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Federal Register / Vol. 86, No. 156 / Tuesday, August 17, 2021 / Rules and Regulations
recent vehicle emissions standards and be operated with gasoline that complies with the most recent Federal requirements.
Comment A10: A commenter states that In east Tennessee there is no air emissions testing and the air quality is very poor. The transportation sector is a major contributor of poor air quality, therefore all vehicles must meet the original manufacturers specifications and all aftermarket modifications to vehicle exhaust and emissions equipment must be made illegal.
Response A10: EPA does not agree with the commenter that air quality is very poor in east Tennessee. As mentioned in Response A1, all areas in Tennessee are in compliance with the NAAQS with the exception of a small portion of Sullivan County in the eastern part of the State that is designated as nonattainment for the SO2
NAAQS. Also, EPA does not understand what the commenter means by . . . no air emissions testing. As noted in Response A4, this action does not remove the ambient air quality requirements that Tennessee is subject to statewide. To the extent that the commenter is referring to vehicle emissions testing, EPA notes that, with respect to SIPs, each State is given wide discretion in formulating its plan, so long as the revision is consistent with the CAA, including section 110l. See Union Elec. Co. v. EPA, 427 U.S. 246, 250 1976; see also Alabama Envtl.
Council v. EPA, 711 F.3d 1277, 1280
11th Cir. 2013, Sierra Club v. EPA, 939
F.3d 649, 673 5th Cir. 2019, and Alaska Dept of Envtl. Conservation v.
EPA, 540 U.S. 461, 470 2004.
EPA agrees with the commenter that the transportation sector is an important sector for maintaining air quality and, as discussed in Response A4, EPA has taken steps to control emissions from the transportation sector, such as the Federal vehicle and fuel standards that will continue to provide benefits without the implementation of the I/M
program in Tennessee. EPA also notes that the commenters statements related to vehicle exhaust and emissions equipment are not impacted by or within the scope of this rulemaking.
Comment A11: One commenter suggests that the topography of Chattanooga would exacerbate poor air quality if EPA removed the local I/M
program. Specifically, the Commenter explains that since Chattanooga is surrounded by mountains, the city suffers from a well-known inversion effect that traps pollutants in it during certain times of the year. Another commenter explains that Nashville sits in a depression called the Nashville or
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Central Basin, which tends to cause air to stagnate over the entire area. Both commenters argue that these unique geographical features would exacerbate poor air quality if EPA removed the I/M program.
Response A11: EPA disagrees that Hamilton County and the Middle Tennessee Area have poor air quality, as both areas currently meet all of the NAAQS, which is explained in more detail in Response A1. EPA does not have evidence to indicate that the removal of the I/M program from either Hamilton County or the Middle Tennessee Area will exacerbate poor air quality because of the unique geographical features in each area.
While it is important to identify and mitigate vehicles that are not properly functioning and as a result may increase emissions, most vehicles are not producing increased emissions. Since the 2000s, with EPAs promulgation of Federal requirements for engine and fuel standards, passenger vehicles are cleaner. See Response A4 for more information on the engine and fuel standards.
Comment A12: A commenter asserts that COVID19 pandemic has had an anomalous impact on air quality improvements in 2020, and indicates that removal of the Tennessee I/M
program should not be considered until after newer trends in air quality are available. The commenter cites to three documents to assert that lockdown events have reduced the populationweighted concentration of nitrogen dioxide NO2 and particulate matter levels by about 60% and 31% across multiple countries, with mixed effects on ozone.
Response A12: EPA disagrees with the commenters implication that newer trends in air quality would be necessary to make the determination on whether removal of the I/M program would interfere with attainment or maintenance of the NAAQS in any area as a result of removal of the program from the Tennessee SIP. As detailed in EPAs April 2021 SNPRM and briefly described in Section III of this final rule, EPA used an emissions inventory comparison approach in which total emissions in 2014 were compared to total projected emissions in 2022. EPAs use of projected emissions in 2022 did not consider any potential reduction of emissions or improvements in air quality that might be sustained through changes in behavior that citizens in Hamilton County and the Middle Tennessee Area might have made as a result of the COVID19 pandemic.
Additionally, the commenter did not provide any information or analysis
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indicating that consideration of 2020 air quality improvements would impact the non-interference demonstration.
In EPAs April 2021 SNPRM, for the Middle Tennessee Area, EPA explained that the difference in NOX emissions in 2022, with and without the I/M
program, is 479 tons per year tpy for NOX and 594 tpy for VOC. However, the total NOX emissions in 2022 without the I/M program are 22,420 tpy less than the total NOX emissions in 2014, and total VOC emissions in 2022 without the I/M
program are 6,272 tpy less than the total VOC emissions in 2014. For CO, the difference in emissions in 2022, with and without the I/M program, is 10,368
tpy. However, the total CO emissions without the I/M program are 56,466 tpy less than the total CO emissions in 2014.
Even without the I/M program in 2022, emissions of NOX, VOC, and CO are projected to decrease by 47.1 percent, 15.1 percent, and 23.9 percent, respectively, from 2014 levels.
For Hamilton County, EPA explained in the April 20201 SNPRM that the difference in emissions in 2022, with and without the I/M program, is 100 tpy for NOX and 146 tpy for VOC. However, the total NOX emissions in 2022 without the I/M program are 3,505 tpy less than the total NOX emissions in 2014, and the total VOC emissions in 2022 without the I/M program are 858 tpy less than the total VOC emissions in 2014. For CO, the difference in emissions in 2022
with and without the I/M program is 2,979 tpy. However, the total CO
emissions without the I/M program are 10,061 tpy less than the total CO
emissions in 2014. Even without the I/M program in 2022, emissions of NOX, VOC, and CO are expected to decrease by 27.0 percent, 8.1 percent and 18.7
percent, respectively from 2014 levels.
In summary, because 2022 total emissions without the I/M program are projected to be less than the total 2014
emissions, EPA is concluding that removal of the I/M program in Hamilton County and the Middle Tennessee Area will not interfere with attainment or maintenance of the NAAQS, or any other applicable CAA requirements.20
As mentioned above and in EPAs April 2021 SNPRM, while EPA considers NOX, VOCs, ammonia, and SO2 as precursors for PM, PM formation in Tennessee is dominated by emissions of SO2, reacting in the atmosphere to form sulfates, and not by emissions of NOX, VOCs, or ammonia. However, NOX and VOC increases are considered through the analysis for ozone described in great 20 Meteorology is not used directly for the emissions inventory approach that EPA used as the basis of its technical analysis.

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