0 Exceptions:

This policy does not apply to the following vehicles, equipment, or situations. Operators must use their own di scretion in certain situations.

5.1 Emergency vehicles and equipmen t are exempted while engaged in operational activities such as fire, police, or ambulance services.

5.2 Vehicles assisting in an emergency activity are exempt.

5.3 Where engine power is necessary for an associated power need such as, but not limited to, electrical power, compressed air, and various power
take-off devices such as auxiliary hydraulics.

5.4 Vehicles may idle for the purpose of defogging, defrosting, or deicing windows. Idling must end when fog, fr ost, or ice conditions have been eliminated. When window ice or frost conditions are present, attempts to remove snow, ice, or frost from the windows with a scraper must be attempted before idling.

5.5 This policy does not apply to vehi cles being serviced or inspected.

5.6 Where safety may be compromised by shutting down the engine, vehicles/equipment may idle at the discretion of the operator.

Mississippi Department of Environmental Quality February 2012 - 29 -

## CITY OF OLIVE BRANCH Engine and Equipment Idling Policy January 23, 2006

Idling of fleet vehicles and equipm ent contributes to poor air quality, consumes fuel unnecessarily, and is harmful to engines. It is the responsibility of all city personnel to operate fleet equipment in an environmentally and economically sound manner.

City fleet vehicles and equipment shal l not be parked with their engine operating for more than five minute s unless it is essential for performance of work. When engine s must be left operating, for any reason other than public safety co ncerns, the operator must remain with the vehicle/equipment. Violators are subject to disciplinary action.

Mississippi Department of Environmental Quality February 2012 - 30 -

# The City of Southaven Anti-Idling Policy

October 16, 2007

1.0 Purpose:

The City of Southaven, Mississippi is committed to reducing unnecessary municipal vehicle/equipment idling as a means of reducing air pollution and fuel

expense.

The purpose of this policy is to establ ish guidelines for unne cessary idling of county and municipal vehicles and equipm ent. Limiting idling times reduces air pollution and contributes to healthier work environments and the efficient use of county/municipality resources.

2.0 Scope:

This policy applies to all staff operating vehicles and equipment owned or leased by the City of Southaven only.

3.0 Definitions:

3.1 Idling:

the operation of a vehicle or equipment wh ile they are not in motion and not being used to operate auxiliary equipment that is essential to the ope ration of the vehicle or equipment.

3.2 Fuels:

includes all vehicles or e quipment that run on fossil fuels which include gasoline, diesel, propane, hydrogen, and natural gas.

3.3 Vehicles:

any self-propelled mechanized equipment th at is used for transporting persons or commodities on public roads ut ilizing fossil fuels.

Mississippi Department of Environmental Quality February 2012 - 31 -

# Appendix 4: DeSoto County Report Card
and Table of Air Outreach Events

Mississippi Department of Environmental Quality February 2012 - 32 -

## DeSoto County Report Card

EPA Region 4 staff and MDEQ – Air Divisi on Staff held an Air Quality Workshop in Hernando, MS on June 20, 2007. The purpose of the meeting was to provide information and tools to DeSoto County ci tizens and officials to lower emissions across the county. Local citizens, elected officials, and MDEQ went above and beyond the recommendations given at the workshop. Cu rrently, there is momentum in DeSoto County to continue steps to reduce Ozone precursor emission s. By continuing to focus resources toward outreach and ozone action pl anning, MDEQ can continue the efforts to
reduce emissions.

DeSoto County Air Quality Workshop Meeting Date: June 20, 2007 Attendees: EPA – Region 4, MDEQ, DeSoto Count y Officials, Local Elected Officials,
and Public

EPA Recommendations MDEQ / DeSoto County Responses

Ozone Action Program DeSoto County Ozone Action Group

• The DeSoto Planning Commission began the Ozone Action Group to engage pub lic and private groups in finding emission reductions and providing public
outreach.

Outreach DeSoto County Ozone Action Group

• The DeSoto Planning Commission began the Ozone Action Group to engage pub lic and private groups in finding emission reductions and providing public outreach. This group meets regularly and brainstorms creative approaches and outreach ideas to reduce
emissions.

• MDEQ, DeSoto County Ozone Action Group, and the DeSoto County Planning Commission have engaged in numerous outreach events throughout the county. A puppet show was also developed as an additional outreach tool for schools and public outreach.

Idle Reduction DeSoto County Anti-Idling Program

• DeSoto County and all muni cipalities within the county adopted idle reduction policies and procedures for all county and municipal fleets.

Diesel Emission Reduction Projects MS School Bus Retrofit Project

• MDEQ retrofitted 93 DeSoto County school buses with diesel oxidation catalysts. In the surrounding counties, MDEQ retrofitted an additional 57 buses with DOCs.

Additional Projects and Efforts:

• All open burning is banned on Oz one Action Days. Open Burning is banned on all days
in Hernando.

• Texas Gas Transmission voluntarily added permit conditions to reduce the load on several compressor engines to 90%. This reduction creates a 50% NOx reduction from those engines.
Page 1 of 2

Mississippi Department of Environmental Quality February 2012 - 33 -• MDEQ and DeSoto County have had additional outreach to companies to develop Ozone
Action Plans.

• DeSoto County has adopted a Greenways Mast er to create and enhance a comprehensive network of greenways, conservation trails , and natural areas. The county employs a County Greenways Coordinator to grow the gr eenways network within DeSoto County to preserve natural amenities, waterways, and environmental systems. The greenway system will connect our citizens with a variety of outdoor recreational opportunities and encourage the use of alternative modes of tr ansportation including bicycle, pedestrian, canoe and kayak, and horseback to improve and maintain our air quality and the health of
our citizens.

• In 2011, DeSoto County received Two Globe certification from the Green Building Initiative as a result of upgrades to existing County-owned buildings to meet energy efficiency standards and reduce. Green Glob es certified/rated buildings, like the DeSoto County Administration building, are committed to using less energy, conserving water resources, emitting fewer pollutants, and pr oviding a healthier indoor environment for
occupants.

• There are currently nine MDEQ Diesel Emission Reduction Projects reflecting 35 pieces of diesel equipment in and around DeSoto County. Private companies have spent over $106,000 of their own money on these projects. MDEQ received 28 application in January 2012 for the 2011/2012 state grant

• MDOT has spent over $1 million in Safe Routes to School, sidewalks and bike path improvements in DeSoto County and conducted an I-69 Corridor Alternatives Analysis to study preferred mass transit options for DeSoto County.

Page 2 of 2

Mississippi Department of Environmental Quality February 2012 - 34 -Mississippi Department of Environmental Quality February 2012 - 35 - 

## Table of Air Outreach Events

Date Event Estimated
Attendance April 2009 Safe & Healthy Schools Summit 150 April 21, 2009 Great Green Expo-Keesler AFB 400 April 24, 2009 DeSoto County Ou tdoor Day-Olive Branch 250 May 2009 MS Asthma Coalition 85

June 17, 2009 MS Association of Supervisors-Gulf Cost
Convention Center-Biloxi 1,700

June 23, 2009 Agri-Science Summer Campers-Career Development Center, Jackson, MS 20

July 15, 2009 MS Municipal League-Gulf Coast Convention
Center-Biloxi 1,700

September 11, 2009 Mississippi Asthma Summit 125 September 23, 2009 Arkabutla Day - DeSoto County 700

September 25 to October 4, 2009 Mid South State Fair - DeSoto County 1,000

October 2, 2009 Renewable Energy Day - Agriculture Museum 400

November 2009 MDA Greening Local Communities Statewide (4 events) 400

January 30, 2010 Moss Point Going Green Rally 200

April 17, 2010 Waterfest - Reservoir 300 April 22, 2010 Earth Day at th e Navy Battalion - Gulfport 500 April 24, 2010 Health Fair - Clinton 350 May 2010 MS Asthma Coalition 75 May 1, 2010 Moss Point Outreach Event 200 June 23, 2010 Jackson Career Development Center Agriscience 20 September 2010 Mississippi Asthma Summit 125 September 22, 2010 Arkabutla Day - DeSoto County 950

October 15, 2010 Odyssey Day - Biloxi 100 October 16, 2010 Romp on the River - Tunica 5000 March 19, 2011 North Mississippi Green Festival 500 April 16, 2011 Waterfest - Reservoir 300 April 30, 2011 Earth Day - Hernando 625 May 2011 MS Asthma Coalition 75 May 2011 MS Department of Health Presentation 25 August 2011 Center for Advance Vehicle Systems 100 September 14, 2011 Arkabutla Day - DeSoto County 950

October 2011 State Port Leadership Group 30 October, 2011 DeSoto County Board of Supervisors 25 October, 7 2011 Renewable Energy Day - Agricultural Museum 400

November 2011 State Port Leadership Group 30