### Memorandum

To: Interagency Consultation Members

From: Kenneth Monroe, P.E., PTOE

Date: November 1, 2013

Subject: SIP Revision Budget Years and Memphis MPO Conformity

An Interagency Consultation group (IAC) meeting was conducted on October 31, 2013 to discuss the revisions to the Memphis-Shelby County portion of the Tennessee State Implementation Plan (SIP) by the Shelby County Health Department (SCHD). The conference call was attended by the following:

 Allison Fluitt, Kimley-Horn and Associates, Inc.

 Carter Gray, Shelby County Government

 Chris Boyd, Shelby County Health Department

 Corbin Davis, Federal Highway Administration

 Denis Fritchie, Shelby County Health Department

 Dianna Smith, U.S. Environmental Protection Agency

 Elton Holloway, Mississippi Department of Transportation

 Jim Holt, Shelby County Health Department

 John Lancaster, Memphis Area Transit Authority

 Keith Head, Mississippi Department of Environmental Quality

 Kenneth Monroe, Kimley-Horn and Associates, Inc.

 Marc Corrigan, Tennessee Department of Environment and Conservation

 Pragati Srivastava, Memphis Metropolitan Planning Organization

 Randal Tatum, City of Memphis

 Theresa Claxton, Federal Highway Administration

 William Kenneth Dean, U.S. Environmental Protection Agency

The need for the revision is, in part, the result of the termination of the City of Memphis’ Inspection and Maintenance (I/M) Program as a Control Measure. The revision will address Ozone and it precursors; Volatile Organic Compound (VOC) and Oxides of Nitrogen (NO x ). Carbon Monoxide is not being addressed as part of the SIP revision. The current Motor Vehi cle Emission Budget (MVEB) years for the precursors of Ozone are 2006, 2009, 2017, and 2021.

When SCHD originally sought feedback from the Memphis MPO on the analysis years to be established in the revised SIP, two alternative analysis year scenarios were discussed as described below:  125 North Main Street Suite 450 Memphis, Tennessee 38103

 TEL 901 576 7190 FAX 901 576 7272Interagency Consultation Group, November 1, 2013, Pg. 2

 Alternative 1 – 2006, 2009, 2017, and 2021

 Alternative 2 – 2006, 2015, 2017, and 2021

The base attainment year of 2006 from the SIP would need to be revisited due to a change in the air quality modeling platform. The previous SIP was developed using EPA’s MOBILE software that ha s since been replaced with MOVES. The last year of the Ozone maintenance plan, which is 2021, would need to be reevaluated due to the change in the air quality model platform as well as the referenced change in emission control measures.

The IAC group then discussed the need for developing motor vehicle emissions budgets (MVEBs) for years prior to 2021. It was stated that, unlike the conformity demonstration process, there is no minimum requirement for developing MVEBs that span 10 years or less in the SIP. So, a gap in years between MVEBs could be greater than 10 years in a SIP.

The potential impacts to the planning pr ocesses of the Memphis MPO were then discussed. The current regional Long Range Transportation Plan (LRTP) and Conformity Demonstration were approved in March, 2012. The next LRTP and full conformity demonstration are due in March, 2016. The first interim year described in the next LRTP will likely be 2020 or beyond. With future year LRTP plan years beyond 2020, MVEB years earlier than 2021 will not provide useful information that will help guide transportation planning decisions presented in these documents. Fewer MVEB years prior to the last year of the Ozone maintenance plan year of 2021 will also reduce the workload of the MPO in developing conformity documents.

For these reasons, it was agreed by those on the call that the SIP would consist of a base analysis year of 2006 and a final year of 2021 . MVEB’s will be established for 2006 and 2021.

The schedule for developing the SIP was then discussed. Revision of the SIP with new MVEBs is a trigger for conformity demonstration by the Memphis MPO, with a demonstration of conformity due 24 months from the approval by EPA of the revised SIP. SCHD will prepare and distribute the revised SIP to State and Federal review agencies within 90 days. It is anticipated that the entire process will take one year for full approval.