Air pollution is falling across the county, leaders say, leading to financial issues for an air permitting program.
Shelby County Health Department officials said large industrial facilities are emitting lesser amounts of pollutants, causing a decrease in revenue for its Title V program. While the agency said this was “great news,” the program relies on permitting fees that are funded from emissions.
“By emissions going down, so [is] our revenue,” said Kasia Smith-Alexander, deputy director for environmental health and sustainability at the Shelby County Health Department.
During a Wednesday meeting of the Shelby County Commission’s Hospitals and Health committee, Smith-Alexander said the health department projected a revenue of $900,000 in 2025, but received $822,783.
In 2026, the department expected $805,000 and received $810,000. Officials said they operate on a budget of $900,000 and are $90,000 short to operate the Title V permitting program.
The department asked the commission to raise the fees associated with the program to “correct the shortfall.” These fees go towards employee salaries and fringe benefits.
“[TitleV] does protect small businesses in creating these fees,” said Smith-Alexander. “Most of the fee impact will be with the major sources โ that means those industrial areas that have the largest [amounts of] pollutants will pay the most for their permit, as they should.”
Small businesses such as gas stations and laundry mats would not be impacted by a fee increase.
“We see [these] fees as equitable,” said Bruce Randolph, interim director of the Shelby County Health Department. “If you’re a major source polluter, you should pay more. You should pay your fair share.”
As the county oversees air pollution, it must make sure certain companies comply with the standards set under a Title V Operating Permit. The permit encompasses air pollution requirements for major industrial sources. The regulated sources fund the program rather than taxpayers.
Smith-Alexander said the fees help keep programs sustainable and functional for residents.
“Major sources are facilities that emit or have the potential to emit 100 tons of pollutants per year,” said Smith-Alexander .
Compliance with the program helps the health department protect air quality, as the major sources must submit data to the agency. Smith-Alexander said the program has contributed to lower emissions across Shelby County. If funding falls, it is up to the health department to supplement the difference. The Environmental Protection Agency (EPA) can step in if the county is not compliant.
Smith-Alexander said the permits issued under Title V serve as legally-binding obligations to protect surrounding communities. It also makes sure those facilities yield to National Ambient Air Quality Standards, which outline six common air pollutants, including carbon monoxide, lead, ground-level ozone, nitrogen dioxide, particulate matter, and sulfur dioxide.
“The Title V program has to be accountable in everything that it does,” said Smith-Alexander. “When violations occur, we can require corrective actions that reduce environmental risks.”
Smith-Alexander also detailed the top five sources of pollutants in Shelby County: Three are located in the 38109 ZIP code. The other two are located in 38127.
The sources are Nucor Steel, Valero, Draslovka, Tennessee Valley Authority (TVA)’s Allen Combined Cycle Plant, and Mitsubishi Chemical of America. SpacexAI was ranked at number-28.
Smith-Alexander said the current federal administration is “rolling back” on pollutant limits and what’s allowed in communities. The department’s has to follow the law and emission standards and requirements are federally approved.
Smith-Alexander said its proposal was presented to and approved by the Memphis and Shelby County Air Pollution Control Board. The county commission voted in favor of the proposed change and there will be two more readings of the ordinance.

