July
19,
2004
Mr.
J.
I.
Palmer,
Jr.
Regional
Administrator
U.
S.
EPA,
Region
IV
Sam
Nunn
Atlanta
Federal
Center
61
Forsyth
Street,
S.
W.
Atlanta,
GA
30303
Mr.
Richard
E.
Greene
Regional
Administrator
U.
S.
EPA,
Region
VI
1445
Ross
Avenue,
Suite
1200
Dallas,
TX
75202
RE:
Supplement
to
July
14,
2004
Petition
for
Downward
Reclassification
for
Memphis
Ozone
Non­
Attainment
Area
Dear
Mr.
Palmer
and
Mr.
Greene:

In
our
July
14,
2004
reclassification
petition
for
Shelby
County,
Tennessee
and
Crittenden
County,
Arkansas,
the
State
of
Tennessee
committed
to
providing
a
supplement
to
this
petition
to
detail
action
taken
by
the
Tennessee
Air
Board
at
its
meeting
July
14­
15,
2004.
As
specified
in
part
III
of
the
petition,
the
following
measures
were
taken
before
the
Board:

RACT
Rule
for
NOx;

Expanded
applicability
of
Stage
I
gasoline
vapor
emission
control
requirements;

Vehicle
Emissions
Inspections;

Anti­
tampering
measures;

Reduction
of
visible
emissions
of
motor
vehicles
statewide;
and
Reduction
of
unnecessary
idling
of
motor
vehicles
statewide
(
Anti­
Idling).

The
RACT
rule
for
NOx
that
was
presented
to
the
Board
was
significantly
different
from
that
which
was
originally
proposed
to
the
public,
primarily
due
to
comments
received
during
the
public
comment
period.
For
this
reason,
the
Board
ruled
that
the
revised
rule
needed
to
again
be
made
available
for
public
comment
before
further
action
was
taken.
The
Board
approved
the
expansion
of
Stage
I
gasoline
vapor
emission
control
requirements
to
twenty­
three
additional
counties,
including
Fayette,
Haywood,
and
Tipton
Counties
in
the
Memphis
area
(
Shelby
County
is
already
subject
to
this
requirement).
This
will
result
in
estimated
statewide
emissions
reductions
of
5,844
tons
of
volatile
organic
compounds
per
year.
A
copy
of
the
approved
rule
is
included
as
Attachment
1.
The
Board
expanded
the
vehicle
emission
inspection
program
to
include
Hamilton
County
(
Chattanooga).
They
also
increased
the
minimum
gross
vehicle
weight
rate
subject
to
inspection
from
8,500
pounds
to
10,500
pounds,
and
removed
the
exemption
for
lightduty
diesel
powered
motor
vehicles.
The
City
of
Memphis
will
voluntarily
upgrade
the
existing
inspection
program
OBD­
II
testing.
A
copy
of
the
approved
rule
is
included
as
Attachment
2.
The
Board
approved
the
motor
vehicle
anti­
tampering
provisions
with
some
modifications
to
the
record­
keeping
requirements
from
the
originally
proposed
rule.
A
copy
of
the
approved
rule
is
included
as
Attachment
3.
The
Board
elected
not
to
take
action
on
the
proposed
smoking
vehicle
rule.
The
Board
elected
not
to
take
action
on
the
proposed
vehicle
anti­
idling
rule.
Tennessee
appreciates
your
consideration
of
this
petition.
If
you
have
any
questions
about
this
information,
please
contact
Barry
Stephens,
our
Air
Pollution
Control
Director,
at
(
615)
532­
0525,
or
Betsy
Child,
Commissioner
of
the
Department
of
Environment
and
Conservation,
at
(
615)
532­
0106.

Sincerely,

Betsy
L.
Child
BLC:
LJH:
lg
Attachments
cc:
Governor
Phil
Bredesen,
State
of
Tennessee
Governor
Mike
Huckabee
Mayor
A.
C.
Wharton,
Shelby
County
Milton
Holt,
Crittenden
County
Judge
Barry
R.
Stephens,
Director
of
the
Division
of
Air
Pollution
Control
Marcus
Devine,
ADEQ
Jeff
Holmstead,
EPA
Headquarters
