905278009
Do not WEED. This document
should be retained in the EPA
Region 5 Library Collection.
Evaluation Of Motor Vehicle Emissions Inspection And Maintenance
Programs In Wisconsin — Phase 3
Final Report
Contract No. 68-02-2607
Work Assignment No. 20
EPA-905/2-78-004
November 1978
GCA/TECHNOLOGY DIVISION
BEDFORD, MASSACHUSETTS 01730
-------
GCA-TR-78-53-G
Prepared for
U.S. ENVIRONMENTAL PROTECTION AGENCY
Region V
Chicago, Illinois
Contract No. 68-02-2607
Work Assignment No. 20
EPA Project Officer
Carlton Nash
EVALUATION OF MOTOR VEHICLE
EMISSIONS INSPECTION AND MAINTENANCE
PROGRAMS IN WISCONSIN
PHASE 3
Final Report
November 1978
by
Theodore P. Midurski
Lee A. Coda
Robert 0. Phillips
Nancy Roy
Frederick Sellars
Donna Vlasak
GCA CORPORATION
GCA/TECHNOLOGY DIVISION
Bedford, Massachusetts
U.S. £nvto»iiT»nta? Protection Agency
Region 5, Library (f>i-
-------
DISCLAIMER
This Final Report was furnished to the U.S. Environmental Protection
Agency by GCA Corporation, GCA/Technology Division, Bedford, Massachusetts
01730, in fulfillment of Contract No. 68-02-2607, Work Assignment No. 20. The
opinions, findings, and conclusions expressed are those of the authors and not
necessarily those of the Environmental Protection Agency or of cooperating
agencies. Mention of company or product names is not to be considered as an
endorsement by the Environmental Protection Agency.
-------
ABSTRACT
Recent data for the State of Wisconsin indicates that the National Ambient
Air Quality Standards for CO and Ox will not be attained in all areas of the
state by 1982, even if all reasonably available control technologies are applied.
In view of this, it is likely that the state will request from U.S. EPA an ex-
tension of the compliance data beyond, 1982. In order for this request to be
considered, the state must, among other things, have adopted a firm schedule for
implementing a motor vehicle inspection and maintenance (I/M) program in the
highly urbanized nonattainment areas. In this connection, the State of Wiscon-
sin is currently planning for the implementation of an I/M program. As part of
this effort, detailed analyses have been performed of the costs, benefits, per-
sonnel requirements, direct and indirect impacts, and scheduling requirements
associated with the particular program option being considered. This document
reports these analyses.
111
-------
CONTENTS
Abstract ................................. ii;i;
List of Figures .............................
List of Tables ..............................
Acknowledgments .............................
1. Introduction .......................... 1
Background and Objective ................. 1
Basis and Organization of this Report ........... 3
References ........................ 5
2. Program Option ......................... 6
Option Definition ..................... 6
Emissions Inspection Scenario ............... 8
3. I/M Program Benefits and Impacts ................ 12
Introduction ....................... 12
Emissions Reductions ................... 12
References ........................ 31
4. Network and Personnel Requirements ............... 32
I/M Network ........................ 32
Personnel Requirements .................. 35
5. Adjunctive Programs ...................... 43
Introduction ....................... 43
Consumer Protection .................... 44
Warranty Protection .................... 49
Public Convenience .................... 52
Public Relations Program ................. 53
Quality Assurance ..................... 55
Mechanics Training .................... 57
Program Enforcement Considerations ............ 60
6. Legislative Considerations ................... 63
Introduction ....................... 63
Approach and Methodology ................. 63
Legislative Issues .................... 63
7. Cost Analysis ......................... 89
Methodology ........................ 89
Fee Computation ...................... 116
8. Implementation Planning .................... 125
Introduction ....................... 125
Immediate Issues ..................... 126
9. Summary and Conclusions ..................... 139
Background of This Study ................. 141
Option Definition ..................... 145
Emissions Inspection Scenario ............... 146
v
-------
CONTENTS (continued)
I/M Program Network 147
Program Administration and Personnel Requirements 149
I/M Program Benefits 149
I/M Program Costs 158
Adjunctive Programs 158
Conclusions 162
References 165
Appendices
A. General Methodology 166
General Methodology 166
Option Costs 166
Fee Computation 180
Emissions 188
B. Detailed Description of Methodology for Calculating Emission
Inventories 190
References 197
C. Estimated Fuel Savings in 1987 Resulting From I/M 198
Fuel Savings 198
Summary Figures 207
D. Introduction 211
Problems Associated With Winter Emissions Testing 211
Mitigating Measures 213
References 214
VI
-------
FIGURES
No. Page
1 Motor vehicle inspection and registration flow chart 11
2 Daily CO emissions by year for LDV's and LDT's, and all vehicles
with and without I/M in nine Wisconsin counties - 1982 through
1987 18
3 Daily HC emissions by year for LDV's and LDT's, and all vehicles,
with and without I/M in nine Wisconsin counties - 1982 through
1987 19
4 Daily CO emissions by year for LDV's and LDT's, and all vehicles with
and without I/M in the Seven County Greater Milwaukee area -
1982 through 1987 20
5 Daily HC emissions by year for LDV's and LDT's, and all vehicles with
and without I/M in the Seven County Greater Milwaukee area - 1982
through 1987 21
6 Effect of varying the stringency level on CO emissions for LDV's
and LDT's, and all vehicles for 1983 and 1987 24
7 Effect of varying the stringency level on HC emissions for LDV's
and LDT's, and all vehicles for 1983 and 1987 25
8 Suggested administrative structure for the state-run option 39
9 Suggested administrative structure for the contractor-run option ... 40
10 Conceptual floor plan for a combined safety, noise, and loaded-mode
emission inspection facility 92
11 Suggested administrative structure for the state-run option 151
12 Suggested administrative structure for the contractor-run option . . . 152
13 Daily CO emissions by year for LDV's and LDT's, and all vehicles
with and without I/M - 1982 through 1987 155
14 Daily HC emissions by year for LDV's and LDT's, and all vehicles with
and without I/M - 1982 through 1987 156
vii
-------
TABLES
No.
1 Projected Carbon Monoxide Emissions (kg/day) and Percent Reductions
Achievable for LDV's and LDT's Only 14
2 Projected Hydrocarbon Emissions (kg/day) and Percent Reductions
Achievable for LDV's and LDT's Only 15
3 Projected Carbon Monoxide Emissions (kg/day) and Percent Reductions
Achievable for all Vehicles 16
4 Projected Hydrocarbon Emissions (kg/day) and Percent Reductions
Achievable for all Vehicles 17
5 Effect of Varying the Stringency Factor on CO and HC Emissions
Reduction Potential 23
6 Annual Growth Rate, Inspectable Vehicle Population, 1973 to 1978 . . 33
7 1987 Inspectable Vehicle Population, Using Two Different
Projection Methods 33
8 Inspections Required, 1987 34
9 Inspection Lanes Required, 1987 35
10 Inspection Network 36
lOa Inspections Required 1982 to 1987 36
11 Operating Personnel Requirements 38
12 Administrative Personnel Requirements for State-Run and Contractor-
Run Options 42
13 I/M Repair Costs 48
14 General Specifications of a Typical I/M Centralized Facility
Emission Analyzer 58
15 Sample Cutpoints Defined as a Function of Model Year For the Idle
Mode Test 67
viii
-------
TABLES (continued)
No.
16 Outline of Program Cost Categories and Elements 90
17 Floor Area Requirements for Various Facility Configurations -
Emissions Testing With Capability to Expand to Include Safety
and Noise Testing 93
18 Inspection Network Requirements 93
19 Building Cost Estimates . . 94
20 Estimated Land Values for Commercially-Zoned Land in Nine Selected
Wisconsin Counties 94
21 Estimated Land Investment Requirements by County 96
22 Major Equipment Items Required for Loaded-Mode Emissions Testing . . 97
23 Equipment Costs as a Function of Facility Configuration 98
24 Equipment Costs for Loaded Mode Testing Network 99
25 Initial Capital Cost Summary 100
26 Estimated Hourly Starting Salaries for Administrative and
Operational Personnel Involved in Inspection and Main-
tenance Programs in Wisconsin 104
27 Administrative Personnel Costs Associated With Program Startup,
State-Run Option 106
28 Administrative Personnel Costs Associated With Program Startup,
Contractor-Run Option 107
29 Summary of Startup Costs 108
30 Annual Personnel Costs for Facility Personnel 109
31 Annual Calibration Costs Ill
32 Annual Taxes - Contractor-Run Option 112
33 Annual Cost for Utilities, Services, and Supplies - State Versus
Contractor-Run Options 113
34 Annual Administrative Personnel Costs - State-Run Option 114
35 Additional Administrative Personnel Costs for Contractor Option . . . 115
ix
-------
TABLES (continued)
No.
36 Cost Summary - State-Run Option 117
37 Cost Summary - Contractor-Run Option 118
38 Annualized Costs for the State-Run Option in Constant Dollars .... 120
39 Annualized Costs for the Contractor-Run Option in Constant
Dollars 120
40 Annualized Costs for the State-Run Option in Actual Dollars 121
41 Annualized Costs for the Contractor-Run Option in Actual Dollars. . . 121
42 Break-Even Fees, fc, in Real 1978 Dollars, and fa in Actual Dollars
for the State-Run and Contractor-Run Options 122
43 Cost Schedule for a State-Run Program, 1979-1987 123
44 Cost Schedule for a Contractor-Run Program, 1979-1987 124
45 Implementation Schedule - Summary 137
46 I/M Options Analyzed 142
47 Breakeven Fees in Constant 1978 Dollars for Options 1 Through 6 ... 143
48 1987 Inspectable Vehicle Population, Using Two Different Projection
Methods 148
49 Inspections Required 1982 to 1987 148
50 Inspection Network 150
51 Program Employees 150
52 Projected Percent Reductions in CO and HC Emissions 1983 to 1987
Due to I/M 154
53 Outline of Program Cost Categories and Elements 159
54 Cost Summary - State-Run Option 160
55 Cost Summary - Contractor-Run Option 161
56 Breakeven Fees, fc, in Real 1978 Dollars, and fa, in Actual Dollars
for the State-Run and Contractor-Run Options 158
x
-------
TABLES (continued)
No.
57 Implementation Schedule - Summary 163
A-l Inspection Network Requirements 167
A-2 Building Cost Estimates, Seven County Option 167
A-3 Estimated Land Investment Requirements by County, Seven County
Option 168
A-4 Equipment Costs for Loaded Mode'Testing, Seven County Option .... 169
A-5 Initial Capital Cost Summary, Seven County Option 170
A-6 Administrative Personnel Costs Associated With Program Startup,
State-Run Option 173
A-7 Administrative Personnel Costs Associated With Program Startup,
Contractor-Run Option 174
A-8 Summary of Startup Costs, Seven County Alternative 175
A-9 Annual Personnel Costs for Facility Personnel 176
A-10 Annual Taxes - Contractor-Run Options 178
A-ll Annual Costs for Utilities, Services, and Supplies - State Versus
Contractor-Run Options, Seven County Alternative 179
A-12 Cost Summary - State-Run Options 181
A-13 Cost Summary - Contractor-Run Option 182
A-14 Annualized Costs in Constant 1978 Dollars 183
A-15 Annualized Costs in Actual (Inflated) Dollars 184
A-16 Breakeven Fees, fc in Constant 1978 Dollars, and Fee in Actual
Dollars for the State-Run and Contractor-Run Options; Seven
County Alternative 185
A-17 Cost Schedule for a State-Run Program, 1979 Through 1987 186
A-18 Cost Schedule for a Contractor-Run Program, 1979 Through 1987 .... 187
A-19 Effect of Varying Stringency Factor on CO and HC Emissions -
Presented as Percent Emissions Reduction as a Function of
Stringency Factor 188
xi
-------
TABLES (continued)
No.
A-20 Effect of Varying the Vehicle Age Exemption on Emissions
Reductions for 1987 189
B-l Travel Weighting Factor Calculation Light-Duty Vehicles 191
B-2 Daily VMT for Brown and Dane Counties 193
B-3 Daily VMT and Average Speed 194
B-4 Wisconsin VMT 1977 195
B-5 Wisconsin VMT 1987 196
C-l Estimated Daily LDV VMT Figures for Selected Counties for 1987 . . . 199
C-2 Travel Weighting Factor Calculation for Light-Duty Vehicles 200
C-3 EPA MPG Specifications and Average Fleet Mileage for LDVs Covered
by I/M in 1987 201
C-4 Potential Annual LDV Fuel Savings in 1987 Due to I/M
(In Gallons) 202
C-5 Estimated Daily LDV VMT Figures for Selected Counties for 1987 . . . 203
C-6 Travel Weighting Factor Calculation Light-Duty Gas Trucks
<6000 Ib (LOT 1) 204
C-7 Mileage Estimates and Average Fleet Mileage for LDT 1 Covered by
I/M in 1987 205
C-8 Potential Annual LDT 1 Fuel Savings in 1987 Due to I/M
(In Gallons) 206
C-9 Travel Weighting Factor Calculation Light-Duty Gas Trucks 6001 to
8500 Ib (LDT 2) 208
C-10 Mileage Estimates and Average Fleet Mileage for LDT2 Covered by
I/M in 1987 209
C-ll Potential Annual LDT2 Fuel Savings Due to I/M in 1987, in Gallons . . 210
C-12 Potential Annual Fuel Savings Due to I/M in 1987, in Gallons .... 210
xii
-------
ACKNOWLEDGMENTS
The authors would like to acknowledge the significant contributions made
by several individuals and organizations throughout this project. We would
like to express our appreciation to the members of the Inter-Agency Task Force
and to several individuals associated with the Wisconsin Departments of Natural
Resources and Transportation who provided the necessary inputs for our study.
Included are Messrs. Ed Hammer and Carl Zutz of the Department of Transporta-
tion, and Mr. Tom Mickelson of the Department of Natural Resources. Also, we
wish to thank the EPA Task Officer, Mr. Carlton Nash, who provided general
direction throughout the study effort.
Xlll
-------
SECTION 1
INTRODUCTION
BACKGROUND AND OBJECTIVE
Amendments to the Clean Air Act that were adopted during 1977 have
established that the National Ambient Air Quality Standards (NAAQS) for
pollutants such as carbon monoxide (CO) and photochemical oxidents (Ox)
must be attained in all areas of the U.S. no later than 31 December 1982.
The U.S. Environmental Protection Agency, the federal agency charged with
the responsibility of administering and enforcing the Clean Air Act and
ammendments thereto, has set the requirement that each state containing
an area (or areas) currently in violation of the NAAQS must submit a revision
to its State Implementation Plan (SIP) during January 1979 demonstrating
compliance in all areas by 31 December 1982. That all states will not be
able to demonstrate total compliance by the end of 1982 is recognized in the
Amendments and provisions are made for extending the compliance date to
31 December 1987. In order to obtain the extension, however, the revised
SIP to be submitted in January 1979 must include (among other things) a
specific schedule for the implementation of a motor vehicle emissions
inspection and maintenance (I/M) program in those nonattainment areas that
have an urbanized population greater than 200,000. Failure to submit an
acceptable I/M schedule (or if a reasonable effort toward submitting an
acceptable schedule is not being made) will result in rather severe sanctions
being imposed on the state.
Preliminary reviews of the status of air quality control regions in the
State of Wisconsin have indicated that the NAAQS for Ox and/or CO will likely
not be achieved by 31 December 1982 in all instances. Given the require-
ments of the Clean Air Act Amendments mentioned above, a decision was made
to initiate action that would serve to identify the overall requirements for
I/M in the State. This action involved the establishment of an Inter-Agency
Task Force, comprised of representatives from the Departments of Natural
Resources and Transportation, which will provide a technical advisory function
for the State. Also, to assist the State in its early efforts, the Region
V Office of the U.S. Environmental Protection Agency contracted a consulting
firm - GCA/Technology Division - to provide specific technical assistance to
the Inter-Agency Task Force.
The initial effort in this connection was the development of background
data regarding the general technical and administrative aspects of I/M pro-
grams, and a summary of various states' experiences to date with actual
-------
program operation. GCA provided this background information through a series
of technical memoranda1>2>3 and a summary report.4
Based in part on the data provided by GCA, the Inter-Agency Task Force
identified and evaluated a series of 55 possible I/M program options. As a
result of the evaluation, the Task Force selected a total of six specific
I/M program options that appeared to be the most appropriate for implementa-
tion in Wisconsin. These included (1) centralized, contractor-operated,
steady-state, loaded mode emission testing combined with noise and safety
inspections; (2) centralized, contractor-operated, loaded-mode emission
testing; (3) centralized, contractor-operated, idle mode emission testing;
(4) centralized, state-operated, steady-state, loaded mode emission testing,
combined with safety and noise testing; (5) centralized, state-operated, idle
mode emission testing; and (6) decentralized, private garage/service station
operation using idle mode emission testing, with provisions for a referee
station. Further, regardless of the option selected, implementation is cur-
rently being considered for the nine counties listed below.
1. Brown County
2. Dane County
3. Kenosha County
4. Milwaukee County
5. Ozaukee County
6. Racine County
7. Walworth County
8. Washington County
9. Waukesha County
Having identified several possible program configurations, the next step
was to analyze each in detail so that eventually a final selection of a single
option could be made. To provide the basis for a decision, a detailed com-
parative analysis was made of the options in terms of costs, benefits, and re-
source requirements; this analysis is reported in Reference 5. Using the
data contained in the evaluation report, the Task Force decided on an option
involving centralized test facilities conducting loaded mode emissions inspec-
tions in the nine counties defined previously (the option will be defined more
explicitly later). Still undecided, however, is whether the network of central
test facilities should be operated by the State or by a private contractor.
The objective of the study being reported here is to analyze the spe-
cific requirements of the option selected, primarily in terms of costs,
benefits, and resource requirements, and consider in detail various tangential
factors and issues that are also relevant. The major difference in this
effort and the effort reported in Reference 5 is that, whereas the earlier
effort focused on providing a comparative analysis of several options and
therefore was rather general in treating several aspects of program imple-
mentation and operation, this effort focuses on one specific program and pro-
vides a more detailed analysis of many program factors.
-------
BASIS AND ORGANIZATION OF THIS REPORT
Again, the intent here is to report the results of a rather detailed
analysis of the particular I/M program configuration that is being consid-
ered for implementation in the State of Wisconsin. The general elements
included in the analysis are (1) benefits, (2) personnel requirements,
(3) adjunctive program requirements, (4) legislative requirements, (5) costs,
and (6) implementation scheduling.
The general philosophy used in developing the analysis considered the
fact that a number of different resources had to be utilized in order to
produce an assessment that was both comprehensive in nature and specific
to the State of Wisconsin. In this connection, it was considered not only
appropriate, but essential to include several State agencies as sources of
data and to conduct discussions with 'various State officials to solicit
their views on different issues that are germane to the I/M program in the
State. Much of the technical information generally available in the lit-
erature and from the U.S. Environmental Protection Agency was reviewed
also as part of the effort, and incorporated where appropriate. Other
sources of technical information used include discussions with both state
officials and private contractors currently involved with running I/M
programs throughout the U.S. A substantial amount of effort was also
expanded on original research by staff members of GCA/Technology Division
utilizing information derived from the above-mentioned sources.
The report is divided into nine principal sections including this
introduction. The option being considered here is defined and discussed in
detail in Section 2. Section 3 provides a discussion of the various bene-
fits associated with implementation of the I/M program, in terms of both
direct and indirect benefits, and also indicates the associated disbenefits.
The resource requirements for the program are discussed in Section 4. Given
prime consideration here are personnel requirements for both implementation
and operation of the inspection program and operation and administration of
the adjunctive programs such as consumer protection, quality assurance, and
others. Section 5 provides a detailed discussion of the several supporting
programs that are required. Included are discussions of (1) quality
assurance, (2) mechanic training, (3) consumer protection, (4) enforcement,
and (5) public information programs. Section 6 discusses the technical
requirements for state legislation and mentions issues relevant to barriers
or obstacles that can be encountered in the legislative process. The costs
associated with implementing the program are discussed in detail in Section 7,
The discussion here is in terms of both actual program costs by category,
and the inspection fee requirements. Section 8 presents an_.analysis of the
implementation staging and scheduling, as well as providing discussion con-
cerning future expansion of the program to include additional elements
(i.e., safety and noise) and increased geographical coverage. Finally, Sec-
tion 9 provides a summary of the overall analysis specifically with regard
to differences in each program element that occur as a function of whether
the program is State or contractor operated. Following the main sections
of the report are four appendices. Appendix A provides a sensitivity analy-
sis of several variables on emission benefits and program cost. Appendix B
-------
includes a detailed description of the methods used in computing the emission
inventories and emissions reductions from the I/M program. A detailed descrip-
tion of the methods used in computing the fuel savings benefits is presented
in Appendix C, and finally, in Appendix D, a discussion of special problems
associated with winter operation is developed.
-------
REFERENCES
1. Midurski, T. P., and D. Ramsay. Technical Memorandum No. 1 - Testing
Programs (Emission, Safety, Noise). GCA Corporation, GCA/Technology
Division, Bedford, Mass. Prepared for U.S. Environmental Protection
Agency, Research Triangle Park, N.C. April 1978.
2. Midurski, T. P., and D. Ramsay. Technical Memorandum No. 2 (Ownership
of Test Lanes and Equipment). GCA Corporation, GCA/Technology Division,
Bedford, Mass. Prepared for U.S. Environmental Protection Agency,
Research Triangle Park, N.C. April 1978.
3. Midurski, T. P., and D. Ramsay. Technical Memorandum No. 3 (Test Mode-
Idle, Loaded). GCA Corporation, GCA/Technology Division, Bedford, Mass.
Prepared for U.S. Environmental Protection Agency, Research Triangle
Park, N.C. April 1978.
4. Midurski, T. P., and D. Ramsay. Summary Paper on Inspection and Main-
tenance. GCA Corporation, GCA/Technology Division, Bedford, Mass.
Prepared for U.S. Environmental Protection Agency, Research Triangle
Park, N.C. March 1978.
5. Midurski, T. P., et al. Phase II Final Report. GCA Corporation, GCA/
Technology Division, Bedford, Massa. Prepared for U.S. Environmental
Protection Agency, Region V, Chicago, Illinois. EPA 905/2-78-003.
September 1978.
-------
SECTION 2
PROGRAM OPTION
OPTION DEFINITION
Based on a rather detailed review of several possible inspection and
maintenance program (I/M) scenarios, the State I/M Task Force selected a
specific configuration that appears to be best suited for implementation in
the State. Essentially, the program selected involves establishing a net-
work of centralized emissions inspection stations where loaded mode testing
will be conducted. The basic loaded mode, centralized facility concept was
selected for several reasons. First, it was considered that the loaded mode
option offers several advantages over the idle mode, including more com-
prehensive diagnostic capabilities, and more flexibility in testing pro-
cedures. Also, there will likely be an NOX standard defined in the near
future for motor vehicles and NOX testing may become necessary as part of
the I/M program; NOX testing can only be performed with the engines under
a load, as when a loaded test is performed. The major disadvantage of the
loaded mode test is that it is slightly more expensive to perform since
additional test equipment is required. The incremental cost difference,
however, is in the range of $0.20 to $0.25 per test and is not considered
to be significant.
The primary reasons for selecting the centralized facility approach
over private garages concerned program control and anticipated public
acceptance of the program. Specifically, the State would be able to ex-
ercise much closer control over the inspection program with fewer personnel,
which should result in a much higher quality program, then would be achievable
if the decentralized option were used. Further, it was considered that the
public would be much less skeptical of a program where inspections were per-
formed by an impartial entity who would not benefit from vehicles either
failing or passing (primarily since repairs are not performed at the cen-
tralized facilities, nor are any individuals undergoing inspections con-
sidered "regular customers" who could bias the inspector.
One rather significant aspect of the program has not yet been deter-
mined - this concerns whether the State or a private contractor will be
responsible for the construction and operation of test facilities. It is
hoped that the results of the study being reported here will aid in arriving
at a decision in this matter.
-------
A number of additional elements must be defined in order to fully des-
cribe the program. The program is currently being considered for the follow-
ing counties:
• Brown County
• Dane County
• Kenosha County
• Milwaukee County
• Ozaukee County
• Racine County
• Walworth County
• Washington County
• Waukesha County
The inspection frequency has been defined as annual with inspections being
staggered throughout the year. Generally, inspections will be scheduled to the
extent that they should be performed within a time period prior to registration.
A method that could be used is to forward registration renewal material to
motorists, say, 60 days before the renewal deadline. In order for the motorist
to renew his registration, an emissions inspection stamp will be required on
the registration form; this inspection stamp would be obtained by successfully
passing the emissions inspection (or being granted a waiver) at an inspection
station. The 60-day lead time would assure adequate time to obtain an inspection
and a reinspection if required.
The vehicle population to be tested consists essentially of all light-duty
vehicles (LDV's) and light-duty trucks (LDT's) with a gross vehicle weight (GVW)
of 8,000 pounds or less. Some exemptions will be made, however, including
(tentatively): 4
• vehicles greater than 15 years old;
• vehicles registered as farm trucks;
• research vehicles; and
• vehicles otherwise included but where at least $50
has been spent on repairs to bring the vehicle into
compliance (where problems are not a result of
tampering) although unsuccessfully.
A stringency level of 20 percent has been defined for this analysis. Other
stringency factors and vehicle exemptions (as a function of model year) have
been analyzed primarily to determine the impact that these would have on inspec-
tion fees and emissions reductions. These are reported in Appendix A. It has
also been indicated that the program would operate on a mandatory inspection -
voluntary repair basis during the first year. This will serve primarily to
acquaint the public with the program as well as to gather baseline emissions
data from which cutpoints can be established.
-------
Several supporting programs will also be established in conjunction
with the I/M program. Included are programs for: (1) public information,
(2) consumer protection, (3) quality assurance, and (4) mechanics's training.
These programs may be operated by the State or portions of each may be
operated by contractors. These ancillary programs are described fully in
Section 5.
EMISSIONS INSPECTION SCENARIO
In order to illustrate how the I/M program will work and where some
of the ancillary programs tie in, the following description of the test
procedure is offered.
The requirements for an emissions inspection in each instance will be
related to the annual registration procedure; that is, emissions inspections
will be required generally during the period when registration renewals are
due. To initiate the registration renewal process, the Division of Motor
Vehicles, within the Department of Transportation, will mail out regis-
tration renewal forms to motorists within the nine counties. Mailings will
be staggered such that approximately one-twelfth of the total registrations
are processed each month (slightly lower in winter months) approximately 2
months prior to the renewal deadline. Sometime during this 2-month period,
motorists will bring their vehicles to contractor (or state) operated
inspection stations.
At the inspection station, the motorist will present his renewal forms,
from which certain information will be collected and entered into a computer
file. This information would include:
1. A serial number which allows the test record to be
retrieved and identified with the computer;
2. Exact date and time of the test;
3. The vehicle identification number (VIN);
4. Vehicle registration number;
5. Vehicle model, year, and make;
6. Owner's name;
7. Engine configuration;
8. Emissions control equipment;
9. Vehicle weight class; and
10. Test number (first, second, third, etc.).
-------
Based on this information, test personnel can make a judgement as to
whether or not the vehicle is exempt from emissions inspection. If the vehicle
is exempt, the owner is given an official waiver form, printed by the computer,
containing information pertaining to his particular vehicle, and the registration
form is stamped, accordingly. He then either mails the completed renewal
materials, (or brings them in person) to the Division of Motor Vehicles,
where they are processed and the registration is completed.
If the vehicle is not exempt, it proceeds through the test lane, where
it is subjected to an emissions test. Pass-fail criteria are automatically
adjusted to the particular characteristics of the vehicle. If the vehicle
passes inspection, the computer prints out a certificate indicating compliance,
and the registration renewal form is stamped, accordingly. The motorist then
mails the registration material or brings them in person to the Division of
Motor Vehicles where the registration is completed.
If the vehicle fails inspection, the computer prints out a form stating
which standards are being exceeded, and by how much. The owner will be
advised of the probable cause for failure, and required to have the vehicle
repaired and reinspected within a specified number of days. The owner will
then bring the vehicle (and the failure form) to the repair station of his
choice where repairs will be made to bring the vehicle into compliance with the
standards. The mechanic completes a repair form, stating:
1. Repair actions performed;
2. Parts replaced;
3. Cost of parts;
4. Cost of labor; and
5. Name and address of repair facility.
The vehicle owner then brings the completed form and the vehicle back
to a contractor (or state) test facility. There, the vehicle undergoes a
test procedure similar to that described previously, except that no test
fee is charged. If it now meets emissions standards, the registration form
is stamped and the owner completes the registration process as described
above.
If the vehicle fails the first retest, the vehicle owner is obliged to
go through the repair and reinspection cycle once again; however, if the
accumulated total of repair costs exceeds a specified repair cost limit, he
may be granted a waiver as before. The second retest (and those following if
necessary), however, will cost the same amount as the original test.
Should the motorist at any point in the above process have a complaint
concerning either the inspection or the maintenance phase, he may register
the complaint with the Department of Transportation by calling a toll-free
"hotline" telephone number. Depending on the nature of the motorist's complaint,
the hotline operators can take a variety of different actions in response. If
-------
the complaint is due to lack of information, the motorist can be refered to a
public relations official (either contractor or state), who can provide more
information about the program and its methods. If the complaint concerns
actions of the contractor or questions the accuracy of the contractor's
equipment, the operators refer the complaint to an appropriate offical concerned
with quality assurance. The Quality Assurance coordinator would decide upon
the appropriate action; he could visit the test lane in question and check the
calibration of its emissions analysis equipment, or have a complaints investi-
gator conduct either an unannounced spot check or a formal investigation of the
test lane in question. If the motorist's complaint concerns actions on the
part of the private automotive repair industry, the operators refer the complaint
to the Trade and Consumer Protection Division of the Department of Agriculture,
which has the authority to investigate consumer complaints concerning private
garages. Should any complaint uncover criminal actions, then the operators could
refer the complaint to the Attorney General's Office for criminal proceedings.
A general flow chart showing the registration process described above
is provided in Figure 1.
10
-------
KAIVEK
GRANTED
t
TES
VEHICLE OWNER TAKES/
HAILS STAMPED REGIS-
TRATION FORM TO RE-
GISTRATION OFFICE
/
YES
\
REGISTRATION
FAILURE RECORDED,
OWNER BRINGS
VESICLE TO REPAIR
FACILITY OF HIS
CHOICE FOR MAINTENANCE
i
NOTE: DOTTED LINE SHOWS COMPLAINT FLOW PATH.
^
INFORMATION
REFERRAL TO
VEHICLE OUTER
t
CALIBRATION CHECK
ON COSTRACTO8 (OR
STATE) TEST LAKE
APPROPKIATE CONSIDER
PROTECTION ACTION TAKEN
1
UNANNOUNCED SPOT
CHECK ON CONTRAC-
TOR (OB STATE) OR
PRIVATE REPAIR
FACILITY
<
I
FORMAL COMPLADTTS
INVESTIGATION OF
COKTSACTCR (OR STATE)
OR PRIVATE REPAIR
FACILITY
1
REFERRAL TO
ATTORNEY GENERAL'S
OTTICE FOR CRDONAL
PROCEEDINGS
Figure 1. Motor vehicle inspection and registration flow chart.
-------
SECTION 3
I/M PROGRAM BENEFITS AND IMPACTS
INTRODUCTION
Concern for controlling automotive emissions stems from the fact that
automobile traffic is responsible for approximately 75 percent of all urban
carbon monoxide (CO) emissions, 50 percent of hydrocarbon (HC) emissions, and
50 percent of the oxides of nitrogen (NO ) emissions. EPA data indicate that
automobile transportation is responsible for as much as 14 to 23 percent of
total air pollution costs. A study by the National Academy of Science estimated
annual societal costs for this pollution (in 1969) to range from $2.2 to $5.7
billion.1 When these costs are subsequently adjusted to account for todays
inflation rates, these costs rise to $3.3 to $8.6 billion. Furthermore, a
1978 study by the National Highway Traffic Safety Administration indicates
that "the prorated societal cost of air pollution caused by automobiles would
be equivalent to from $24.30 to $64.30 per vehicle."1 This same study also
states that "it is conceivable that national inspection and mandatory mainte-
nance would reduce societal cost of pollution $1.3 to $3.4 billion annually."1
Besides these economic benefits and the benefit of decreased emissions
seen from I/M implementation, other important benefits may accrue. These in-
clude an improvement in fuel economy, increased reliability, better overall
performance etc.; these types of benefits have been realized by fleets that
undergo their own special maintenance programs where the actual maintenance is
similar to that associated with an I/M program.
EMISSIONS REDUCTIONS
Emission reduction is the primary benefit to be derived from I/M programs.
Although new vehicles are required to meet certain EPA specifications for emis-
sions, it has been shown that emission rates for in-use vehicles deteriorate
significantly unless adequate maintenance is performed. I/M has been suggested
as an effective means for ensuring that the necessary routine maintenance is
performed periodically, thus resulting in a significant decrease in emissions
generated by the motor vehicle population.
Various levels of reductions in emissions have been noted in ongoing I/M
programs. The actual reduction varies with stringency factors, climate, and
other considerations. Hamilton Test Systems, under contract to the State of
Arizona, noted in a 1978 report2 that of those vehicles undergoing inspection
and subsequent maintenance in the Arizona I/M program, 25 percent reduction
in idle CO emissions and 41 percent reduction in idle HC emissions were shown
compared to those tested in 1976 (Pre-I/M), Hamilton Test Systems claims that
this program is reducing by about 250 tons, the daily amount of CO and HC
12
-------
emitted into the atmosphere in the Arizona counties covered by I/M, as well as
saving motorists an estimated 30 million gallons of gasoline annually.3
Analyses performed by other state and federal agencies'1 show similar
results.
Projected Emission Reductions
Motor vehicle emission inventories for both CO and HC were developed for
each of the nine counties using EPA's MOBILE 1 computer routine. Input data
regarding vehicle-miles of travel (VMT) by vehicle type, roadway functional
class, and speed were provided by the Wisconsin Department of Transportation.
It should be noted that the emission inventories developed for use here are of
a preliminary nature and may be different from the rather detailed inventories
currently being developed by the state for use in the upcoming State Implemen-
tation Plan revision. That the inventories presented here are of a preliminary
nature does not diminish their usefulness significantly since the intent is to
indicate relative emissions burden with and without an I/M program, rather than
define the absolute magnitude of emissions produced. A detailed description of
the methodology used in deriving the inventories is provided in Appendix B.
Inventories were prepared for each year beginning with 1982 through 1987
for each of the nine counties. Average daily emissions generated by light-
duty vehicles (cars and trucks) and by all vehicles were defined for two
scenarios. The first scenario reflected the vehicle population emission cha-
racteristics in the absence of an I/M program, while the second scenario re-
flected the compounded effects of an I/M program beginning in January 1982 on
emissions during each year. Comparison of the emission totals for both the
total vehicle population, and the individual vehicle classes affected by I/M
indicate the impact that I/M can be expected to have. Tables 1 through 4
provide a county-by-county summary of daily CO and HC emissions, respectively,
during the years 1983 through 1987, both with and without the I/M program (as
defined in Section 2), for both the total vehicle population and for LDV's and
LDT's only. Table 1 shows the county-by-county tabulation for CO for the
years 1982 through 1987 for light-duty vehicles while Table 2 shows the same
data with regard to HC emissions. Tables 3 and 4 are similar to Tables and 1
and 2 except that emissions from the entire vehicle population are shown. Of
particular interest is the reduction achievable by 1987 for the LDT and LDV
population. EPA requires that the program produce at least a 25 percent re-
duction in emissions in 1987 from vehicles included in the program (LDV's and
LDT's) compared to the emissions that would be produced by these same vehicles
in 1987 without I/M. The last column in Tables 1 and 2 indicate that the
proposed I/M program will, on the average for all counties, achieve a reduc-
tion of 50 percent and 42 percent for CO and HC, respectively, indicating that
the program configuration is more than adequate to meet EPA's minimum standards.
The reductions by year are shown graphically for CO and HC in Figures 2 and 3,
respectively, for the total nine counties, and in Figures 4 and 5 for only
the seven counties in the Milwaukee area for CO and HC, respectively.
An analysis of the effects of varying the stringency factor was also con-
ducted, again using MOBILE 1. Average daily CO and HC emissions were computed
for 1983 and 1987 using the I/M program scenario discussed in Section 2,
except that stringency factors of 10 through 40 percent were substituted for the
13
-------
TABLE 1. PROJECTED CARBON MONOXIDE EMISSIONS (kg/day) AND PERCENT REDUCTIONS
ACHIEVABLE FOR LDV's AND LDT's ONLY
Milvauke.9-7-County Area
Freeways and Arterials
Renosha
Milwaukee
Ozauk.ee
Racine
Ualworth
Washington
Waukesha
7-County, locals
7-Comty total
fto-nCssa
Freeways, arterials. and locals
Dane County
Freeways, arterials, and locals
Total I/M area
1982
Without
I/H
40,606
286,308
24,073
50,189
24,723
27,636
91,324
88,941
630,005
63,493
124,237
817,735
Dally
I/M
36,813
252,433
19,922
45,196
22,507
24,789
82,324
78,023
562,007
57,228
111,378
730,613
emissions
I/M*
29,689
203,087
16,040
36,432
18,208
20,076
66,461
62,812
452,805
46,230
89,877
588,912
In 1983
reduction
19
20
19
19
19
19
19
19
19
19
19
19
Daily
I/M
33,436
223,184
18,013
40,787
20,496
22,383
74,334
68,579
501,212
51,643
100,051
652,906
emissions
I/M
23,974
159,398
12,877
29,224
14,776
16,171
53,406
49,068
358,894
37,166
71,835
467,895
in 1984
reduction
2B
29
29
28
28
28
28
28
28
28
28
28
Daily
I/M
30,596
119,016
16,413
37,031
18,798
20,355
67,612
60,816
450,692
46,926
90,591
588,209
emissions
I/M
19,723
127,633
10,536
23,879
12,211
13,265
43,710
39,130
290,087
30,438
58,530
379,055
in 1985
reduction
36
36
36
36
35
35
35
36
36
35
35
36
Daily
i I/M
28,030
179,223
14,950
33,715
17,618
18,703
61,671
54,907
408,817
42,842
82,462
534,121
emissions
15,877
100,829
8,413
19,073
10,090
10,764
35,088
31,062
231,196
24,515
46,894
302,605
ijl 1986 Daily
reduction I/M
-3 25,966
44 163,319
44 13,778
43 31,016
43 16,697
42 17,367
43 56,866
43 50,191
43 375,200
43 39,541
43 75,918
43 490,659
emissions
I/M
12,378
80,265
6, 769
15,354
8,407
8,807
28,382
24,833
185,695
19,912
37,878
243,485
in 1987
reduction
50
51
51
50
50
49
50
50
50
50
50
50
Assiaaed I/H stringency level is 20 percent
-------
TABLE 2. PROJECTED HYDROCARBONS* EMISSIONS (kg/day) AND PERCENT REDUCTIONS
ACHIEVABLE FOR LDV'S AND LOT'S ONLY
County
Freeways and Artenals
Kenosha
Milwaukee
Ozaukee
Racine
Wai worth
Washington
Uaukesha
7-County, locals
1982
I/M
5,039
33,174
2,795
6,150
3,181
3,496
11,494
9,351
Daily t
a*
4,466
28,810
2,462
5,419
2,817
3,071
10,104
8,148
MiSsiOQ0 :
I/M I
3,861
24,627
2,135
4,677
2,453
2,669
8,761
6,853
In 1983
reductioi
11
15
13
14
13
13
13
16
Dili; 1
i I/M
3,984
25,211
2,182
4,809
2,506
2,712
8,936
7,158
missions i
I/M 1
3,227
20,107
1,775
3,885
2,052
2,216
7,275
5,584
In 198*
reductioi
19
20
19
19
18
18
19
22
Daily <
I I/M
3,593
22,3.47
1,955
4,314
2,252
2,419
7,991
6,375
Missions j
I/M ]
2,661
16,188
1,456
3,184
1,696
1,818
5,961
4,484
In 19(5
reductioi
26
28
26
26
25
25
25
30
Dfilj t
I I/M
3,266
20,122
1,762
3,898
2,083
2,194
7,215
5,816
Missions i
I/M i
2,160
12,916
1,172
2,566
1,411
1,485
4,823
3,595
Jl 1986
•eductioi
34
36
33
34
32
32
33
38
Saiiy (
i I/M
:,8^o
18,, 61
1,619
3,589
1,963
2,030
6,636
5,401
911551005 J
I/M .
1,777
10,438
959
2,097
1,190
1,229
3,952
2,919
10 1937
reduction
3:
,3
41
42
39
39
40
46
7-County total 74,680 65,297 56,036 14 57,498 46,121 20 51,246 37,448 27 46,356 30,128 35 42,540 24,561
Freevays. arterials, and locals 7,109 6,307 5,365 15 5,635 4,471 21 5,097 3,675 28 4,664 2,986 36 4,343 2,457 43
Freei-ays, arterials, and locals 14,605 12,854 11,011 14 11,395 9,121 20 10,227 7,458 27 9,293 6,029 35 8,598 4,937 43
Total I/M area 96,394 84,458 72,412 14 74,528 59,713 20 66,570 48,581 27 60,313 39,143 35 55,481 31,955 42
Nooaethane HC only.
-------
TABLE 3. PROJECTED CARBON MONOXIDE EMISSIONS (kg/day) AND PERCENT REDUCTIONS
ACHIEVABLE FOR ALL VEHICLES
County
1982
Daily a
Without
I/M
Without
I/M
Missions in 1983
With
I/M i
Percent
reduct to
Dally
Without
emissions in 1984
Daily
I/M reduction I/M
enissions in 1985
Dally emissions In 1986
I/M reduction I/M I/M reductic
Dally
» I/M
-i*
lions
in 1987
I/M reduction
Milwaukee-7-Councv Area
Freeways and Arterials
Kenosha
Milwaukee
Ozaukee
Racine
Kalnorth
Washington
Vaukesha
7-County, locals
7-County total
Brown County
Freeways, arterials,
Dane County
Freeways, arterials.
Total I/M area
50,
399,
29,
65,
36,
38,
136.
121,
877,
and locals 78,
and locals 162,
1,118,
435
372
241
810
288
484
558
240
928
025
524
477
46,
362,
26.
60,
33,
35,
126,
108,
801,
71,
148,
1,021,
606
056
976
610
995
600
934
592
369
456
945
770,
39,481
312,711
23,096
51,847
29,733
30,887
111,074
93,390
692,219
60,458
127,445
880,122
15
14
14
14
13
13
12
14
14
15
14
14
42,791
324,444
24,690
55,344
31,407
32,527
116,344
96,368
723,915
64,991
135,340
924,246
33
260
19
43
25
26
95
76
581
50
107
739
,329
,657
,555
,780
,686
,315
,415
,857
,594
,514
,123
,231
22
20
21
21
18
19
18
20
20
22
21
20
39
291
22
50
29
29
106
85
656
59
123
839
,465
,772
,695
,709
,080
,803
,820
,876
,220
,346
,473
,039
28,591 28
220,390 24
16,813 26
37,508 26
22,494 23
22,713 24
82,918 22
64,190 25
495,617 24
42,858 27
91,414 26
629,889 25
36
263
20
46
27
27
97
77
597
54
112
756
,333 24,183
,869 185, H/5
,793 1-..255
,322 31,680
,363 19,836
,496 19,557
,950 71,369
,630 53,786
,756 420,141
,332 36,006
,922 77,354
,010 533,501
33
30
31
32
28
29
27
30
30
34
31
29
33,874
241,937
19,310
42,884
26,095
25,687
91,008
71,172
551,967
30,356
104,619
706,942
20,
158,
12,
27,
17,
17,
62,
45,
362,
30,
66,
459,
787
883
300
222
805
128
525
864
514
727
580
821
39
34
36
37
32
33
31
36
34
39
36
35
-------
TABLE 4. PROJECTED HYDROCARBON EMISSIONS* (kg/day) AND PERCENT REDUCTIONS
ACHIEVABLE FOR ALL VEHICLES
1982 Daily 1
CcU°ty Without Without
I/M 1/M
Nilwaukee-7-County Area
Keoosha 5,789 5,152
Milwaukee 41,241 3S.997
Ozaukee 3,304 2,923
Racine 7,242 6,408
Waluorth 3,950 3,511
Washington 4,240 3,737
Waukesha 14,304 12,614
7-County, locals 12,029 10,554
7-County total 92,099 80,896
Brown County
Freeways, arterials, and locals 8,218 7,319
Dane County
Freeways, arterials, and locals 17.393 15,380
Total I/M area 117,710 103,595
*
Nonmethane HC only.
missions in 1983
With Percent
I/M reductior
-,523 12
31,51-1 12
;,580 12
5,628 12
3,123 11
3,312 11
11,176 11
9,148 13
71,004 12
6,334 13
13,438 13
90,776 12
Dally ecisslons In 1984
Without With Percent
i I'M 1/M reductior
4.601 3.S23 17
31,530 26,150 17
2,593 2,172 16
5,689 4,732 17
3,121 2,646 15
3,297 2,781 16
11,142 9,393 16
9,297 7,620 18
71,270 59,317 17
6,547 5,342 18
13,648 11,283 17
91,465 75.942 17
Daily emissions In 1985
Witliout With Percent
I I/M I/M reductiot
4,147 3,194 23
27,903 21,484 23
2,321 1,804 22
5,097 3,935 23
2,795 2,219 20
2,933 2,313 21
9,923 7,812 21
8,286 6,295 24
63,404 49,061 23
5,919 4,460 25
12,239 9,383 23
81,562 62,904 23
Daily enissloos li 1986 Daily emissions in 1987
Without With Percent Without With Percent
I I/M I/M redaction I/M I/M reduction
3,768 2,643 3D 3,489 2,222 36
25,090 17,620 30 22,981 14.690 36
2,089 1,486 :9 1,917 1,241 35
4,598 3,235 30 4,228 2,703 36
2,573 1,883 27 2,413 1,621 33
2,654 1,925 27 2,444 1,625 34
8,918 6,449 28 8,162 5,400 34
7,571 5,243 31 7,044 4,448 37
57,261 40,484 29 52,678 33,950 36
5,416 3,700 32 5,043 3,116 38
11,110 7,759 30 10,269 6,519 37
73,787 51,943 30 67,990 43,585 36
-------
o
•o
e
o
V)
1400
1200 -
1000 -
800
• TOTAL co EMISSIONS FROM ALL VEHICLES-WITHOUT I/M
O TOTAL CO EMISSIONS FROM ALL VEHICLES-WITH I/M
AUDV AND LDT CO EMISSIONS-WITHOUT I/M
ALDV AND LDT CO EMISSIONS-WITH I/M
O 600 -
OT
V)
i
Ul
o
u
400 -
ZOO -
1983
1984
1985
1986
1987
YEAR
Figure 2. Daily CO emissions by year for LDV's and LDT's, and all
vehicles with and without I/M in nine Wisconsin counties
1982 through 1987.
18
-------
120
• TOTAL HC EMISSIONS FROM ALL VEHICLES-WITHOUT I/M
O TOTAL HC EMISSIONS FROM ALL VEHICLES-WITH I/M
ALDV AND LOT HC EMISSIONS-WITHOUT I/M
EMISSIONS-WITH I/M
1983
1964
1985
1986
1987
YEAR
Figure 3. Daily HC emissions by year for LDV's and LDT's, and all
vehicles, with and without I/M in nine Wisconsin counties
1982 through 1987.
19
-------
1400
• TOTAL co EMISSIONS FROM ALL VEHICLES-WITHOUT I/M
O TOTAL CO EMISSIONS FROM ALL VEHICLES-WITH I/M
AND LOT CO EMISSIONS-WITHOUT I/M
ALDV AND LDT CO EMISSIONS-WITH I/M
1982
1983
1984
1985
1986
1987
YEAR
Figure 4. Daily CO emissions by year for LDV's and LDT's, and all
vehicles with and without I/M in the Seven County Greater
Milwaukee area - 1982 through 1987.
20
-------
140
I - 1
HC EMISSIONS FROM ALL VEHICLES -WITHOUT I/M
O TOTAL HC EMISSIONS FROM ALL VEHICLES- WITH I/M
LOV AND LOT HC EMISSIONS -WITHOUT I/M
LDV AND LOT HC EMISSIONS - WITH I/M
1983
1984
1989
1986
1987
YEAR
Figure 5. Daily HC emissions by year for LDV's and LDT's, and all
vehicles with and without I/M in the Seven County Greater
Milwaukee area - 1982 through 1987.
21
-------
20 percent rate. A summary of the impact that the different stringency factors
have on CO and HC is presented in Table 5; these data are also displayed graph-
ically in Figures 6 and 7. These figures show quite dramatically that
increasing the stringency level above 20 percent results in very slight addi-
tional reductions in CO or HC emissions.
Fuel Economy
Typically, the types of repairs required by the I/M program include either
carburetor adjustments or minor engine tune-ups. Several studies have shown
that the types of repairs associated with I/M affect fuel consumption as well
as reduce emissions. Although a general improvement in fuel economy is reported
in the studies, there remains a question with regard to the magnitude of the
improvement.
A report1 published in 1978 by the National Highway Traffic Safety Adminis-
tration noted that vehicles undergoing I/M related repairs showed an increase
of 4.7 percent in fuel economy. This study also noted that fuel savings
nationwide could be projected if I/M programs were implemented on a national
scale; these projections show an annual gasoline savings of about 1.8 billion
gallons. It is noted, however, that these projections are based only on one
specific study, therefore the results and conclusions may not be applicable
in all instances. The important point here, however, is that relatively minor
problems such as a maladjusted carburetor or ignition timing can have an
effect on fuel economy and these types of problems become readily apparent
during routine emission inspections.
Champion Spark Plug Company, along with aid from the American Automobile
Association, conducted vehicle tests nationwide to gather data on motorist
maintenance habits and their effect on fuel consumption and emissions. This
study concluded that, after a tune-up, test cars showed an average fuel economy
improvement of 11.36 percent. Even as a result of simply replacing the spark
plugs, fuel consumption was seen to improve by 3.68 percent. The survey re-
vealed a lack of vehicle maintenance by the motoring public. Of the cars sur-
veyed, 79 percent needed some maintenance work to regain the optimum performance
level, and the type of maintenance needed most often was ignition and car-
buretion service. To quote the report, the program "clearly pointed out the
advantages gained by new plugs alone or complete engine tune-up in providing
better mileage, lower emissions, and better overall driving performance."5
Of interest when considering I/M program vehicle coverage, is the fact that
the oldest cars in the study (pre-1968) showed the greatest improvement (in
miles per gallon) in fuel economy of all year groups.
Another fuel economy improvement study was undertaken by Jerome Panzer
of Exxon Research and Engineering Company. Using a 50 percent rejection rate,
a pre-1975 vehicle population, and subsequent tune-ups for failed vehicles,
the average gain in fuel economy between annual inspections for study vehicles
was about 7.5 percent. This figure has been adjusted to account for estimated
deterioration; without considering this, a 13 percent immediate improvement
is indicated. Panzer found that repairs carried out to correct only emissions
produce about three-fourths of the fuel economy benefit achieved by a complete
tune-up. Also of interest is the fact that, when the effect of repairing the
22
-------
TABLE 5. EFFECT OF VARYING THE STRINGENCY FACTOR ON CO AND HC EMISSIONS REDUCTION POTENTIAL
LDV's and LDT's only
daily emissions* in kg/day and (percent reduction)'
Area Pollutant Year
Without I/M with 10%
I/M stringency
9-Counties CO 1983 730,613 636,866
(132)
1987 490,659 281,074
(43%)
HC 1983 84,458 74,161
(12%)
CO 1987 55,481 34,820
U) (37%)
7-County Greater CO 1983 562,007 489,778
Milwaukee Area (13%)
1987 375,200 214,498
(43%)
HC 1983 65,297 57,383
(12%)
1987 42,450 26,754
(37%)
I/M with 20%
stringency
588,912
(19%)
243,485
(50%)
72,412
(147.)
31,955
(42%)
452,805
(19%)
185,695
(50%)
56,036
(14%)
24,561
(42%)
I/M with 30%
stringency
561,656
(23%)
220,936
(55%)
71,411
(15%)
30,237
(46%)
431,840
(23%)
168,532
(55%)
55,268
(15%)
23,250
(45%)
daily emissions*
I/M with 40% Without I/M with 10%
stringency I/M stringency
547,127
(25%)
208,912
(57%)
70,864
(16%)
29,097
(48%)
420,660
(25%)
159,738
(57%)
54,847
(16%)
22,386
(47%)
1,021,770 928,038
(9%)
706,942 497,360
(29%)
103,595 92,528
(11%)
67,990 46,451
(32%)
801,369 729,154
(97.)
551,967 391,266
(29%)
80,896 72,353
(11%)
52,678 36,144
(31%)
All vehicles
in kg/day and
I/M with 20%
stringency
880,122
(14%)
459,821
(35%)
90,776
(12%)
43,585
(36%)
692,219
(14%)
362,514
(34%)
71,004
(12%)
33,950
(36%)
>
(percent reduction)"
I/M with 30?=
stringency
852,827
(17%)
437,223
(38%)
89,776
(13%)
41,865
(38%)
671,215
(16%)
345,301
(37%)
70,237
(13%)
32,643
(38%)
I/M with 40%
stringency
838,299
(18%)
423,584
(40%)
89,231
(14%)
40,730
(40%)
660,035
(18%)
334,892
(39%)
69,817
(14%)
31,778
(40%)
Total daily CO and nonmethane HC emissions
'Percent of analysis year emissions without I/M
-------
900
000
TOO
«OO
BOO
/
L/
v ALL AFFECTED ALL AFFECTH) ALL AFFECTED ALL AFFECTED ALL AFFECTED
VEHICLES VEHICLES VEHICLES VEHICLES VEHICLES VEHICLES VEHICLES VEHICLES VEHICLES VEHICLES*CT*MW/VCr-
0% IO% 20% 50% 40%
1983
IOOO
f
I
j
I
I
g
§
g
TOTAL 9 COUNTY AREA
•-T GREATER MILWAUKEE COUNTIES
PLUS DANE COUNTY
-7 GREATER MILWAUKEE COUNTIES
/\
"ALL AFFECTED ALL AFFECTED ALL AFFECTED ALL AFFECTED ALL AFFECTED
VEHICLES VEHICLES VEHICLES VEHICLES VEHICLES VEHICLES VEHICLES VEHICLES VEHICLES
0% 10% 20% S0%
IfST
40%
Figure 6. Effect of varying the stringency level on CO emissions for
LDV's and LDT's, and all vehicles for 1983 and 1987.
24
-------
" ALL AFFECTED ALL AFFECTED ALL AFFECTED ALL AFFECTED ALL AFFECTED
VEHICLES VEHICLES VEHICLES VEHICLES VEHICLES VEHICLES VEHICLES VEHICLES VEHICLES VEHICLES '
0% 10% 20% 50% 40%
ISSS
100
; -u
o
B 60
••TOTAL 9 COUNTY AREA
7 OREATER MILWAUKEE COUNTIES
PLUS DANE COUNTY
«-7 OREATER MILWAUKEE COUNTIES
ALL AFFECTED ALL AFFECTED ALL AFFECTED ALL AFFECTED ALL AFFECTED
VEHICLES VEHICLES VEHICLES VEHICLES VEHICLES VEHICLES VEHICLES VEHICLES VEHICLES VEHICLES
0% 10% 20% 50%
40%
I9IT
Figure 1. Effect of varying the stringency level on HC emissions for
LDV's and LDT's, and all vehicles for 1983 and 1987.
25
-------
50 percent of the vehicles tested that were the highest emitters is spread out
over the total car population, the fuel economy drops to an estimated 2 percent.
There are other interesting conclusions to note from this study. For in-
stance, it was found that as little as a 40 pound weight factor in a car has
a detectable effect on fuel consumption. Also, at the lowest rejection rates,
the malfunctions repaired were those having the greatest: impact on fuel economy
(e.g., misfires). Therefore, the rate of fuel economy improvement diminishes
as the rejection rate rises. There was no significant fuel economy change noted
in tuning up the 50 percent of the study cars that passed the emissions tests.
For the purposes of this study, it is assumed that the fuel economy im-
provement for vehicles that fail the emissions test and therefore undergo
maintenance, will be 7 percent averaged over a year. Applying this to the
projected vehicle population in the nine counties in 1987, the failure rate
chosen - 20 percent, and the relative travel distribution by various model
year vehicles, it is estimated that during 1987, approximately 5.76 million
gallons of gasoline would be saved as a result of the I/M program. Assuming
further that the cost of a gallon of gasoline in 1987 is $0.80, the fuel cost
savings associated with the 5.76 million gallons of fuel conserved is $4.6 mil-
lion. A detailed discussion concerning the derivation of the fuel savings
associated with the program is presented in Appendix C.
Impact on Vehicle Performance and Life
The effects of inspection and maintenance programs on vehicle performance
and life are currently under study. Preliminary analyses in this area have
focused on various vehicle fleets and indicate that I/M does have a positive
effect on both vehicle performance and vehicle life, although specific, quan-
titative statistics are not yet available.
Some of the more notable findings to date regarding vehicle performance
come out of Phoenix, Arizona. In order to reduce on-the-road failures, a
rather comprehensive preventative maintenance inspection program was imple-
mented for the City's vehicle fleet. Results of the program were closely
monitored resulting in the determination that: (1) the fuel consumption rate
during the first 6 months of the program decreased approximately 10 percent,
much of which was attributed directly to the program; arid (2) a significant
decrease occurred in the number of vehicles breaking down on the road and
requiring towing.
An aspect of the benefits that has not been adequately studied to date
concerns the deterioration of emission characteristics over time subsequent
to repairs being performed. Several studies have been performed that indirectly
consider the subsequent deterioration of emissions but consistent conclusions
regarding the long-term (over a 1-year period, say) effect have not been
reached.
26
-------
Indirect Benefits and Impacts
The improvement in fuel economy that results from an I/M program is an
important benefit for vehicle owners. The vehicle owners view the fuel savings
as an individual economic issue, whereas the total or aggregate fuel savings
is actually an important energy conservation savings as well.
The cost savings that result from the improvement in fuel economy, the
better engine performance and increased longevity may not be readily apparent
to the individual motorists, although the fleet owners who have good long-
term records will be able to perceive these benefits over time. It is impor-
tant, therefore, that the motoring public be made aware of these benefits.
On the other hand, the obvious costs of repairs for failed vehicles will
be readily apparent to the vehicle owners. The question arises, however, as
to how much of these repair costs should be directly attributable to the I/M
program. While it is true that a vehicle owner may be required to make a repair
if his vehicle does not comply, it is inappropriate to charge the entire cost of
mandated repairs to I/M requirements. I/M will cause vehicles to be repaired
more completely and frequently than they would be without it. Indeed, this
is the purpose of I/M. But a fraction of the repair cost would have been
incurred regardless. Estimates of the magnitude of this fraction vary from
25 to 75 percent.
This issue of mandated repairs is central to I/M program externalities.
The costs of these repairs are a burden on the vehicle owner. These costs
will not be distributed evenly throughout the population. It is safe to assume
that older vehicles will generally be owned by individuals at the lower end of
the economic spectrum. These vehicles are more likely to require repairs than
newer vehicles. If these vehicles fail to meet I/M standards more frequently
than newer vehicles, the burden of I/M could fall unevenly on lower income
segments of the population. This uneven impact is partially mitigated by es-
tablishing exemptions to compliance based on vehicle age and ceilings on the
dollar value of mandated repairs.
As the vehicle mix changes over time, this problem will become less
severe than it may be now. As older vehicles, those that are costly to main-
tain to standards, dropout of the vehicle population, they will be replaced
by used vehicles that have been included in the mandatory I/M program are,
therefore, likely to be in better overall condition. It can be expected that
these vehicles would require less expensive maintenance throughout their
serviceable life.
This trend will be countered to a certain extent because vehicles filtering
down via resale will be equipped with various emissions control devices. This
equipment has been covered by a 50,000-mile warranty by manufacturers as a
result of federal warranty requirements. The useful life of emission control
devices covered by warranty is not presently known. Of course, if these devices
prove to be as durable as the vehicles in which they are installed, they will
not create extra repair costs as these vehicles age. Should they require
replacement after 50,000 miles but prior to the end of a vehicle's life, the
cost of doing so will fall on the used car owner who is generally in a lower
income category than the initial purchaser. Replacing control devices could
27
-------
become costly. Thus, if these devices do require extensive maintenance to be
kept operating correctly near the end of a vehicle's life, I/M may impose a
greater financial burden on the used vehicle owner than it will on the public
at large. If this proves the case, it will add another reason for exempting
vehicles reaching a certain age.
Establishing an accurate average cost for repairs that are induced by I/M
is difficult. General data from existing programs can provide a starting point
in contemplating the magnitude of this figure. For California's Riverside
Trial Program, the average repair cost for a vehicle failing inspection,
including parts, tax and labor was $11.42 when adjusted to remove voluntary
repairs made at the time required repairs were performed.7 This figure applies
repair costs for a 40 percent stringency rate over the entire vehicle popu-
lation tested. Average repair values for California were $27.33 and $32.08
for idle- and loaded-mode testing. In a similar study in Michigan these figures
were $23.29 and $36.56.8
In these studies, the repair costs directly attributable to I/M may not
be accurate. This is for two reasons. One reason, mentioned earlier, is that
some of these repairs would have been made anyway, even if the I/M program
was not in existence. Second, no accounting is made, nor can it be made with
current data, of extra repair costs incurred in anticipation of inspection.
It is likely that some vehicles that pass the first time through inspection
have attained higher maintenance standards than they would have otherwise in
order to avert failure and the inconvenience of traveling to the inspection
site a second time for retesting.
The nature of repairs required to meet I/M standards for failed vehicles
can help shed light on the burden noncomplying vehicle owners must bear. The
Riverside Trial Program found that 66 percent of the diagnosed repair evalua-
tions consisted of an imbalance in the idle air-to-fuel ratio. An additional
18 percent of vehicles failing were diagnosed as experiencing rich carburetion.
These problems are neither difficult nor costly to rectify. Thus, the average
repair cost figures may be somewhat misleading. Most vehicles requiring service
will experience costs lower than the average reported figure. A small portion
will have bills considerably in excess of the average reported figure. If
these bills fall into waiver regions (either an absolute dollar limit on repair
cost or a percentage of vehicle value figure), then assuming an average repair
cost for all failed vehicles can overstate the total repair cost burden to
vehicle owners; that is, the total cost of required repairs (those that do not
exceed cost limit categories) may be less than the total cost of repairs re-
ported by an I/M sequence.
There are other costs to vehicle owners relating to I/M in addition to
repair costs and the vehicle inspection fee. Two major costs to consider are
time and operating costs experienced traveling to and from inspection sites.
Actual operating costs can be calculated fairly accurately. Time costs have
a much more subjective nature.
The vehicle miles traveled (VMT) induced as a result of an I/M program
depend on the size of the affected vehicle population, density of that popu-
lation, siting of inspection stations, and so forth. Estimates of total induced
28
-------
VMT can be used to determine total vehicle operating costs and time spent on
those induced VMT. Applying an average emission level to these extra VMT can
provide a rough estimate of emissions induced by the implementation of I/M.
An elusive but probably a more significant figure Is the time cost of
travel to and from, and waiting time at inspection facilities. There are
evaluative decisions about the value of time spent traveling, waiting time,
and so on that must be resolved before a dollar figure can be computed. The
issue is complicated because different people value their time differently
and even value different types of time differently (e.g., time spent driving
versus time spent waiting at an inspection site). The value an individual
places on his time is related to his income level. As income rises, an in-
dividual tends to value his time more highly.
Estimating operating and time costs is further complicated because it is
difficult to determine what portion of these costs to assign directly to I/M
requirements. Many times the trip to an inspection site is combined with
other errands and stops. The total costs, time and operating, of such trips
should be allocated between the different purposes served by them. It is also
difficult to determine how circuitous the I/M stop is. It may require a sub-
stantial detour in some cases and none in others.
A potential benefit for the vehicle owner is money saved by utilizing
diagnostic information provided by I/M to correct small problems before they
become serious. By prompting repairs early-on, I/M can help eliminate substan-
tial costs to the vehicle owner.
This brief overview of the impacts I/M may have for vehicle owners serves
to emphasize the complex nature of program costs and benefits. A qualitative
evaluation of them helps assure that they will be considered when implementing
I/M.
Impact on the Automotive Repair and Parts Industry
It is safe to state that I/M implementation will result in an increased
demand for repair activities and replacement parts. To the extent that I/M
induces new repairs that would not have been performed otherwise, the repair
industry will directly benefit from the program. Additionally, I/M will
place a requirement on the repair industry regarding training; that is, since
new types of repairs will be in demand, it is necessary for the repair industry
to become trained to perform these repairs. Mechanic training program require-
ments are discussed in detail in Section 5.
Job creation will be necessary to increase the supply of repair personnel
to meet new demand. The ratio of mechanics to vehicles has been declining
significantly over the last few decades. In 1950 there were 73 vehicles for
every mechanic nationwide. By 1975 this ratio decreased to one mechanic
available for every 146 vehicles. This trend cannot continue if I/M becomes a
reality. As emissions regulations increase, vehicle complexity will extend
repair times for existing components. New subsystems will also be created that
will eventually require repair and the demand for mechanic time will increase
for each vehicle.
29
-------
In addition to recruiting and training new mechanics, existing personnel
should undergo at least a limited retraining phase to orient them to the pur-
poses and goals of I/M and emissions control. In some cases the needs of I/M
are in conflict with maintenance standards now existing that emphasize high
engine performance. It is important that the repair industry be aware of the
different criteria demanded by I/M so that appropriate repairs can be made.
No matter how responsive the supply of mechanics is to this increase in
demand, some lag is inevitable. Because of this, windfall profits may accrue
to existing members of the industry for an initial time period. The tight
supply situation could result in some overcharging. This should be brief, as
new mechanics will be trained and in turn enter the labor pool as the public
becomes aware of the implications of I/M. As the supply of repair personnel
expands, the consumer will again be able to choose among many repair shops.
This will make overpricing practices more difficult.
30
-------
REFERENCES
1. Bayler, Ted and Leslie Eder. Impact of Diagnostic Inspection on Automo-
tive Fuel Economy and Emissions. National Highway Traffic Safety Adminis-
tration, Washington, D.C. 1978.
2. Bureau of Vehicular Emissions Inspection, Arizona Vehicular Emissions
Inspection Program Operation, Arizona Department of Health Services.
April 1978.
3. Arizona Department of Health Services. There's Something New in the
Air This Year. Arizona Vehicle Inspection Program.
A. Elston, John. New Jersey's Auto Emission Inspection Program: An Assess-
ment of One Year's Mandatory Operation. Department of Environmental
Protection. Paper Presented at the Fourth North American Motor Vehicle
Emission Control Conference, Anaheim, California. November 5 through 7,
1975.
5. Walker, D.L. et al. How Passenger Car Maintenance Affects Fuel Economy
and Emissions: A Nationwide Survey. Champion Spark Plug Company, 1978.
6. Panzer, J. Fuel Economy Improvements Through Emissions Inspection/
Maintenance. Exxon Research and Engineering Company. 1976.
7. Vehicle Inspection Program Staff, Bureau of Automotive Repair. Volume 2,
Summary Report, California Vehicle Inspection Program Riverside Trial
Program Report. Operations From 9/2/75 to 2/13/76.
8. Grad, F.P., et al. The Automobile and the Regulation of Its Impact on
the Environment. University of Oklahoma Press. Norman, Oklahoma. 1975.
31
-------
SECTION 4
NETWORK AND PERSONNEL REQUIREMENTS
I/M NETWORK
In order to derive network requirements for an I/M program to be estab-
lished by 1982, it is necessary to make reasonable estimates as to the size of
the vehicle population to be served by such a program. Not all motor vehicles
registered in the affected counties will be subject to inspection; for various
reasons, certain vehicle classes have been exempted. These are: those
vehicles having a gross weight of over 8,000 pounds, those vehicles registered
as farm trucks, those vehicles over 15 years old (tentatively), and special
purpose vehicles such as prototypes or experimental models.
Using detailed county vehicle registration data provided by the Wisconsin
Department of Transportation, estimates were made of the 1982 and 1987
inspectable vehicle populations using two different methods. The 1982 and
1987 figures are of interest because the Clean Air Act Amendments of 1977
require full program implementation by 1982, and network facilities will be
designed to meet the demands of the 1987 vehicle population. One method of
projection is to take the 1978 inspectable vehicle population for each of the
nine counties and increase it at a constant annual rate of 3 percent. This
growth rate approximates the annual statewide growth in registrations; using
this method results in a 1982 projection of 1,329,209 and a 1987 projection
of 1,540,918 inspectable vehicles in the nine counties.
While a constant annual growth rate of 3 percent may be useful in making
statewide vehicle population estimates, it may create problems when applied to
county statistics. Since county registration data back to 1945 were available,
it was possible to calculate annual growth rates in registrations for each
county using the formula:
. , „ „, n _ 1/5 In / 1978 vehicle population \
Annual Growth Rate = e I • ^- rr—: r v , „ . I
\1973 vehicle population/
The growth rates, in percent per year, are shown in Table 6. It can be seen
from this table that although some counties, such as Brown and Dane, have
experienced growth rates at or near the 3 percent level, other counties such
as Milwaukee, have growth rates significantly less, or, like Ozaukee and
Waukesha, have growth rates significantly greater than 3 percent. As a
result, applying these county growth rates to their 1978 inspectable vehicle
populations yields 1982 and 1987 estimates which are somewhat different from
32
-------
those derived with the constant 3 percent method. The 1987 inspectable vehicle
populations derived using both methods are presented in Table 7.
TABLE 6. ANNUAL GROWTH RATE, INSPECTABLE
VEHICLE POPULATION, 1973 TO 1978
County
Brown
Dane
Kenosha
Milwaukee
Ozaukee
Racine
Walworth
Washington
Waukesha
Annual
growth rate, %
3.198
2.993
1.695
0.855
4.397
1.822
2.153
4.530
4.342
TABLE 7. 1987 INSPECTABLE VEHICLE POPULATION, USING
TWO DIFFERENT PROJECTION METHODS
County
Brown
Dane
Kenosha
Milwaukee
Ozaukee
Racine
Walworth
Washington
Waukesha
Total
Method I
117,789
219,871
84,772
638,456
48,608
121,438
50,530
56,528
202,836
1,540,918
Method II
119,335
221,928
76,908
523,051
56,516
109,278
46,831
66,073
235,399
1,455,319
33
-------
The annual capacity of a contractor (or state) operated emissions inspec-
tion lane can be calculated given the vehicle throughput time, the number of
inspection hours per year, and an efficiency factor to account for equipment
downtime, random arrival of vehicles, etc. If it is assumed that throughput
time is 2 minutes, the facility is open for business 40 hours per week, 52
weeks per year, and the facility operates at 67 percent of its total potential
efficiency, then the annual capacity of an inspection lane is:
(2 min/inspection) (4° hr/wk) (52 wk/yr) (0t67) = 41'808 inspections/yr
Due to the fact that the inspection cut points will be set such that 20
percent of those vehicles inspected will fail and require reinspection, the
total number of inspections performed in 1987 will be 1.2 times the figures
reported in Table 7. Table 8 shows the total number of inspections re-
quired in each of the nine counties in 1987 using both projection methods.
Dividing these totals by 41,808, the annual capacity of an inspection lane
yields the total number of lanes required in each county in 1987, the design
capacity of the system. In only two out of the nine counties, Milwaukee and
Waukesha, will the number of lanes required differ between the two projection
methods. In both cases the Method II projection is preferable, since it more
accurately reflects historical trends ignored by Method I. Milwaukee's ve-
hicle population has been growing much slower than the 3 percent statewide
average, and Waukesha1s vehicle population has been growing much faster than
average. Human population statistics and projections also bear out these trends,
TABLE 8. INSPECTIONS REQUIRED, 1987
County
Brown
Dane
Kenosha
Milwaukee
Ozaukee
Racine
Walworth
Washington
Waukesha
Total
Method I
141,300
263,800
101,700
766,100
58,300
145,700
60,600
67,800
243,400
1,848,700
Method II
143,200
266,300
92,300
627,700
67,800
131,100
56,200
79,300
282,500
1,746,400
34
-------
Table 9 shows the number of lanes required in each county to handle
projected 1987 inspection demands.
TABLE 9. INSPECTION LANES REQUIRED, 1987
County
Brown
Dane
Kenosha
Milwaukee
Ozaukee
Racine
Walworth
Washington
Waukesha
Lanes required, 1987
4
7
3
15
2
4
2
2
7
Total 46
In locating the inspection facilities, the following methodology was used:
first, due to the problems associated with locating suitable large parcels,
maximum facility size was limited to six lanes; second, due to diseconomies
of scale of one-lane facilities, minimum facility size was set at two lanes;
third, the facilities were located in or near the population centers of their
respective counties to maximize consumer convenience. Given these three site
selection criteria, Table 10 shows facility configurations and general site
locations.
For purposes of cost analysis, it is useful to calculate the average ve-
hicle population inspected between 1982 and 1987. Table lOa shows the number
of inspections required in each year (using Method II) and the average for the
5-year period.
PERSONNEL REQUIREMENTS
The personnel requirements for the entire program can be described in
terms of either operating personnel (i.e., those directly involved in or sup-
porting the inspection process), and program administrative personnel (i.e.,
administrators, legal council, accounting personnel, other indirect support
personnel, etc.). The requirements for both types of personnel are discussed
separately in the following paragraphs.
Operating Personnel
Based on both an analysis of the tasks involved in conducting the actual
emissions test, and the experiences of the I/M programs currently in operation,
35
-------
TABLE 10. INSPECTION NETWORK
County
Brown
Dane
Kenosha
Milwaukee
Ozaukee
Racine
Walworth
Washington
Waukesha
Total
Facility
4- lane
4- lane
3 -lane
3-lane
6 -lane
6 -lane
3-lane
2-lane
4-lane
2-lane
2-lane
4-lane
3-lane
46 lanes ,
Location
Green Bay
Madison
Madison
Kenosha
Milwaukee
Milwaukee
Greenfield
Meguon
Racine
Elkhorn
West Bend
Brookfield
Waukesha
13 facilities
Table lOa. INSPECTIONS REQUIRED 1982 TO 1987
Year
1982
1983
1984
1985
1986
1987
Inspections required
1,296,000
1,327,000
1,358,000
1,389,000
1,422,000
1,455,000
Average
1,375,000
36
-------
the basic personnel requirements for the test facility operation was derived.
The general requirements are for:
• one manager and one assistant manager for each test facility;
• three inspectors for each test lane; and
• one maintenance/calibration person for every 10 lanes
Applying these to the network requirements shown in Table 10 results in the
operating personnel requirement shown in Table 11. These requirements are
identical for both the state-run and the contractor-run option.
Administrative Personnel
The following paragraphs provide a description of a proposed administrative
structure that could be utilized for the program being assessed here. The
structure described here is based both on an analysis of specific tasks and
responsiblities associated with implementing and operating the program, and
on information concerning other I/M programs that are currently in operation.
While most of the personnel described in this section would be employed
directly by the state, it is not likely that all positions would require new
personnel; rather, it is likely that existing personnel could assume some of
the responsibilities.
The basic administrative structure is shown in Figures 8 and 9 for the
state-run option, respectively. As can be seen for either figure, the overall
structure is organized under a Department Secretary (most likely the Secretary
of either the Department of Transportation or of Natural Resources) who
would hold ultimate responsibility for the program. Reporting to the Secretary
would be the Program Administrator, who would be responsible for operating the
program in accordance with administrative rules set by the Departments of Trans-
portation and Natural Resources.
An advisary Task Force comprised of members of all departments directly
involved in the program would provide technical imput to the Director. These
individuals would be concerned with issues such as setting standards, defining
exemptions, advising on policy matters, etc. Also, the responsibility for
monitoring the effectiveness of the program would be delegated to the Task
Force.
The Administrator would also be supported by an Engineering Coordinator
and a Legal Advisor. The Engineering Coordinator would be responsible for
overseeing the design and construction of inspection facilities and the
selection and purchase of equipment. This would not be a permanent position;
however, the position would be required only during the design and construction
phase of the program startup. The Legal Advisor would not be a full-time
position although it is conceivable that there would be an occasional need for
these services. In all likelihood, this position would be filled from existing
resources within the state government. The function of the Legal Advisor would
be to advise the Administrator and the Task Force on all matters concerning
the legal aspects of the program.
37
-------
Table 11. OPERATING PERSONNEL REQUIREMENTS
OJ
03
Position
Facility manager
Assistant manager
Emissions inspector
Maintenance/calibration
persons
Number of
individuals required
per lane or facility
1 per facility
1 per facility
3 per lane
1 per 10 lanes
Number of
lanes - facilities
13 facilities
13 facilities
46 lanes
46 lanes
Number of
persons required
13
13
138
5
-------
VO
DEPARTMENT SECRETARY
PROGRAM ADMINISTRATOR
I/M TASK FORCE
CLERICAL SUPPORT
CONSUMER PROTECTION/
QUALITY/ASSURANCE
COORDINATOR
QUALITY ASSURANCE;
INVtSTIGATOR
CONSUMER PROTECTION
INVESTISATO*
HOT LINE OPERATOR/
CLERK
ADMINISTRATIVE FUNCTIONS
r ^^r ^M» .^ar ^mr .^^f ^^r ^*t* ^•^.Miw^^v ^^f **+^
OPERATIONAL. FUNCTIONS
NOTES
0. REQUIRED DURING START-UP ONLY
b. NOT A FULL-TIME POSITION
Figure 8. Suggested administrative structure for the state-run option.
-------
COORUINATOR ANALYST COOKIMN.IOK COORDINATOR 1^1 | |
1 SJg PURCHASING TRAINING DATA
512 COHTNACTl TRAJNIRS DATA
ACCOUNTANT J> | Vl OPHCtR COORDCNATOR ANALYSIS
1 1 S1'*-
QUALITY ASSURANCE CONSUMER PROTECTION . 1 1~
INVIST16ATOB INVESTICATOH k! 1^*
*j
1HOT LINE OPERATOR/
Ct-fr
tOHIMISTRtT/VE FUNCTIONS
OPERATIONAL FUNCTIONS
NOTES INSPECTION
a REQUIRED OURIIM START-UP ONLY STATION
b NCT A PULL -TIME POSITION MANAGERS
Figure 9. Suggested administrative structure for the contractor-run option.
-------
The Training Coordinator would be responsible for establishing and
implementing training programs for both mechanics and personnel involved in
the inspection program (except contractor personnel). This position would
not require full-time effort; rather, an occasional effort would be needed
both during program startup and during the actual operation of the program.
An Information Systems Analyst would be responsible for developing the
software to be used in the overall data collection system and for providing
periodic summaries concerning the program operation (e.g., percent failures,
emission characteristics of vehicles tested, etc.) as requested by the
Administrator or others. Also, he would be responsible for the day-to-day
data processing effort.
Overall responsibility for the program finances would be held by the
Financial Coordinator. For the state-run option, this position would be a
full-time and would be supported by an Accountant. For the contractor-run
option, the Financial Coordinator would not be a full-time position, and
there would not be a need for the Accountant position.
A full-time Consumer Protection/Quality Assurance Coordinator would be
required to administer the quality control and consumer protection aspects
of the program. Subordinate to the Coordinator would be two Investigators,
one for quality assurance and one for consumer protection, and a Hot-Line
Operator.
The contractor-run option would require a slightly different organizational
structure as shown in Figure 7. The primary difference is that several
additional personnel would be required, but these would be involved individuals
hired by and working directly for the contractor rather than being state
personnel.
The administrative personnel requirements are summarized for both the
state-run and contractor-run options in Table 12. This table indicates the
number of positions and the approximate level of activity during both program
startup and operation associated with each option. Again, this is a suggested
structure and should be viewed as such. It does, however, reflect the desire
to minimize the number of personnel involved in administrating the program,
and in this context reflects the minimum personnel requirements; the impact
of minimizing the program staffing is discussed in the following section.
41
-------
TABLE 12. ADMINISTRATIVE PERSONNEL REQUIREMENTS FOR STATE-RUN
AND CONTRACTOR-RUN OPTIONS
Position
Administrator
Training Coordinator
Legal Advisor
Engineering Coordinator
Data Systems Analyst
Financial Coordinator
Accountant
Consumer Protection/
Quality Assurance Coordinator
Consumer Protection
Investigator
Quality Assurance
Investigator
Hot Line Operator/Clerk
Clerical
Station Operations
Superintendent ^
Legal Advisor
Purchasing/Contract B
Officer^
Engineer Analyst
Inspector Training
Coordinator*
Clerical5
State-run option
Startup
phase
1 full-time
1 half-time
1 quarter-time
1 three-quarter time
1 occasionally*
1 full-time
1 quarter-time
1 half-time
1 occasionally*
1 occasionally''1
no requirement
2 full-time
_
-
_
-
_
-
Operational
phase
1 full-time
1 half-time
1 occasionally*
no requirement
1 full-time
1 full-time
1 full-time
1 full-time
1 full-time
1 full-time
1 full-time
2 full-time
.
-
_
-
_
-
Contractor-run option
Startup
phase
1 full-time
1 full-time
1 quarter-time
1 half-time
1 occasionally*
1 half-time
no requirement
1 half-time
1 occasionally*
1 occasionally*
no requirement
1 full-time
1 full-time
1 half-time
1 full-time
1 full-time
1 occasionally*
1 full-time
Operational
phase
1 full-time
1 half-time
1 occasionally^
no requirement
1 half-time
1 half-time
no requirement
1 full-time
1 full-time
1 full-time
1 full-time
1 full-time
1 full-time
1 occasionally
1 full-time
1 full-time
no requirement
1 full-time
All personnel would be employed by the state.
All personnel would be employed by the state except thoae in positions denoted with
'indicates less than quarter-time.
Personnel would be employed by the private contractor.
42
-------
SECTION 5
ADJUNCTIVE PROGRAMS
INTRODUCTION
This section describes the adjunctive or basic support program elements.
It includes quality assurance, mechanic training, consumer protection, public
convenience, mechanic training, enforcement and public relations. What they
have in common is that they all enhance the effectiveness of the I/M program.
This includes the following functions:
• quality assurance increases the quality and uniformity of the
emission inspection and repair process
• mechanic training increases the quality of the emission repairs
• consumer protection protects the consumer from unneeded repairs
or inequities in the testing
• public convenience mimimizes travel time and waiting at the
inspection lanes
• enforcement ensures a maximally effective system to ensure
compliance
• public relations provides comprehensive information to the
public on the needs, benefits, and procedures of the I/M program
It is important to realize that these adjunctive programs interrelate and
overlap to a high degree. Some of the adjunctive program elements may serve
multiple purposes. For example, mechanics training serves to increase the
quality control of the repair or maintenance phase of the program, serves as
an important consumer protection element by encouraging more uniform, less
expensive emission tuneups and also may serve as a public relations mechanism
by orienting the mechanics to the purpose and benefits of the overall I/M
program. Given the multiple purpose nature of many of the adjunctive pro-
grams then, there is necessarily some overlap in the discussions.
The methodology consisted of two basic elements. The first element was
an analysis of the overall inspection and maintenance process in reference
to each adjunctive program element. The second part was extensive research
into all published sources of information on the program being investigated.
43
-------
This also included contacts and visits to various I/M programs around the
country, calls to various governmental agencies especially the U.S. Environ-
mental Protection Agency which has conducted or sponsored much of the research
and set the basic policy for I/M programs, and finally contacts with companies
currently running I/M programs such as Hamilton Test Systems in Arizona as
well as emission inspection equipment manufacturers.
CONSUMER PROTECTION
An effective consumer protection program is highly important for a suc-
cessful I/M program. It is important from the point of view of protecting
the public from unnecessary costs and inconveniences and equally important in
securing general public acceptance and avoiding a significant buildup of adverse
publicity. Among such consumer protection and convenience measures are public
relations elements, although the primary aim of these elements is ensuring pro-
tection from inequities in either the inspection or the maintenance phase of
the program. In this discussion, consumer protection will be dealt with first
and then, consumer convenience.
Consumer protection mechanisms are generally of two types. First, there
are specific active procedures set up to deal with consumer complaints as they
occur. These are the consumer hot lines and complaints investigators. Second,
there are features built into the system that directly or indirectly protect
consumers from potential inequities or abuses. These include state motor
vehicle repair regulations, repair cost ceilings, waivers or exemptions, repair
facility or mechanic licensing or approval, and warranty regulations (both
federal and state).
Existing Consumer Protection Mechanisms
Before discussing the specific consumer protection mechanisms to be added
for the I/M program, it is important to describe the various regulations and
mechanisms that already exist in Wisconsin.
Consumer complaints concerning improper, inadequate or overpriced repairs
(exceeding $25.00) in any private repair facilities, except fleet repair
stations, are currently handled by the Trade and Consumer Protection Division
of the Department of Agriculture. The authority to regulate the repair prac-
tices of private facilities was established by the Wisconsin Administrative
Code Chapter (Agriculture) 132, entitled "Motor Vehicle Repair." According to
these regulations, which became effective on September 1, 1975, repair faci-
lities are required to obtain repair orders and provide price estimates for
repairs exceeding $25. They also require specific authorization for doing any
work not requested by the customer. The law prohibits the repair shop from
collecting for repairs not authorized by the customer, repairs known to be
unnecessary, or repairs that should not have been made, Also, the shop is
required to keep detailed records of repairs made, charges, parts used, etc.
This law, if enforced properly, would clearly go a long way towards providing
the consumer protection needed in an I/M program.
44
-------
The Department of Transportation, Dealer Inspection Unit, handles com-
plaints for new and used motor vehicle sales. Automobile sales through dealers
are regulated by Wisconsin Administrative Codes, Chapter MVD 24, Motor Vehicle
Trade Practices. According to this law, new car dealers must furnish to the
customer prior to the delivery of any new motor vehicle a copy of the pre-
delivery test and inspection made pursuant to the manufacturer's specifica-
tions. The law also requires that all used car dealers specify in writing
prior to sales all significant existing mechanical and structural defects.*
Such regulations would give the consumer better knowledge prior to purchase
as to whether the car will require extensive repairs. Finally, this statute
also requires that prior to sale, all existing warranty provisions for new
and used cars be brought to the attention of the purchaser. This provision
would help in the implementation of the Federal 207(b) warranty on emission
controls, which is discussed below in the Warranty section.
Consumer Hotlines
Consumer hotlines would serve two important functions. First, they would
provide valuable information to the public regarding basic operating times and
locations of the inspection lanes, procedures, consumer rights and obligations,
and other related information. Second, and equally important, the hotlines
would be centralized referral points to guide the consumer after an evaluation
of his problem to the correct department. In many cases, all that may be needed
is correct information, but when a significant problem requires the attention of
a particular department, the consumer can then be routed to the right office.
Also, the hot line personnel are trained in dealing with the public and thus
can make a significant contribution to the overall public relations effort of
the overall I/M program. It is very important that all contacts between the
public and I/M personnel be smooth and harmonious, especially given the some-
what controversial nature of the program. In Wisconsin, the hotlines them-
selves would likely be manned by the Department of Transportation.
Complaints Investigation
Some of the problems reported to the hotlines operated by the Department
of Transportation would require referral to other departments, depending on
the nature of the complaint. As an example, complaints that require legal
actions would be routed to the Attorney General's office. Of course some
problems would presumably involve more than one department's involvement.
Any problem could potentially involve the Attorney General's office at some
point if illegal proceedings were uncovered that required legal action or
resolution. Hopefully, most problems could be resolved without resort to
legal action. The types of problems and organization in the appropriate
department are discussed below.
*
Among the items requiring disclosure prior to sale are the emissions and
exhaust and fuel systems.
45
-------
Complaints Regarding Centralized Inspection Lanes—
The Department of Transportation would handle complaints regarding the
inspection process conducted by the state or contractor in the centralized in-
spection lanes. The Quality Assurance Investigator would visit the contractor
(or state) inspection stations at least every 90 days or at random intervals.
Presumably the investigator would check any stations or individual analyzers
that are giving undue numbers of passes or failures.
Complaints Regarding the Repair Industry—
As indicated above, the Department of Agriculture currently has regulations
governing the repair of motor vehicles. The Department's Trade and Consumer
Protection Section would likely continue in its function of assuring that cor-
rect procedures are followed regarding repair orders, repair price information,
estimates, and repair authorization. These procedures would play an important
role in keeping the repairs within reasonable cost limits and protecting the
consumer from unnecessary repairs. Investigations of specific complaints in
repair shops would be conducted by the Consumer Protection Investigator.
Attorney General's Office—
The Wisconsin Attorney General's office would not be involved in most
complaints. The Attorney General's office would become involved in prosecution
of more serious cases of consumer fraud or when there were repair facilities
that had serious and continued records of violations of the regulation governing
motor vehicle repairs, emission inspections, or tampering.
Repair Costs Limits
The repair cost limit is a maximum cost that a motorist may be obligated
to spend on repairs for his motor vehicle in order to meet the emission stan-
dards . This cost ceiling helps to prevent the program from becoming an exces-
sive burden on those vehicle owners in lower income brackets especially. Also,
on certain vehicles the cost of complying may be so great as to make operation
prohibitively expensive. However, it should be clearly stated that the vehicle
owner is in no way compelled to keep the repairs below the specified limit.
For those who can easily afford the extra costs or who desire to achieve full
compliance, there should be strong encouragement to do so.
Repair costs may be cumulative. In some cases a motorist may fail the
retest and return to the repair shop again for repairs. The repair cost limit
applies to the cumulative emission repairs for the entire sequence within a
specified time limit after failing the emission test.
Repair cost limits are generally of two types. First, an absolute dollar
limit and second, a sliding scale related to the value of the vehicle. In the
first approach generally a fixed upper limit of from $50 to $100 is set which
applies to all vehicles regardless of their age, conditions, or resale value.
In the second approach, which in theory would be more equitable, the price
ceiling relates to the vehicle value as determined by an accepted reference
such as the used car Blue Book of average retail prices. The Minnesota I/M
revised statute, Section 5, reads as follows:
46
-------
"Maximum Repair Cost, l(a) The maximum repair cost for meeting
emission standards, not covered by any warranty, shall be as
follows: a motor vehicle having a value of $2,000 or less, $50,
for each full $500 of vehicle value over $2,000, an additional
$10. Motor vehicle values shall be determined as provided in
Minnesota Statutes, Section 168-013,"
Wisconsin has tentatively selected a $50 repair cost limit. The data shown in
Table 13 indicate that this limit would cover 80 to 90 percent of the average
repair costs. If the repair cost limit is specified in the legislation it
should allow for periodic revision to reflect the average repair costs actually
experienced in the Wisconsin I/M program plus the effect of inflation,
Waivers and Exemptions
Granting of waivers or exemptions for specific vehicle types, in addition
to vehicles exceeding the repair cost ceiling, is another consumer protection
mechanism. Wisconsin has tentatively chosen to exempt vehicles older than 15
years and experimental vehicles. Exemptions of vehicles over a certain age is
a commonly used method to protect owners from undue financial hardships. The
older vehicles generally cost more to bring into compliance and are more likely
to need extensive repairs such as ring or valve jobs. Moreover, given the small
fraction of the total vehicle population that they represent, such exemptions
entail a minimum sacrifice in overall emission reduction benefits. Other ve-
hicle types commonly given exemptions are electric, experimental, antique, and
off-the-road vehicles, The major considerations when judging whether any par-
ticular vehicle type should be exempt would be the potential hardships on ve-
hicle owners, balanced by effects on overall emission reductions,
Licensing, Certification, or Approval of Repair Facilities and Mechanics
Licensing or certification of repair shops and mechanics are mechanisms
for ensuring that repairs are done adequately and at a reasonable cost to the
consumer. As such, they may be important as consumer protection elements.
The type and degree of regulation of private industries such as repair shops
by state government is a sensitive issue but given the need to ensure protec-
tion of the consumer and the adequacy of repair, some type of interaction or
influence on repair industry practices is crucial. An active mechanic training
program in emission-related tuneup and emission repairs has been shown to have
a very beneficial impact on upgrading mechanic skills and fostering a positive
attitude toward emission control. Mechanic training will be discussed later
in this section.
Most states and repair industry groups do not look favorably at formal
licensing of repair shops and mechanics; rather, they view it as expensive
interference in private industry. Of course, when the repair facilities are
designated as official inspection stations then some sort of official licensing
and close supervision is very important for both consumer protection and quality
assurance considerations. However, in the centralized state and contractor
approaches being considered in Wisconsin, the same degree of state supervision
is less critical. Generally there are two reasons for needing some supervision
47
-------
TABLE 13. I/M REPAIR COSTS
New Jersey Oregon
Less than $10 29.7% No cost 27%
$10 - $25 26.4% $0 - $10 37%
$25 - $50 22.1% $10 - $30 18%
$50 - $100 16.1% $30 - $50 8%
Over - $100 5.6% $50 - $75 5%
Over $100 2%
N = 16,000
Average repair costs = $32.40 N = 1400 (primarily newer cars)
Median - 50% of repairs cost Average repair costs = $16.00
less than $20 Median - 50% of repairs
65% of repairs cost less than cost less than $8
the average 71% of repairs cost less than
the average
Arizona
Less than $5 27%
$5 - $10 17%
$10 - $25 24%
$25 - $50 20%
$50 - $100 10%
Over $100 2%
N = 2000
Average repair cost = $23.40
Median — 50% of repairs cost less
than $15
64% of repairs cost less than average
Failure rates - New Jersey - 12% (annual)
Arizona - 16% (annual)
Oregon - 36% (biannual)
48
-------
or influence on the private repair facilities: emission analyzer calibration
and accuracy and control of unauthorized repair practices. Rather than formal
licensing of repair facilities, by which is meant that only licensed facilities
could perform emission repairs, a lesser degree of control in the form of certi-
fication or approval would be appropriate. Given the need for using reasonably
accurate and reliable analyzers, many states publish lists of approved emission
analyzers. New Jersey has one such list. A repair facility may become approved
or certified if it utilized an approved analyzer. In addition, the state may
require that the facility employ emission tuneup mechanics who have taken
approved mechanic training courses. Furthermore, the state could have each
approved analyzer calibrated at regular intervals.
The I/M Task Force has indicated that it is reluctant to endorse further
State regulation of the auto repair industry at this time, therefore, a certi-
fication program is currently not being considered. It is recommended here,
however, that consideration be given to at least a minimal program consisting
of very elemental components that, in the aggregate, serve more to provide
incentives to the repair industry rather than place controls on it. A minimum
program would include recognizing repair facilities that employ mechanics who
have completed the State mechanic's training program and also are equipped
with a suitable exhaust analyzer. Recognition could, for instance, be merely
distributing lists of these repair facilities to motorists who fail the emission
inspection and therefore will need to have repair work done. Obviously, it
would be to the advantage of a repair facility to be included on the list,
therefore an incentive would exist for not only participating in a training
program, but for ensuring that reasonable repair work is being performed as
well.
WARRANTY PROTECTION
In Wisconsin consumers would be protected by both state and federal war-
ranty programs. Prospective buyers of new and used vehicles are protected under
Wisconsin Administrative Code MVD 24, Motor Vehicle Trade Practices with respect
to warranties in the following manner: the dealer must provide for each used
vehicle the basic terms and conditions of warranty, if offered, displayed in
a conspicuous place; if the sale of a motor vehicle is made subject to a
warranty, such warranty must be in writing and must be provided to the buyer
prior to or at the time of purchase and must include all the basic information
on the terms, coverage, and exclusions of the warranty; it is an unfair prac-
tice and prohibited for a warrantor to fail to service or repair a motor vehicle
in accordance with the terms and conditions of the warranty or service agree-
ment. The enforcement of these warranty provisions is handled by the Depart-
ment of Transportation, Dealer Inspection unit. The enforcement of these pro-
visions is especially important in view of the possibility of the failure of
emission control equipment such as the catalytic convertors whose replacement
This presupposes that an additional consideration as to whether or not a par-
ticular service facility would be listed is the quality of repairs and integ-
rity of the business as judged by reinspection results and feedback from
consumers through complaints.
49
-------
could become a significant burden on the public, if unregulated through warran-
ties. Also, since the ability of in-use vehicles to maintain the emission
standards for which they were designed depends largely on the integrity of the
catalytic converters it is significant to have a mechanism that ensures that
failed equipment will be identified and replaced. This problem was recognized
by the Clean Air Act Amendments warranty provisions in Section 207(b).
The intent of the Federal Clean Air Act 207(b) warranty provisions was to
ensure that the basic emission control equipment be manufactured such that it
would last up to 50,000 miles or 5 years, whichever came first. As such 207(b)
may be seen as an incentive to the manufacturers to design the basic emission
control equipment to last at least up to the end of the warranty period if not
longer. There is still much debate about what should be the best warranty
period and suggestions have been made to have the warranty extended to the
entire useful life of the vehicle or 100,000 miles. The actual wording of
section 207(b) is as follows:
"(b)If the Administrator determines that (i) there are available
testing methods and procedures to ascertain whether, when in ac-
tual use throughout its useful life (as determined under section
202(d), each vehicle and engine to which regulations under section
202 apply complies with the emission standards of such regulations,
(ii) such methods and procedures are in accordance with good
engineering practices, and (iii) such methods and procedures are
reasonably capable of being correlated with tests conducted under
section 206(a)(l), then-
(1) he shall establish such methods and procedures
by regulation, and
(2) at such time as he determines that inspection
facilities or equipment are available for purposes of
carrying out testing methods and procedures established
under paragraph (1), he shall prescribe regulations which
shall require manufacturers to warrant the emission control
device or system of each new motor vehicle or new motor
vehicle engine to which a regulation under section 202 applies
and which is manufactured in a model year beginning after the
Administrator first prescribes warranty regulations under this
paragraph. The warranty under such regulations shall run to the
ultimate purchaser and each subsequent purchaser and shall pro-
vide that if—
(A) the vehicle or engine is maintained and
operated in accordance with instructions under
subsection (c)(3),
(B) it fails to conform at any time during
its useful life (as determined under section
202(d)) to the regulations prescribed under sec-
tion 202, and
50
-------
(C) such nonconformity results in the ulti-
mate purchaser (or any subsequent purchaser)
of such vehicle or engine having to bear any
penalty or other sanction (including the denial
of the right to use such vehicle or engine) under
State or Federal law,
then such manufacturer shall remedy such nonconformity under such
warranty with the cost thereof to be borne by the manufacturer.
No such warranty shall be invalid on the basis of any part used in
the maintenance or repair of a vehicle or engine if such part was
certified as provided under subsection (a)(2). For purposes of
the warranty under this subsection, for the period after twenty-
four months or twenty-four thousand miles (whichever first occurs)
the term "emission control device or system" means a catalytic
converter, thermal reactor, or other component installed on or
in a vehicle for the sole or primary purpose of reducing vehicle
emissions. Such terms shall not include those vehicle components
which were in general use prior to model year 1968."
The basic meaning of the warranty is that the manufacturer will be res-
ponsible for the costs of replacement of the emission control devices or sys-
tem up to 50,000 miles or 5 years whichever comes first provided that the
vehicle is operated and maintained in accord with written instructions fur-
nished by the manufacturer. In relation to the I/M program, what is particularly
important is the definition of the acceptable test procedures referred to in
the first paragraph of section 207(b). The basic question is what actual
emissions test will be reasonably correlated with the basic standard of emis-
sion testing which is the Federal Test Procedure (FTP) used to determine if
prototype vehicles and vehicles selected from the assembly line meet the ap-
plicable emission test standards under the Federal Motor Vehicle Emission
Control Program (FMVCP). The purpose of this program is to ensure that cars
being designed and manufactured meet the Federal emission standards. 207(b)
requires that there be a reasonable correlation between the short emission
test used in the I/M program with the lengthy FTP. To date five short test
have been proposed as suitable for use in light-duty vehicle and light-duty
truck emission inspection program. These include the following tests:
• the idle test
• the Federal 3 mode
• the Clayton Key mode
• the Federal Short Cycle
• the New York/New Jersey short cycle
These tests, then, have been proposed as being suitable for use in an I/M
program to implement the warranty provisions of 207(b). An associated issue
is the determination of appropriate cutpoints, that is, correct emission test
standards. There are three options for developing these standards: states
can determine them, or they can be provided by EPA or the manufacturers could
provide the data on the basis of which standards would be set either by the
51
-------
states or the EPA. With EPA's adoption of official outpoints, however, in
order for the 207(b) warranty provisions to be activated by an I/M program
test failure, then the state's I/M outpoints must be at least as stringent
as the promulgated EPA outpoints, EPA has not yet officially promulgated the
outpoints.
PUBLIC CONVENIENCE
The general motoring public is likely to view Inspection/Maintenance
as an inconvenience, as yet another requirement imposed by the state. Without
properly designed public relations programs, I/M is likely to be very unpopular.
In Arizona, the program was very nearly defeated in a public referendum for
this very reason. As a result, an I/M program must be designed so as to be as
convenient as possible to the motoring public. There are tradeoffs, however,
between public convenience and program cost, which is ultimately reflected in
inspection fees. Consumer convenience can be promoted in a variety of differ-
ent ways, among which are the following:
1. Contractor (or state) facilities should be placed in loca-
tions which maximize their accessibility to the public.
Stations should be sited in or near maximum concentrations
of population, so as to minimize the travel distance between
the average vehicle owner and the inspection facility. In
no case should a motorist have to spend more than 20 to 30
minutes traveling to an inspection facility.
2. Waiting lines in contractor (or state) inspection facilities
should be kept to a minimum through automation of test proced-
ures and proper design and sizing of facilities such that their
capacity is sufficient to handle peak demands. Registration
mailings can also be timed so as to stagger the number of
inspections processed within a given month, so that vehicles
do not arrive at the inspection stations in large numbers at
the end of their registration period. If necessary, inspec-
tions could be assigned on an appointment basis to ensure that
vehicles arrived at stations on off-peak hours. At present,
the registration process is arranged, such that 8 to 10 per-
cent of total registrations are processed each month with the
exception of January, where about half that number are pro-
cessed. This system would seem adequate to spread inspections
fairly evenly throughout the year; however, they may well need
to be spread out evenly throughout the month as well to avoid
bunching and long waiting lines at the end of each month.
3. Retest policies for those vehicles that fail inspection can
take a variety of different forms, some of which are more con-
venient from a consumer viewpoint than others. The maintenance -
retest cycle can be made either a two-stop or a one-stop
procedure. In the two-stop procedure, a motorist would be given
a certain time generally between 30 to 80 days, in which to
have his vehicle maintained, and then would be required to
52
-------
bring it back to the contractor (or state) inspection station
for a free retest before the registration process could be
completed. In the one-step procedure, such as that used in
California, a motorist whose vehicle failed inspection could
be required to bring the vehicle to a certified repair facility
containing a state-approved and calibrated analyzer. At this
facility, the vehicle would be maintained and retested. If its
emissions were corrected to meet the standards, the owner would
be given a certificate of compliance directly by the repair
facility and would not be required to undergo the free retest
at the contractor (or state) facility.
Both of the above retest policies have advantages and disadvantages. The
one-stop policy obviously involves less travel time and waiting time on the
part of the vehicle owner, but it also involves a widespread state program for
licensing, certifying, and regularly calibrating emissions analyzers in private
repair facilities. The manpower and equipment costs involved in such a program
might be so high as to significantly affect the test fee. If this is the case,
then serious equity considerations arise: should the entire motoring public
be made responsible for a program that benefits only those vehicles that fail?
Contractor (or state) facilities have been designed and costed so as to have
sufficient capacity to handle retests, and these retests could be performed in
these facilities in a much more rigorously controlled test procedure than in
private repair shops.
PUBLIC RELATIONS PROGRAM
Experiences in several states that recently established inspection/
maintenance programs emphasize the importance of an effective public relations
program. A well-designed, comprehensive program that introduces the public
to the basic need for, and benefits of, I/M and clarifies the misunderstandings
that surround I/M is critical during the early stages of implementation. A
well-thought-out program can help eliminate potentially adverse reactions that
other states with inadequate public relations programs have experienced (e.g.,
Arizona; Cincinnati, Ohio; and Chicago).
A comprehensive public relations program should consist of three basic
phases: (1) early initial public education on the basic need and benefits of
I/M; (2) an intensive public relationship effort 6 months prior to the actual
beginning of mandatory inspection; and (3) an ongoing public relations program.
Phase I: Initial Public Information Program
The emphasis of this phase, which should begin in the early planning and
design stages, should be in basic education as to the needs for I/M, the bene-
fits of I/M, and what it means to the public. It is very useful that the public
begin to gain a familiarity with the I/M concept and that this concept have time
to grow in the public awareness. By beginning early grass roots activities, sup-
port for the I/M program can be obtained. The elements of this phase would con-
sist of a slide presentation, mobile emission testing display, a generalized bro-
chure, and press releases. The slide presentation can be given to specialized
53
-------
interest groups such as clean air groups, environmental groups and conservation
clubs, the League of Women Voters, automobile clubs, automobile service in-
dustry groups, and local civic or service clubs. Also, metropolitan and re-
gional planning agencies can be involved at this point. A mobile emissions test
demonstration van has been found useful to acquaint the public or special groups
with the inspection process. Many states have prepared brochures explaining
I/M and distributed it widely among the general public. As important decisions
are made and implementation begins, periodic press releases should be made.
This initial public information effort may be accomplished by the state itself
or through assistance provided by private organizations with experience in I/M
public relations programs. Some states have contracted with the local clean
air or lung association.
Phase II; Preinspection Public Relations
About 6 months prior to the opening of test lanes for mandatory testing
with voluntary maintenance, there should be an intensive public relations effort.
During this time every motorist must be informed of the needs and benefits of
I/M and also of his obligations and rights and the basic organization and
procedures in the program. Also, this is the period during which the training
of the inspectors, in either state or contractor lanes would occur. An im-
portant part of the training is dealing effectively and courteously with the
public.
The basic elements of Phase II public relations would be a mailing to each
motorist, inspector training, news relations and media advertizing. The mailing
would consist of a pamphlet not only explaining the basic reasons for having
I/M and the benefits such as air quality and fuel economy improvements but also
what the times and places of the inspection stations operation, what consumer
rights and obligations are, what the complaint procedures are, and also impor-
tant details of the maintenance phase. During this phase, media advertisements
or announcements are important because it is critical that every affected
motorist receives the right information. All the employees of both the state
and the contractor who deal directly with the public especially the emission
inspectors, station managers, hot line operators, complaints investigators,
and calibration officials should receive training in how to deal with the public
and an understanding of the basics of I/M.
Phase III: Ongoing Public Relations
The emphasis in the ongoing public relations program is largely informa-
tional. States with existing I/M programs such as New Jersey and Arizona have
indicated that as the public becomes used to the program there may be somewhat
less need for an intensive public relations effort. There would still be a
need to inform motorists of any significant changes in program operations or
other modifications of program elements such as waivers, exemptions, repair
cost ceiling, inspection fees, or registration procedures. This would entail
periodic mailing and possibly some media announcements. Also, new employees
who deal with the public would be required to receive the same orientation that
the initial personnel received at the beginning of the program. The public
should also be made aware of the status of the program in terms of the emis-
sions reductions achieved.
54
-------
QUALITY ASSURANCE
Maintaining a high degree of precision and uniformity in emission test
results is vital to the success of an inspection/maintenance program. Accurate
information must be generated to correctly analyze the impact of the program on
lowering emissions and to maintain public interest in the program. If I/M is
perceived as a haphazard, arbitrary program, enforcement problems will become
intractable.
The repeatability of the actual test results is central to the issue of
quality assurance. The test must be carried out correctly and with a high
degree of uniformity on all vehicles included in the program. Wisconsin's
decision to establish a state- or contractor-operated network of test lanes
will facilitate the standardization and repeatability of tests. Such a system
contains a relatively small number of high quality exhaust gas emission ana-
lyzers that can be closely monitored.
It is technically feasible and desirable to automate the testing sequence
in this situation, tying all operations associated with the test into a central
computer system.
The key or loaded-mode test procedure that Wisconsin has chosen to incor-
porate into its I/M program is a sophisticated test that measures vehicle
exhaust emissions under a variety of different "loads" or conditions that
simulate the actual emissions generated by a vehicle under normal driving con-
ditions. To correctly perform a loaded-mode test, a series of samples must be
taken from a vehicles exhaust when it is experiencing loads within certain
parameters. The results of this sampling series are integrated to provide a
composite assessment of the vehicle's emissions characteristics.
Automating a loaded-mode test by interfacing the control of the analyzer
and dynamometer with a computer routine removes a large portion of the cause
of test result variability, human error. This approach to test control limits
human involvement to (1) identifying the vehicle to the computer by means of
entering the vehicle identification number (VIN) into an input/output device
(i.e., a "CRT" or TV screen-type computer terminal), (2) manually inserting
the analyzer probe into the tailpipe (or tailpipes) of the vehicle being tested,
and (3) operating the vehicle on the chassis dynamometer. The computer routine
can monitor the "load" being generated by the dynamometer and automatically
take exhaust samples at the appropriate times. The sample results can be
integrated by the computer and compared with test standards stored in the
computer.
Once such a system has been installed and its software has been found
accurate and reliable, a series of relatively simple checks should be made
to insure its continued correct operation. Analyzers must be calibrated peri-
odically. This procedure is straightforward. By analyzing a set of "cali-
bration gases" that have known precisely-blended contents and checking the
analyzers readings of actual gas content, the analyzers accuracy can be deter-
mined. At the very least, an exhaust gas analyzer should be checked in this
fashion whenever it is turned on and adjusted if its readings are different
55
-------
than they should be. With an automated system, the analyzer can be calibrated
regularly at frequencies of 1 hour to minimize the possiblity of inaccuracies
resulting from equipment malfunction.
If the contractor-operated system is chosen, periodic inspections should
be made by the state to verify the accuracy of data submitted by the contractor.
Ninety days is the generally accepted interval for such checks on central test
lane equipment. In addition to scheduled inspections, the state may perform
unannounced checks if there have been complaints about test accuracy or other
indications that an analyzer has not been functioning properly.
In order for such state inspections and checks to be useful, there are
certain informational requirements that should be placed on the contractor.
Most important, periodic reports on the frequency and results of equipment
calibrations should be mandatory. A log of any adjustments made in the process
of calibrating equipment should also be kept. Experience to date shows that
the operation of automated test systems is relatively trouble free, and that
downtime resulting from equipment malfunction is minimal. In addition to
direct equipment maintenance and calibration records, there are a number of
items that should be recorded to provide data for use in analyzing the effec-
tiveness of the program. This subject is dealt with in the section of this
report concerned with legislative aspects of implementing I/M.
Another quality assurance issue that should be handled in program enabling
legislation is the provision of a clause that prohibits the contractor from
engaging in any other type of business that leads to a conflict of interest.
The contractor must not be in a position to profit from one test result, but
not another. This issue is discussed more completely in Section 6 which deals
with enabling legislation.
Standards should be set regarding the type of analyzing equipment that may
be used by the contractor. There is a wide range in the quality and capacity
of such equipment on the market today. Use of equipment that is inappropriate
to a centralized network type application could provide a very low level of
test accuracy and uniformity between tests. Wisconsin can establish equipment
performance standards in one of two fashions. First, a list of approved equip-
ment, by manufacturer and model type can be compiled. Alternately, the actual
specifications and tolerances that acceptable equipment must meet may be
promulgated.
There are a number of performance parameters that should be specified to
insure that only high quality equipment is used. Most obviously, the accuracy
(in plus or minus percent) of the actual hydrocarbon and carbon monoxide
readings must be specified. The consistency of a unit's analysis over time
should also be subject to limits. If this "zero drift" is large over time,
either more frequent recalibrations should be stipulated or the unit should
not be approved for use. The "purge time" of an exhaust gas analyzer is another
important parameter. This refers to the time interval that must pass between
tests to assure that the emission readings are influenced only by the exhaust
of the vehicle being tested. The "purge time" is a measure of the time that a
unit must remain unused before it has been cleansed of all gases introduced by
56
-------
the previous test sequence. In high speed units of the type suitable for use
in the high volume contractor-operated system Wisconsin has chosen, an inert
or "neutral" gas such as nitrogen is run through the analyzer after each test
sequence to remove all traces of material introduced into the analyzers system
by previous tests.
Specifications of an analyzer that is quite adequate for the applications
described here are presented in Table 14. These specifications are provided
for use as a guideline in selecting analyzers and are not intended to be used
as "minimum" standards. This information was obtained from Horiba Instruments
Incorporated, Irvine, California.
MECHANICS TRAINING
Need for Mechanics Training
Mechanics training is a highly important part of an effective I/M program.
Mechanics training may occur through a very structured government sponsored
series of courses, through auto industry programs, as a regular part of voca-
tional training courses, or informally through repair shop on-the-job training.
Most government sponsored mechanics training courses include both background
content, or orientation towards the basic need and benefits of I/M and the
mechanic's role in the program, as well as technical content on emission systems,
correct diagnosis and repair of emission systems and low emission tuneup pro-
cedures. EPA and the automotive industry have focused much attention on me-
chanics training for two basic reasons. One is the increasing technical com-
plexity not only of the emissions controls but the overall technical sophisti-
cation in the basic ignition and carburetion systems, and the use of electronic
devices and power systems, there is an ever accelerating need for constant
training and retraining of mechanics. In recognition of this automobile manu-
facturers have themselves instituted in-service training programs for mechanics.
The second basic reason for needing mechanics training relates to the employ-
ment situation in the automobile repair industry itself and public attitudes
towards the repair industry. Due to skill shortages, relatively high employee
turnover rates, the growing complexity of the motor vehicles mentioned above,
and due to abuses by some car dealers and repair shops, it is generally con-
sidered that there are widespread substandard and unethical repair practices
in the repair industry. In the past few years there has been much publicity
on consumer dissatisfaction with the quality of service experienced throughout
the repair industry. In response to this general dissatisfaction, there have
been proposals to have more stringent regulation of the repair industry such
as licensing or certification of repair facilities or mechanics. The potential
effects of such regulations has been debated widely and most industry spokes-
persons oppose overly stringent controls because they appear to restrict
competition.
A related development of major concern to the I/M program itself is the
widespread practices of vehicle owners tampering with their emissions controls,
and fuel switching. Misunderstanding on the part of both the public and the
auto service industry on the technical aspects of emission controls and the
relationship between emissions control, and fuel economy and performance have
57
-------
TABLE 14. GENERAL SPECIFICATIONS OF A TYPICAL I/M CENTRALIZED FACILITY
EMISSION ANALYZER
Item
Specifications/Comments
Measuring Method;
Sensitivity:
Repeatability;
Zero Drift:*
Span Drift;*
Response Time (electrical):
Ambient Operating Conditions:
Warm-Up Time;
Power Requirements;
Meter Readout Accuracy:
Sample Gas Flow Rate:
Sample Gas Inlet Pressure:
Interference From Co-existing Gases;
Minimum/Maximum Measuring Range;!
CO (carbon monoxide)
(methane)
(propane)
(n-hexane)
NDIR, optical filter, dual source gas-
filled capacitive type detector.
0.5% of full-scale analysis range
±0.5% of full-scale with successive
identical gas samples under the same
physical conditions
less than 1% of full-scale/24 hrs
less than 1% of full-scale/24 hrs
0.5 to 15.5 seconds to 90% of full-
scale in 120 switch selected increments
temperatures between 0 C to 40 C
humidity - less than 95% RH
30 minutes to full accuracy
115 VAC (±10%) 60 Hz ±0.5 Hz
5% of full scale
0.5 to 10 liters per minute
28.5 p.sig.
less than 1% of full scale
Minimum Maximum
50 ppm
100 ppm
100 ppm
100 ppm
100%
100%
100%
5%
* Drift performance specifications are based on ambient temperature variation
of less than 10°C over a 24-hour interval.
Total analyzer response time is dependent on sample gas flow rate, sample
cell length and electrical response time.
T Minimum Recommended Measuring Range is the full-scale concentration which
may be measured with a 500 mm sample cell, response time of 0.5 seconds
full-scale and a noise level of less than 0.5% of full-scale.
58
-------
encouraged these practices. U.S. EPA has stated that 35 percent of 1976 and
1977 model cars have had their emission systems tampered with in some way,
ranging from minor adjustments away from manufacturer's specifications, to major,
sophisticated disconnections or modifications.1 At a recent emission control
conference, Mort Schultz, the editor of "Car Clinic" in Popular Mechanics
Magazine stated that he receives scores of letters from individual car owners
asking how to disconnect their emission control equipment.2 Twenty percent of
the letters that Mr. Schultz receives deal with emission control or related
problems. In many cases, auto mechanics both in small shops and dealer service
organizations encouraged tampering or were unable to fix problems that related
to emission control system problems. Among the solutions to these problems,
according to Mr. Schultz, was "better mechanic orientation." The mechanic at
the grass roots level can be the best emissary or the worst enemy. If he or
she is convinced that emissions control is necessary then he or she can con-
vince the consumer... Better Consumer Education."3
Benefits of Mechanics Training
The benefits of mechanics training may readily be seen from the above
analysis of the need for mechanics training: better understanding of the
need for emission tuneups and repairs, a more positive attitude towards emis-
sions reduction and I/M program, higher quality emission repairs and tuneups,
fewer consumer complaints about emission repairs, reductions in illegal
tampering and fuel switching, and, generally, a better relationship between the
auto repair industry and the public. In conjunction with mechanics training
a comprehensive public education program is, of course, needed to ensure that
the public at large does not encourage or contribute to unethical practices
such as tampering that reduce the overall effectiveness of mechanics training
programs in particular and the I/M effort in general.
Approaches to Mechanics Training
A variety of approaches have been instituted for mechanics training in
various states, ranging from very comprehensive government-sponsored programs
to informal industry sponsored efforts. In this discussion, the emphasis will
be on providing an understanding of the range of methods that could be employed
in Wisconsin.
Many states have instituted a formal, structured mechanics training pro-
gram in conjuction with the implementation of their I/M programs. In terms
of the actual timing of these courses, it is important to begin training
mechanics several months to a year before the mandatory inspection process
begins. However, the difficulty in implementing early training programs
relates to the fact that attendance is voluntary. Consequently, there must
be an incentive to participate. The primary incentives are, first, govern-
ment requirements for the official certification of a repair shop that it
employ at least one mechanic who has completed an approved mechanics training
course and second, the economic incentive to the repair facilities and mechan-
ics that result from the certification process. The repair shops that meet
the certification requirements can increase their repair business and this
servos as a significant incentive to other shops and mechanics to join the
59
-------
program. Obviously, as the I/M program becomes operational and repair demand
grows, so does the demand for mechanics training. The more formal government
sponsored programs are held in a classroom setting at local vocational schools
or community colleges. Typically, such courses may be held in the evenings
and last for 12 total hours. Subject matter includes basic orientation to
the needs and benefits of I/M and the role of emission tuneup personnel in
the I/M program and familiarization with basic emission control equipment and
emission control tuneups. "Hands-on" experience is important. Instructors
for such programs may be trained through the Colorado State University emission
instructor program. These master teachers then are available to train local
vocational education instructors.
Another approach to be considered which was found useful in Arizona's
program, is on-the-job training. Special two-person instructor teams may
hold courses at local repair facilities, training mechanics from nearby shops.
This approach emphasizes practical experience and overcomes the problem of
reaching mechanics who are unable to take the time off to attend classroom
courses.
In addition to government sponsored I/M program mechanics training courses,
it is important to consider industry sponsored efforts and resources. General
Motors Training Centers are available in many metropolitan areas. These centers
regularly hold special emission control repair and tuneup courses for GM equip-
ment at no charge to the mechanics. Some dealers send mechanics regularly to
these centers to update their knowledge and skills to keep abreast with the
rapidly changing technologies. The other major automobile manufacturers also
offer training opportunities, although not as extensive as those from GM.
Manufacturers, both domestic and foreign, may send instructors to dealers
or localities with mobile vans and conduct mechanics training upon request
from local car dealers.
Another important resource is the statewide vocational education school
system. Regular mechanics training courses of longer duration than those
described above, are held for students seeking basic automobile mechanic
skills. These courses should receive continuous update of the new technologies
and skills so that students graduating from then are competent to do emission
control repair and tuneup practices.
PROGRAM ENFORCEMENT CONSIDERATIONS
Once Wisconsin initiates an I/M program, efforts should be made to monitor
the public's rate of compliance with program requirements. Steps should be
taken to minimize public behavior that may adversely affect the goals of I/M.
Maintaining a high level of participation in the actual inspection procedure
by owners of vehicles included in the program is a prime concern. An effective
enforcement effort will tend to discourage noncompliance by making it highly
visible and by levying sanctions that are sufficiently severe to render non-
compliance undesirable to motor vehicle owners.
60
-------
Current Motor Vehicle Registration Procedures
The Bureau of Registration and Licensing (BRL) of the Wisconsin Department
of Transportation's Division of Motor Vehicles registered some 3.5 to 4 million
light-duty vehicles in 1977. This estimate includes both initial and renewal
registrations. Vehicle registration activity occurs fairly regularly over
time. The distribution of registrations by month appears below:
DISTRIBUTION OF LIGHT-DUTY VEHICLE REGISTRATIONS BY MONTH, %
July Aug Sept Oct Nov Dec Jan Feb Mar April May June
9.3 10.2 8.8 7.7 7.8 6.2 6.5 6.5 11 7.7 7.5 10.7
Initial registrations may be made in person by motor vehicle owners at
one of 22 or more BRL offices scattered across Wisconsin. Applications made
before the 16th of any month result in issuance of a registration that is valid
from the first of the month. Applications made on or after the 16th of any
month produce registrations that become valid on the first of the following
month. In both cases registrations issued are valid for 12 months.
Roughly 30 days prior to the expiration of a motor vehicle registration,
the BRL mails renewal forms to owners of all motor vehicles with valid regis-
trations. Motorists then return completed renewal forms by mail to the BRL.
If the motorist desires, this process may be completed in person.
Registration Related Enforcement Procedures
Maintaining a high participation rate in the I/M program assures that the
program's emission reduction goals will not be jeopardized. Also, from an
equity standpoint, full participation by all owners of vehicles covered by
such a program is necessary. The most effective method of enforcement, based
on the experiences of programs in other states, is to make I/M compliance a
requirement for registration and reregistration of motor vehicles. Recent
policy statements made by U.S. EPA indicate that this method is to be used.
A July memorandum to EPA regional administrators states that all I/M programs
must "prohibit registration or provide some equally effective mechanism to
prevent vehicles which do not comply with the applicable exhaust emission
requirements from operating on the public roads."1
Although there are several procedures that the State can apply to tie
enforcement to the registration process, one appears to be the most practical.
First, a requirement would be established for motorists to prove that they
either have successfully passed the emissions test or have been granted a
waiver prior to reregistering their vehicles. Proof could be in the form of a
stamp or other official marker being affixed to the registration renewal form
at the time the vehicle passes the test or the waiver is granted. This would
eliminate the need for handling any additional forms or other pieces of paper
61
-------
and should be fairly efficient. A similar system is utilized in Massachusetts
where certain types of insurance coverage is mandatory. Prior to renewing
registrations, the insurance carrier stamps the registration form indicating
that the individual has the required coverage. The registration personnel,
then, merely check to see that the form is stamped.
For initial registrations a grace period between the initial registration
date and when compliance is required will be necessary. Thus, for example,
owners of vehicles with initial registrations may have 60 days within which
to pass an emissions inspection.
With renewal, enforcement is automatic since it is impossible to register
vehicles without the forms being stamped. For initial registrations, the
State could, for instance, require inspection within a given time period, say
30 to 60 days after registration. Visible proof of inspection or waiver in
the form of a windshield sticker would eliminate the need for cross-referencing
new registrations and emission inspections if the program included statewide
coverage. However, since only a few counties are affected, a more positive
form of enforcement such as cross-referencing may be required.
62
-------
SECTION 6
LEGISLATIVE CONSIDERATIONS
INTRODUCTION
The purpose of this section is to. analyze the issues that must be addressed
by Wisconsin in the legislation that establishes the inspection/maintenance pro-
gram. The actual legislation developed is instrumental to the success of the
program in that it establishes the basic program framework, defines basic
rules and regulations and administrative duties, and designates authority to
operate the program. As such, the legislation must be broad enough to encom-
pass all the necessary program elements and responsibilities, and yet have
sufficient flexibility as to allow for necessary changes in the program over
time as required by changing economic, political or other conditions.
APPROACH AND METHODOLOGY
The basic approach used in analyzing the legislative issues and require-
ments was to review all pertinent literature and documentation, and to analyze
legislation from several other states where I/M bills have been successfully
drafted. In connection with the basic literature review, the most relevant
information is contained in various guidance documents and policy statements
issued by the U.S. Environmental Protection Agency. The intent here is to
define various technical and administrative requirements related to I/M legis-
lation that apply in a general sense to any state where I/M is required by
virtue of the 1977 Amendments to the Clean Air Act. It is important to note,
however, that a complete discussion of the legislative issues and requirements
for the state would have to consider existing statutes and legal requirements
for preparing legislation that are specific to Wisconsin. This level of
analysis was not undertaken primarily because It would more appropriately be
undertaken through a joint effort among various state agencies and members of
the State Legislature and their staffs.
LEGISLATIVE ISSUES
A number of issues relevant to I/M legislation were identified during the
literature review. The following paragraphs present a discussion of these
issues both in general terms, and in connection with specific legislation
written in other states. The issues discussed include:
63
-------
1. Authority to Implement I/M
2. Definitions
3. Authority to Establish Emission Test Standards
4. Authority to Grant Waivers and Exemptions
5. Authority to Contract with Private Contractors
6. Authority to Oversee Private Contractor
7. Enforcement and Penalties
8. Conflict of Interest Prohibition
9. Designation of Lead Agency and Other Agency Responsibilities
10. Licensing of Inspectors
11. Program Coverage
12. Vehicle Coverage
13. Inspection Frequency
14. Retest Policy
15. Repair Cost Limits
16. Fleet Inspections
17. Tampering
18. Documentation of Repairs Performed
19. Fees
20. Program Commencement and Phase-in Dates
21. Funding
22. Length of Program
23. Data Collection and Studies
24. Mechanics Training
25. Public Information Program
Authority to Implement I/M and Statement of Purpose
The basic statutory authority to implement an I/M program is stated in
one or several sections of the I/M enabling legislation. Often in the section
designating the responsibilities of the lead agency and other cooperating
agencies the basic authority to implement and conduct the program is stated.
Also, the authority to conduct various elements or tasks of the program such
as to establish emission test standards, grant waivers and exemptions, to con-
tract and oversee contractor responsibilities, to conduct enforcement and apply
sanctions or penalties are all stipulated under various specific sections of
the legislation. These specific issues are discussed below.
The statement of the basic intent and purpose including legislative find-
ings of the need for the I/M program may be included at the beginning of the
64
-------
I/M legislation. The inclusion of this section, which may be called a preamble,
may depend on whether or not the enabling legislation is the first statute to
introduce an inspection program for automobiles. An example of a preamble taken
from a U.S. EPA model I/M bill is provided below:
MODEL LEGISLATION FOR MOTOR VEHICLE POLLUTION CONTROL
"Purpose
Legislative Findings: For purposes of public health and safety,
the finds:
(1) That the emission of pollutants from motor vehicles is a
significant cause of air pollution in many sections of the
State of .
(2) That the control and elimination of such pollutants are of
utmost importance for the protection and preservation of the
public health, safety and well-being.
(3) That each state has a responsibility to establish procedures,
regulations and other provisions which comply with any promulgated
federal laws to control or eliminate such pollutants.
The state Environmental Agency and all other agencies, departments or
divisions of said departments and agencies shall provide by rules and
regulations standards, guidelines, for the inspection of all registered
vehicles (with promulgated exceptions) in said state, for the purpose
of controlling exhaust emissions of any air contaminants."
Definitions
Typically, a separate section of the I/M legislation is provided specific-
ally to define important words, and phrases used in the text of the legisla-
tion. As is the case in any law, having clear, unambiguous meanings is essen-
tial in order to avoid legal problems, misinterpretation, or unnecessary con-
flicts among agencies, individual citizens, or private groups with interests
in the program. Some I/M legislation defines the key terms in the body of the
text but most begin the law with a definitions section to establish clarity at
the outset. Following is the definitions section from the New Jersey State
Department of Environmental Protection Air Pollution Control Code, Chapter 15,
Control and Prohibition of Air Pollution from Light-Duty Gasoline-Fueled Motor
/Vehicles, January 6, 1972:
"Section 1 - Definitions
1.1 PERSON: Includes corporations, companies, associations, societies,
firms, partnerships and joint stock companies as well as individuals,
and shall also include all political subdivisions of this State or any
agencies or instrumentalities thereof.
1.2 MOTOR VEHICLE: Includes all vehicles propelled otherwise than by
muscular power, excepting such vehicles as run only upon rails or tracks.
65
-------
1.3 LIGHT-DUTY: Light-duty shall mean any motor vehicle designed
primarily for transportation of persons or property and registered
at 6,000 pounds gross weight or less.
1.4 MODEL YEAR OF VEHICLE: The production period of new motor
vehicles or new motor vehicle engines designated by the calendar
year in which such period ends. If the manufacturer does not designate
a production period, the model year with respect to such vehicles
or engines shall mean the 12-month period beginning January of the
year in which production begins.
1.5 EXHAUST EMISSIONS: Substances emitted into the atmosphere
from any opening downstream from the exhaust ports of a motor vehicle
engine.
1.6 CRANKCASE EMISSIONS: Substances emitted into the atmosphere
from any portion of the engine crankcase ventilation or lubrication
systems.
1.7 SMOKE: Small gasborne and airborne particles, exclusive of
water vapor, arising from a process of combustion in sufficient
number to be observable.
1.8 CARBON MONOXIDE: A nonirritating, colorless, odorless gas at
standard conditions which has the molecular form of CO.
1.9 HYDROCARBONS: Compounds whose molecules consist of atoms of
hydrogen and carbon only.
1.10 APPROVED EXHAUST GAS ANALYTICAL SYSTEM: A device for sensing
the amount of air contaminants in the exhaust emissions of a motor
vehicle. For purposes of this Chapter this shall mean analyzing
devices of the nondispersive infrared type sensitized to measure
carbon monoxide at the 4.74 micron band expressed as percent carbon
monoxide in air and to measure hydrocarbons as hexane at the 3.41
micron band expressed as parts per million of hydrocarbons (Hexane)
in air. The device shall be a design meeting "SPECIFICATIONS FOR
EXHAUST GAS ANALYTICAL SYSTEM" on file with the State Commissioner
of Environmental Protection and approved for use in accordance with
the manufacturer's recommended procedures for calibration and
maintenance.
1.11 NEW MOTOR VEHICLE: A newly manufactured motor vehicle regis-
tered in New Jersey, prior to delivery to the ultimate purchaser.
1.12 NEW MOTOR VEHICLE DEALER: A sales agency, his employees, and/or
agents licensed pursuant to N.J.S.A. 39:10-19 to sell new motor
vehicles.
1.13 ULTIMATE PURCHASER: Any person, other than a motor vehicle
dealer purchasing in his capacity as a motor vehicle dealer, who
in good faith purchases a motor vehicle for purposes other than
for resale as a motor vehicle dealer.
1.14 PREDELIVERY CHECKLIST: A schedule of items and procedures
which a new motor vehicle dealer is required or requested by a
manufacturer to check or follow prior to delivery of a new motor
vehicle to the ultimate purchaser."
66
-------
Authority to Establish Emission Test Standards
The success of an I/M program rests largely on the manner in which the
maximum allowable emissions levels for vehicles are set. To achieve maximum
emission reduction benefits while minimizing consumer inconvenience, several
states are using standards or cutpoints that are specific to the type and model
year of the vehicle. While it does increase in the complexity of certain aspects
of the test procedure, it also ensures that the program is equitable in the
sense that older, less well-controlled vehicles would not be tested against the
same standard that newer, better controlled vehicles would be.
A draft of sample I/M legislation prepared by the EPA in 1976 indicates
the types of variations in standards as a function of vehicle model year that
would be reasonable for both idle and loaded mode testing; standards for idle
tests are presented in Table 15 below<.
Table 15. SAMPLE CUTPOINTS DEFINED AS A FUNCTION OF MODEL YEAR FOR
THE IDLE MODE TEST
Model year
Maximum
allowable
HC (ppm) CO (%)
Pre-1968
1968-69
1970-74
Post-1974
1000
600
500
150
6.0
5.0
4.0
1.5
The EPA sample for loaded mode emission level standards is presented in a
similar, but more detailed table (not included here).
The actual authority to establish cutpoints should rest with the agency
administering the I/M program. The following quote from chapter 1154,
Section 2, 39118 of the California Health and Safety Code illustrates this.
"39118. With respect to the program designed and adopted by the
Department of Consumer Affairs pursuant to Chapter 20.4 (commenc-
ing with Section 91889.50) of Division 3 of the Business and
Professions Code, the board shall, in time for the Department of
Consumer Affairs to comply with the schedule specified in subdivi-
sions (a) and (b) of Section 9889.55, after public hearings, prescribe
maximum air pollution emission standards to be applied in inspecting
motor vehicles. In prescribing such standards, the board shall under-
take such studies and experiments as are necessary and feasible,
evaluate available data, and confer with automotive engineers. The
standards shall be set at a level reasonably achievable for each
67
-------
class and model of motor vehicle when operating in a reasonably
sound mechanical condition, allowing for the effects of installed
emission control equipment and devices, and the motor vehicle's
age and total mileage. The standards shall be designed to secure
the operation of all such motor vehicles, as soon as possible, with
a substantial reduction in air pollution emissions, and shall be
revised from time-to-time, as experience justifies."
Section 36-1772, Part E of the Arizona Revised Statutes (ARS),
Section R9-3-10063 states:
"The director (of the Department of Health Services) shall adopt
minimum emissions standards pursuant to Section 36-1717 with which
the various classes of vehicles shall be required to comply after
January 1, 1977. R9-3-1006 of ARS titled "The Mandatory Vehicular
Emissions Inspection" states in Subsection E that "All tested
vehicles must meet exhaust emissions standards as established in
this subsection when their exhaust emissions are inspected under
the conditions as prescribed in Subsection B of this section. Any
vehicles that do not meet their prescribed standard shall fail their
exhaust emission inspection." Subsection I then establishes emis-
sion standards based on a variety of factors.
It Is important to empower the program administrator with the authority
to set and revise the emission standards. There is an important balance between
the emission standard and resulting failure level. As standards become more
stringent, the failure levels increase. Because over a certain failure level
there is only a marginal reduction in emission it is important to have the
flexibility in setting the standards so as to maximize emission reductions and
minimize overly high failure levels. A very high failure level could create
a significant political backlash and jeopardize the program.
Power to Grant Exemptions/Waivers
The agency administering the I/M program should be empowered to establish
exemptions for certain vehicle classes and grant waivers to specific vehicles
under certain circumstances. Exemptions should be established based on equity
considerations (vehicle age, repair cost, etc.), and practicality (i.e., vehi-
cles that present difficulties in performing emissions inspections). The fol-
lowing list is representative, but not all inclusive, of exemption categories
established by programs currently in force:
• Vehicle age (Wisconsin has tentatively chosen to exempt
vehicles over 15 years old).
• Vehicles temporarily or permanently out of use and on
private property.
• Failed vehicles that have undergone required repairs but
are still out of compliance.
68
-------
• Permanent four wheel drive vehicles (these vehicles cannot
be tested with a loaded mode system).
• Vehicles with engine displacements less than a specified
minimum.
• Special purpose vehicles such as prototypes, experimental
models, etc.
• Motorcycles.
The power to grant waivers is important also. If one make of a certain
model year cannot meet the emission levels established for that model year,
it may prove more advantageous from the point of emission reductions to allow
that make/model year vehicle to remain out of compliance rather than, for
instance, lowering the standards to accommodate that vehicle.
Minnesota, for example, has stipulated that after consultation with the
Commissioner of Public Safety the pollution control agency "shall exempt by
rule, from all or any part of the mandatory periodic inspection," (a) motor
vehicles registered as classic, pioneer, or collector, pursuant to Minnesota
Statutes, Section 168.10; (b) motor vehicles used for racing or other exhibi-
tion purposes at places other than on public highways of the State and not
generally operated under their own power upon any public highways; and (c) any
class of motor vehicle which presents prohibitive inspection problems."
Arizona provides for "H.2. The exemption from inspection of (a) vehicles
which are temporarily or permanently immobilized and placed on privately-owned
lands; (b) a motor vehicle over 15 years old; (c) new vehicles originally
registered at time of initial retail sale and titling in this state pursuant
to Section 28-302."
Power to Contract With Private Firms
The agency designated to administer an I/M program must be empowered to
enter into a contractual agreement with an independent firm that will conduct
the actual inspections. The wording of this phrase can be straightforward.
A few examples follow:
Minnesota:
"Sec. 4. (Inspection Stations) Subdivision 1. (Establishment of Inspection
Stations, Contractor.) The agency, after consultation with the Commissioner,
shall determine the appropriate number and geographic distribution of inspec-
tion facilities required to implement the motor vehicle inspection program and
shall contract with a public or private entity to design, implement, construct,
and operate the inspection program established by this act."
Arizona: (Chapter 158, House Bill 2319
"36-1775. Agreement with independent contractor; qualifications of con-
tractor; agreement provisions.
69
-------
A. The Director is authorized to enter into an emissions inspection
agreement with one or more independent contractors subject to public bidding,
to provide for the construction, equipment, establishment, maintenance and
operation of an official emissions inspection stations in such numbers and
locations as may be required to provide vehicle owners reasonably convenient
access to inspection facilities for the purpose of obtaining compliance with
this article and the rules and regulations adopted pursuant hereto."
Authority to Oversee Contractor
It is important that the State maintain authority to oversee the activi-
ties of the contractor charged with operating the I/M inspection facility net-
work. The state should retain the authority to determine what data the con-
tractor must collect and maintain and in what format it should be reported to
the state (see 'Data Collection,' below).
Title 36, Chapter 14, Arizona Revised Statutes (ARS) Article 3, part 5-1775
deals with provisions in the agreement that the state may enter into or with
a private contractor. Part D, sections 3 through 6 assure that the State will
have sufficient authority to knowledgably oversee the contractor's operations.
It states that, among other provisions, the agreement shall deal with, "3.
The minimum requirements for adequate staff, equipment, management and hours and
place of operation of official emissions inspection stations. 4. The submis-
sion of such reports and documentation concerning the operation of official
emissions inspection stations as the director may require. 5. Surveillance
by the Department of Health Services to ensure compliance with vehicular emis-
sions standards, procedures, rules, regulations and laws. 6. Any other provi-
sion deemed necessary by the Director for the administration or enforcement of
the emissions inspection agreement."
Enforcement and Penalties
The legislation must include mechanisms to ensure that the motor vehicles
covered by the I/M program comply with the regulations. EPA policy states that
all I/M programs must "prohibit registration or provide some equally effective
mechanism to prevent vehicles which do not comply with the applicable exhaust
emission requirements from operating on the public roads." Nearly all the
states that are currently operating I/M programs utilize the registration pro-
cedure as the primary enforcement mechanism although other enforcement methods,
such as the use of inspection stickers, are considered to be applicable.
Arizona utilizes an enforcement procedure that requires a vehicle owner
to obtain evidence of I/M compliance and present it when he applies for a
renewal or new vehicle registration. R9-3-1007 of the Arizona Department of
Health Services (DHS) rules and regulations states: "Evidence of meeting state
inspection requirements.
The evidence that a vehicle has met the State's inspection requirements
shall be attested at the county assessor's office in one of the following
manners:
70
-------
A. Persons applying for renewal of registration shall provide either
of the following documents:
1. An Arizona card for the vehicle with all its carbon copies
attached and with a pass mark (for the emissions level test)
affixed as specified in Section R9-3-1010 or,
2. A completed certificate of inspection for a vehicle that is
part of a fleet qualifying under Sections R9-3-1019 and
R9-3-1020.
B. Applicable vehicles sold by a holder of a fleet station permit and
applying for transfer of title and registration shall provide any of the two
following documents:
1. An Arizona certificate of title accompanied by a completed
certificate of inspection.
2. A certificate of waiver.
C. Applicable vehicles with previous registrations that are being
registered in Arizona for the first time and are being registered in Maricopa
or Pima County by a person other than a holder of a fleet station permit shall
provide a certificate of admittance with a pass mark affixed.
D. Applicable vehicles with previous registrations that are being re-
gistered in Arizona for the first time and are being registered in Maricopa
or Pima County for a holder fleet station permit shall provide a completed
certificate of inspection.
E. Vehicles that are receiving registration or title changes under any
other circumstances other than described in this article shall not be required
to show evidence of meeting the state's inspection requirements.
F. The county assessor shall ensure that each certificate of inspection
accepted as evidence of meeting the inspection requirements of this article
properly indicates whether the inspection was for the purpose of acquiring a
new title or renewing registration."
In addition to the denial of registration for vehicles not in compliance
with the basic requirement of having passed the emission test, there may be
penalties or other sanctions for falsification of compliance forms, stickers,
waiver forms, or other acts, the intent of which is to avoid compliance. The
Colorado law, Section 42-4-315 states: "Penalties for false certificate and no
certificate (of compliance). (1) No person shall make, issue, or knowingly
use any imitation or deceptively similar or counterfeit certificate of emis-
sions inspection."
In the Minnesota legislation the following penalties are stipulated:
71
-------
"Section 9. (PENALTIES.) Subdivision 1. (a) Any employee of an
official inspection station or of a fleet inspection station who
certifies a motor vehicle as in compliance without having inspected
its equipment and mechanisms, or who wilfully certifies a motor
vehicle which has equipment and mechanism which do not meet or ex-
ceed the criteria and standards therefore, shall be guilty of a
misdemeanor.
"(b) Any employee of an official inspection station who undertakes
to furnish information to, recommend, suggest, or designate to a
motor vehicle owner or operator, or any other person connected
therewith, the name or any other description of a parts or repair
facility or any other place where parts, repairs, or adjustments
may be obtained to bring a motor vehicle into conformance with
inspection requirements, shall be guilty of a misdemeanor.
"(c) Any person who materially alters or changes any equipment or
mechanisms of a motor vehicle that has been certified to comply
with standards promulgated under this act, which causes the motor
vehicle to be in noncompliance with the standards and criteria,
shall be guilty of a misdemeanor.
"(d) Any person who provides information to an inspection station
on the extent or cost of repairs done to bring a motor vehicle
into compliance with the standards promulgated under this act, when
such repairs were not undertaken or when the cost was not as repre-
sented, shall be guilty of a misdemeanor."
Conflict of Interest Prohibition
It is essential for consumer protection purposes that the state be pro-
hibited from entering into a contract with an entity that stands to profit
from the outcome of emissions inspections tests. Businesses that buy, sell,
maintain, or repair vehicles, or that sell repair parts are particularly pro-
hibited in most legislation.
In Section 4 again, Minnesota admonishes, "The agency shall not contract
with any person who is engaged in the business of selling, maintaining, or
repairing motor vehicles or selling motor vehicle replacement or repair parts
at retail in this State, except that the contractor may repair any motor vehicle
owned or operated by the contractor." Subdivision 2 (repairs) states, "The word
'inspection' as used in this section shall not include repairs and adjustments.
Repairs or adjustments necessary to bring a motor vehicle into conformance with
the criteria and standards under this act shall be the responsibility of the
motor vehicle owner and may be made by the owner or any repair facility of his
choosing."
A potential enabling act in Connecticut states in Section 4(b) that,
"the Commissioner of Motor Vehicles and the Commissioner of Environmental
Protection are prohibited from entering into an inspection agreement with any
independent contractor who: (i) is engaged in the business of maintaining
or repairing vehicles in this state, except that the independent contractor
72
-------
shall not be precluded from maintaining or repairing any vehicle owned or
operated by the independent contractor, (ii) Does not have capability, re-
sources or technical and management skill to adequately conduct, equip,
operate and maintain a sufficient number of official inspection stations to meet
the demand for inspection of every vehicle which is required to be submitted
for inspection pursuant to this act."
Designation of Lead Agency
The lead agency should be designated in the program's enabling legisla-
tion. In addition to establishing the lead agency several states (California,
Colorado, Nevada, New Jersey) have named the Department of Motor Vehicles
(DMV) as a cooperative agency to assist in program operation. In Wisconsin, it
is likely that the Department of Transportation will assume the lead role
with direct support being provided by the Departments of Natural Resources and
Agriculture.
In California Senate Bill No. 479, Chapter 1154 states: "...requires the
Department of Consumer Affairs, with the cooperation of the Department of the
California Highway Patrol and the (Air Resources) Board, to design and adopt
a program for the mandatory periodic exhaust emission inspection of all motor
vehicles registered in such counties, and prescribes specified duties in con-
nection therewith." In August 1976 Assembly Bill No. 4161 transfered adminis-
trative control from the Department of Consumer Affairs to the State Air Re-
sources Board.
In several statutes the lead agency is presented in the "definitions"
section. The original bill that created mandatory I/M in Arizona (House Bill
2319, Chapter 158) defines "department" as the Department of Health Services
(DHS) and "director" as the director of the DHS. The bill then defines duties
that the director must assume; "The director shall administer a comprehensive
annual emissions inspection program which shall require the inspection of
vehicles in this state in accordance with the provisions of law or administra-
tive regulations pursuant to this article."
A proposed act in Connecticut in 1976 designed to establish an I/M pro-
gram states, "the Commissioner of Motor Vehicles may adopt regulations for the
construction, equipping, maintenance, and operation of official inspection
stations and for the enforcement of the provisions of this act. Such regula-
tions shall provide for the efficient conduct of inspections for emissions and
the presence of air pollution control devices and may include tests to deter-
mine whether the vehicle is in safe operating condition."
Licensing of Inspectors
Some state's I/M legislation may specify the requirements for licensing
and/or training of the official motor vehicle emission inspectors. Other
state's legislation does not include this level of detail and such specifica-
tions are then made as rules by the lead agency. The same requirements for
becoming an emission inspector may be used by the state regardless of whether
the state selects a contractor or state-run approval. An example of legisla-
tion concerning the licensing of inspectors is contained in the Arizona legis-
lation which follows:
73
-------
"R9-3-1016 Licensing of Inspectors:
"A. No person will be licensed as a vehicular emissions inspector
unless he has demonstrated his competence to the department by such
examination, training, or other standards as the director may approve.
B. Applications will be obtained from, and approved by, the department.
C. All completed applications will be returned to the department.
D. Any vehicular emissions inspector inspecting a diesel-powered
vehicle as prescribed herein must have successfully completed an approved
training course for visually reading opacity with the unaided eye
within the last six months or must use an opacity meter that is a full-
flow, direct reading, continuous reading light extinction type using
a collimated light source and photoelectric cell, and is accurate
within plus-or-minus 5%.
E. Licenses issued to vehicular emissions inspectors shall be renewed
annually on or before December 31, except that no license shall be
renewed twice in any calendar year.
F. Applications for renewal of vehicular emissions fleet inspector's
licenses shall be submitted thirty days prior to the current license
expiration date.
G. The department may suspend, revoke, or refuse to renew the license
if an applicant has violated any applicable rule or regulation issued
by the department.
H. The department may suspend, revoke, or refuse to renew the license
issued to an inspector when he has intentionally failed to properly
inspect a vehicle in compliance with regulations adopted by the
director.
I. A vehicular emissions inspector shall inform the department of any
change in his employment status within seven days of such change.
J. Each vehicular emissions inspector shall be assigned a single,
unique, nontransferable inspector's number. No vehicular emissions
inspector shall be assigned more than one inspector's number during
his lifetime."
Program Coverage
The geographical area the program will cover should be defined specifically
in the legislation. In Wisconsin the geographical area will include nine
counties. According to U.S. EPA "I/M should focus on the metropolitan areas
and should include the entire urbanized area and adjacent fringe areas of de-
velopment. Boundaries of the area affected may bev adjusted if an equivalent
emission reduction is achieved. For urbanized areas of 200,000 population
or greater which need I/M to obtain an extension of the 1982 attainment date,
full mandatory I/M must be implemented by the deadlines..."
Arizona House Bill 2319, Chapter 158, quoted above, continues, "such
inspection shall commence in counties with a population in excess of three
hundred fifty thousand by January 1, 1976. Inspection in other counties of
the state will commence when required by the director to meet air pollution
control standards or upon application by a county board of supervisors for par-
ticipation in such inspection program, subject to approval by the director."
74
-------
Vehicle Coverage
In addition to defining the geographical coverage of the I/M program,
the enabling legislation should specify the types of vehicles to be included
in the program. U.S. EPA guidelines stipulate that all I/M programs must
"provide for regular periodic inspections of all vehicles for which emission
reductions are claimed." The emission reduction benefits are calculated,
according to specific certain emission reduction credits defined by EPA.
Credits are defined for light-duty vehicles (LDV's) and two categories of
light-duty trucks. Light-duty trucks are defined as a vehicle category
consisting of trucks used chiefly for personal transportation that are (generally)
powered by gasoline-fueled, spark-ignited internal combustion engines. Two
subcategories of light-duty trucks are used: trucks having a gross vehicle
weight (GVW) in the range of 0 to 6000 pounds (LDT1), and trucks with GVW in
the range of 6001 to 8500 pounds (LDT2). Trucks in these two categories are
essentially all two-axle, four tire trucks. Light-duty vehicles (LDV) are
primarily vehicles used for personal transportation with a GVW of up to
8500 pounds. Emission credits have not been defined for light-duty diesel
trucks and heavy-duty trucks (gasoline and diesel).
Different states have defined the relevant vehicle population differently.
Minnesota states that procedures shall be established "for the annual inspection
of all motor vehicles registered by residents of the metropolitan area for
air pollution emissions,..." "Motor vehicle means any self-propelled motor
vehicle weighing less than 8500 pounds and licensed for use upon the public
highways of the state for transportation of persons or property." The Minnesota
statute also provides for inspection prior to initial registration for new
motor vehicle sales and for inspection of vehicles owned by new residents
within the area of program coverage. Regarding the latter issue, the statute
states "In addition to annual inspection, a motor vehicle when first registered
to a resident of the metropolitan area following a move by that person from out
of the state shall be inspected for compliance with the inspection standards
under this act prior to the initial registration in Minnesota."
Arizona's House bill 2319, Chapter 158 states, "Vehicles required to be
inspected and registered in this State except those provided for in Section 36-
1776 (a list of exemptions), shall be inspected in accordance with the provi-
sions of this Article,.." "Vehicle" means any automobile, truck, truck tractor,
motor bus or any self-propelled or motor-driven vehicle registered or to be
registered in this State and used upon the public highways of this State for
the purpose of transporting persons or property, except implements of husbandry,
road rollers or road machines temporarily operated upon the highway."
In addition to enumerating the vehicle types affected by an I/M program,
vehicles that change hands must be considered. These vehicles may be new
cars that are sold for the first time, used vehicles sold by dealers within the
area of program coverage, used vehicles sold by dealers outside the area of
program coverage, vehicles sold by one individual to another and vehicles owned
by people who move their residence from outside the program's geographic coverage
into it.
75
-------
Existing programs treat these vehicles in fairly consistent ways. When
a vehicle changes hands between individuals some states require reinspection
by the new owner if it has not been inspected within 60 days prior to the
sale date. Elsewhere, no specific requirement is made, that is, the vehicle
must be inspected again within 30 days prior to reregistration by the new
owner.
Vehicles owned by individuals moving into Wisconsin may be treated in one
of several ways. Inspection can be required upon registration within the state
for all such vehicles. Alternately, all such vehicles can enter the state
without being inspected, falling under the inspection requirement prior to
reregistration in the usual manner. It may be feasible to follow this policy
for vehicles previously registered in an area with emissions inspection while
requiring vehicles entering from jurisdictions without I/M to undergo a test
and meet emission level standards within a certain time after entering Wisconsin.
The type of policy established regarding vehicles changing hands and en-
tering the relevant vehicle population will be dictated largely by the prac-
tical problems of establishing viable enforcement measures for the policy
chosen. The most practical form of enforcement is to tie I/M requirements
to vehicle registration requirements (see the discussion on Enforcement).
Inspection Frequency
Generally, the more frequently a motor vehicle is inspected, the more
likely it is that its emissions will approach the minimum level. Although
the emission deterioration characteristics of motor vehicles vary from vehicle
to vehicle and as a function of many other external factors, it has generally
been found that carbon monoxide emissions tend to deteriorate back to pre-
inspection levels over a period of about a year, while hydrocarbon emission
rates deteriorate somewhat more quickly. EPA policy states that I/M programs
must require inspections to be performed on a regular, periodic basis but does
not stipulate the exact interval. From a practical standpoint a program whereby
inspections are performed more frequently than annually is not desirable. Nearly
all states have chosen an annual inspection cycle, which is generally integrated
into the motor vehicle registration process for enforcement. Since registration
in Wisconsin is on an annual basis, a 1-year inspection interval would be
appropriate.
Most existing legislation defines the frequency of inspections in a
straightforward manner. Minnesota established "procedures for the annual in-
spection of all motor vehicles..." Rhode Island states that "31-38-2c. Vehi-
cles required to be inspected in this State shall be inspected at least once
within each twelve (12) month period in accordance with rules and regulations
established by the Registrar" (of Motor Vehicles). Other enabling legislation
is worded similarly.
76
-------
Retest Policy
There are a number of ways to deal with the issue of retesting vehicles
that have failed to meet established emission standards. Having the failed
vehicles return to the test facility within a specified time after failing is
common to most programs currently in operation. Vehicles failing the inspec-
tion are generally required to have appropriate maintenance performed and
then return to the inspection station for a retest. The time limit between
the initial inspection and retest ranges from 15 to 30 days depending on the
state.
Another important issue is whether or not retests will be paid or free
to the motorist. To insure consumer acceptance the typical approach is to
provide retests within a specified time period at no additional charge. This
creates an incentive to bring failed vehicles into compliance promptly, as
well as reducing the economic impact of failing the test.
The regulations relating to the time period a failed vehicle is allowed
before it must be retested need not be stated in the enabling legislation of
an emissions inspection program. It may be appropriate to leave this matter
to the discretion of the director of the agency charged with administering
the program,
Arizona has included a phrase in House Bill 2313-F that deals with failed
vehicles. It reads, "36-1773 D, Any person whose vehicle has been inspected
at an official inspection station shall, if such vehicle was not found to
comply with the minimum standards, have his vehicle repaired and have the
right within thirty consecutive calendar days, but not thereafter, to return
such vehicle for one reinspection without charge," Rhode Island legislation
reads similarly; "Any person whose vehicle has been inspected at an official
inspection station, shall, if such vehicle was not found to comply with the
minimum standards, have his vehicle repaired and have the right within twenty
(20) consecutive calendar days, but not thereafter, to return such vehicle
for one (1) reinspection without charge,"
Repair Cost Limits
Any program that requires individuals to make purchases must be both
equitable and practical if it is to be successful. The mandatory repairs
required by an I/M program to bring all vehicles within established guidelines
for allowable emissions must have limits placed on the magnitude of the cost
of required repairs. This ceiling will help prevent the program from becoming
an excessive burden on the public. Also, for certain vehicles the cost of
complying may be so great as to render their operation prohibitively expensive.
To ameliorate these problems, repair cost ceilings are usually specified.
These limits may take either/or a combination of two forms. First, an
absolute dollar limit on the expense of mandated repairs may be set. If a
vehicle owner can show that repairs have been performed up to that limit, the
vehicle registration is allowed, regardless of whether or not the vehicle
emission level is within standards or not. A second type of limit is defined
77
-------
as a function of the value of the vehicle. Minnesota has adopted such a pro-
vision in subdivision 5 of its statute. "Maximum Repair Cost. l(a) The
maximum repair cost for meeting emission standards not covered by any warranty,
shall be as follows: a motor vehicle having a value of $2,000 or less, $50,
for each full $500 of vehicle value over $2,000, an additional $10. Motor
vehicle values shall be determined as provided in Minnesota Statutes,
Section 168.013." When absolute dollar limits are used, they are usually set
at $50 or $75 with provisions to increase it over time.
Fleet Inspections
Several states have established procedures for certifying owners of
fleets of vehicles to self-inspect their vehicles. Commonly included are
private or government organizations (other than the Federal Government) that
owns or operates a number of vehicles where it is deemed that self-inspection
would be more cost effective than requiring that each vehicle travel to the
state or contractor inspection stations. Most states have certified fleet
inspection stations and have set the number of vehicles needed to qualify for
being classified as a fleet at about 15 to 25 vehicles. Fleets include state,
city or local government agency vehicles, taxi fleets, rental vehicles, etc.
The benefits of having certified fleet inspection stations include both
cost savings to the fleet owners and a potential reduction in the number of
centralized inspection stations.
It is important that the state establish adequate supervision and quality
assurance controls on the fleet inspection stations. The enabling legislation
must stipulate the requirements for certification for fleet stations, sur-
veillance procedures, equipment calibration requirements, and procedures and
reasons for revocation of permits.
Section 36-1776 of the Arizona Revised Statutes, entitled "Fleet emissions
inspection stations; certificates of inspection; dealer's inventory, inves-
tigations; revocation of permit" deals with several issues relating to fleet
inspections. It establishes that a registered owner or lessee of a fleet of
at least 25 vehicles is eligible to apply to the Director of the Department of
Health Services (the I/M program's administrative agency in Arizona) for a
permit to establish a fleet emissions inspection station. There are several
requirements that must be met before the director can issue a permit. They are:
"that the applicant:
1. Maintains an established place of business for the repair and
maintenance of applicant's fleet of vehicles.
2. Has obtained approved machinery, tools and equipment to ade-
quately conduct the required emissions inspections, except that
notwithstanding any other provisions of this article, or rules
or regulations promulgated hereunder, fleet emission inspection
stations shall be permitted to inspect vehicles owned or leased
by the fleet emission inspection stations, by using either an
idle test condition or a loaded test condition.
78
-------
3. Employs properly trained and licensed personnel with which
to perform the necessary labor,
A. Agrees to provide data as may be prescribed by the director,"
The statute stipulates that only vehicles found to comply with applicable
regulations, "that is meet tailpipe emission level standards," may have certif-
icates of compliance issued to them. The fleet emissions inspection station
permit holder is not allowed to inspect or certify any vehicle not owned
or leased by the holder. An important phrase which establishes dealer inven-
tory as part of a dealer's fleet, and hence eligible for fleet inspections by
the dealer reads, "Vehicles owned by a licensed vehicle dealer and which are
held for resale as a part of the dealer's business inventory shall be deemed
a part of such dealer's vehicle fleet for purposes of this section."
Part F of Section 36-1776 provides the Director of the Department of
Health Services with the authority to investigate fleet inspection stations
to verify their compliance with these regulations,
"The director shall investigate the operation of each fleet emissions
inspection station as the conditions and circumstances of such operation may
indicate. He may require the holder of any fleet permit to submit such docu-
mentation required concerning the operation of such inspection station, The
director may revoke and require the surrender and forfeiture of any fleet
emissions inspection station permit and certificates of inspection of such
permittee if he finds that such station is not operated in accordance with
this article and the lawful rules and regulations adopted by the director or
the holder of such permit has failed or refused to submit records or docu-
mentation required."
Minnesota has also addressed the issue of fleet inspection stations.
Owners of fleets of 15 or more motor vehicles may apply for fleet inspection
station licenses. The applicant must show that "he has facilities, equipment,
and personnel to competently perform the inspection." Minnesota also treats
motor vehicle inventories held by dealers as part of the dealer's fleet.
"All motor vehicles held for resale shall be considered as 'owned' until such
time as the motor vehicle is titled in a purchaser's name or otherwise disposed
of." The legislation stipulates how many fleet vehicles the pollution control
agency may inspect to verify the action taken by a fleet inspection station.
"The agency may require owners of fleets of motor vehicles to submit motor
vehicles designated by the agency numbering five percent or two motor vehicles,
whichever is larger, to inspection annually at official inspection stations,
to insure compliance with the provisions of this section."
Minnesota also spells out policy on hearings when a licensee has his
license revoked or suspended and when an application for a license is refused.
"The agency may revoke or suspend any fleet inspection station license upon
a finding that any motor vehicle was wrongly certified as in compliance and
may refuse, suspend, or revoke the license upon a finding the licensee does
not have the equipment, facilities, or personnel to competently perform in-
spections as required by this act, or for other just cause. In the event of
any refusal, suspension, or revocation of a fleet inspection station license,
79
-------
the licensee or applicant may request, within 30 days of the agency's action,
pursuant to Minnesota Statutes, Chapter 15. If a hearing is requested no
suspension or revocation shall be effective until after the decision based
upon the hearing."
Tampering
Both the Wisconsin Departments of Transportation and Natural Resources
have provisions to check whether or not vehicle emission control equipment has
been tampered with. In addition to establishing these procedures, penalties
have been defined for persons found guilty of tampering with (disconnecting)
air pollution control devices and systems.
Removing or disconnecting any ", . , vehicle emission control devices
originally installed by the manufacturer or comparable tested placement
devices. . ." on any vehicle operated on Wisconsin highways is unlawful
according to Subchapter IV, Exhaust and Fuel Systems, of the Department of
Transportation, Standards for Motor Vehicle Equipment. Furthermore, MVD 5,
Subchapter IX, Homemade or Reconstructed Motor Vehicles, states that it is
unlawful for "... any vehicle. . .homemade or reconstructed using a 1968
model year engine or later. . ."to be operated on a highway if it does not
have proper emission control devices."
The New Dealer's Unit of the DOT's Division of Enforcement has been em-
powered to enforce these provisions as prescribed in Section 110.075 (7) of
the Wisconsin Statutes. In supervising all of the new and used motor vehicles
sales operations in the State, the Unit may refuse or deny any dealers found
in violation of the regulations the right to do business. The Wisconsin
Department of Natural Resources may levy fines of from $10 to $5,000 upon
persons violating Section 144.42 Motor Vehicle Pollution, Excerpts of
Chapter 83, Laws of 1967. Authority provided through this regulation reads
as follows:
"(2) Except as permitted or authorized by law, no person shall
fail to maintain in good working order or remove, dismantle or
otherwise cause to be inoperative any equipment or feature con-
stituting an operational element of the air pollution control
system or mechanism of a motor vehicle and required by rules of
the department to be maintained in or on the vehicle. Any such
failure to maintain in good working order or removal, dismantling
or causing of inoperability shall subject the owner or operator to
suspension or cancellation of the registration for the vehicle.
The vehicle shall not thereafter be eligible for registration
until all parts and equipment constituting operational elements of
the motor vehicle have been restored, replaced or repaired and are
in good working order."
Documentation of Repairs Performed
It is of value to collect data on repairs required by an I/M program in
order to evaluate its impact and assure that vehicles returning for reinspec-
tion have actually undergone the necessary repairs. If exemptions are granted
80
-------
to vehicles that fail reinspection after having repairs performed, it is es-
sential that some form of documentation be prepared by those actually per-
forming repairs. This type of data would also be necessary to provide the
basis for evaluating the efficiency of individual repair shops in performing
maintenance and thus would play an integral role in both consumer protection
and quality control programs. Further, these data would be useful as input
for an overall program evaluation effort, which should be undertaken
periodically.
Fees
Enabling legislation generally sets a maximum fee that may be charged
for performing a motor vehicle inspection. How many reinspections, if any,
covered by the fee collected should also be stipulated? In the event that
vehicles are required to undergo rein'spections that are not included in the
basic fee, the ceiling costs performing the additional inspections should be
stated, also.
Minnesota deals with this issue in the following manner: "[Fee for
Inspection.] (a) An inspection fee of not to exceed $10 shall be paid at the
official inspection station at the time any motor vehicle is inspected. The
inspection fee shall entitle the owner of the motor vehicle to one initial
inspection and, if necessary, one full or partial reinspection, at the official
inspection station. If two or more reinspections are required, an additional
fee of not more than $7,50 per full or partial reinspection shall be set by
the agency and charged in the same manner at the time of reinspection. The
fee shall cover the contract cost of the inspection and the administration
costs of the agency and department under this act. The fee for motor vehicles
inspected in a fleet inspection station shall be set by the agency to equal
the costs of agency and department fleet license and program administration
only. The inspection fee shall also apply to vehicles exempt from license
fees pursuant to Minnesota Statutes, Section 68,012,"
The last two sentences are particularly important. The first insures
that the 1/M program will be self-supporting. The fee charged per inspection
must be set high enough to cover costs that are incurred in performing the
inspection. This is a desirable feature and appears in virtually all I/M
enabling legislation.
The last sentence allows a fee to be charged for all vehicles exempt from
license fees. These vehicles are usually owned by units of government that
are "higher up" than the governmental unit levying the fee. In this case, it
is concerned with federally owned vehicles.
Legislation for other programs cover similar issues, but may be worded
differently. Arizona, for example, specifies that fees will be collected
along with each vehicle's annual registration charge. This approach provides
a positive method of collecting fees that is low in cost. Section 36-1773
of the Arizona Revised Statutes reads as follows:
81
-------
"Emission inspection fees; composition and disposition
A. The director shall fix, regulate and alter in accordance with
this section, the fees, not to exceed five dollars per inspection,
required to be paid for the inspection of every vehicle inspected
pursuant to this article.
B. The director shall fix the fees, not to exceed five dollars
per inspection. Such fees shall be originally fixed and there-
after adjusted by the director to reflect the contractual charge
payable to any independent contractor as well as increase or
decrease in costs to the state of providing and administering
emissions inspection services.
C. The fees charged for official emissions inspection shall
be uniform as applied to each class of vehicle which shall be
defined by the director. Except for fees collected by the
director pursuant to Section 36-1776, the inspection fee shall
be collected with the registration fee by the county assessor
at the time and place of motor vehicle registration pursuant
to title 28, chapter 3, section 1, and:
1. The assessor of each county is constituted an agent of the
department of transportation for the collection of the emis-
sions inspection fee.
2. All monies received from inspection fees by the county
assessor shall be immediately transferred by the collecting
officer to the state treasurer and by him to the emissions
inspection fund.
D. Any person whose vehicle has been inspected at an official
emissions inspection station shall, if such vehicle was not
found to comply with the minimum standards, have his vehicle
repaired and have the right within thirty consecutive calendar
days but not thereafter to return such vehicle for one rein-
spection without charge,"
Section 9889.61, Part B of Chapter 1154 of the California Vehicle Code
states, "The department shall charge a fee for the inspection of motor vehicles
conducted pursuant to Section 9889.55. The revenues from such fees shall be
sufficient to provide the State funds to match any federal grants awarded in
response to application under subdivision (a), and to reimburse the Motor
Vehicle Account in the Transportation Tax Fund for all appropriations made for
the design, adoption, implementation, and operation of the inspection program
established by this chapter."
Chapter 38 of the general laws of Rhode Island, entitled "Inspection of
Motor Vehicles" deals with fees in the following way:
"31-38.3 Inspection fees; composition and disposition.
a. The registrar (of Motor Vehicles) shall fix, regulate and
alter in accordance with this section, the fees required to be
paid for the inspection of every vehicle inspected pursuant to
this chapter. Such fees shall be originally fixed and there-
after adjusted by the registrar to reflect the contractual
charge payable to any independent contractor as well as any
82
-------
increase or decrease in the costs to the state of providing and
administering inspection services.
b. The fees charged for official inspection shall be uniform
throughout the State and shall be collected at the point of
inspection.
c. Any person whose vehicle has been inspected at an official
inspection station, shall, if such vehicle was not found to
comply with the minimum standards, have his vehicle repaired and
have the right within twenty (20) consecutive calendar days, but
not thereafter, to return such vehicle for one (1) reinspection
without charge."
Program Commencement and Phase^-in Dates
The I/M program commencement date must be stated in the enabling legis-
lation. Several states have implemented programs in phases, often beginning
with mandatory inspection but voluntary maintenance. The mandatory maintenance
usually begins after 1 year. This approach has been very beneficial since it
gives the public time to become acquainted with the basic I/M concepts. Also,
it has other important benefits such as allowing time for the repair industry
to gain the necessary training and experience in emission related repairs.
Arizona's I/M program began with a 1-year voluntary maintenance period.
The sections of Arizona regulations dealing with this issue are R9-3-1004
Parts A and B and they read as follows: "A. Pursuant to ARS §36-1772, all
vehicles required by this article to be subjected to the mandatory vehicular
emissions inspection shall be required to be inspected, but, from 12:01 a.m.
on January 1, 1976 to 12:01 a.m. on January 1, 1977, shall not be required to
pass inspection. B. All vehicles required by this article to be subjected
to the mandatory vehicular emissions inspection shall be required to pass the
inspections subsequent to 12:01 a.m. on January 1, 1977." Section 36-1772 of
the Arizona Revised Statutes is referred to by this passage. Section 36-1772
establishes I/M in Arizona. Regarding program commencement it states in
Part A of this section that "such inspection shall commence in counties with
a population in excess of three hundred fifty thousand by January 1, 1976."
Thus, it is appropriate to establish the date on which an I/M program is
initiated in the enabling legislation and determine how to phase it in, should
a gradual implementation approach be chosen, via adoption of rules and regu-
lations by the director of the program's administering agency.
Funding
Many states' enabling legislation establish the funding mechanism required
for the program. Often this section is included with the fee section, although
it may be separate. The funds section first establishes the fund, defines the
revenue sources for it, establishes authorized expenditures from it, defines
exemptions, and may establish any investment policies. The major revenue
sources for the inspection fund generally would be general state appropriations,
grants (especially Federal grants), fees from the inspections, and bonds if
83
-------
established for the program. The Arizona legislation established an inspection
fund in House Bill 2319 which reads as follows:
"36-1774. Emissions inspection fund, composition; authorized
expenditures; exemptions; investment
A. There is established an emissions inspection fund which shall
consist of:
1. Money appropriated thereto by the legislature.
2. All money remitted by owners of vehicles which is collected
for emissions inspection.
3. All money collected by the Director for the issuance of in-
spection certificates to owners of fleet emissions inspection
stations.
4. Money received from private grants or donations when so desig-
nated by the grantor or donor.
5. Money received from the United States by grant or otherwise to
assist the State in any emissions inspection program.
B. The Director of Administration shall approve properly certified
claims submitted by the Department of Administration for enforce-
ment of the provisions of this article. When such claims for reim-
bursement are approved by the Director and transmitted to the State
Treasurer, he shall transfer the amounts claimed to the Director of
the Department of Health Services.
C. No monies in the emissions inspection fund shall revert to the
general fund or the Department of Health Services and such monies
shall be exempt from the provision of Section 35-190, relating to
lapsing of appropriations until January 1, 1981.
Providing and administering emissions inspection services.
C. The fees charged for official emissions inspection shall be
uniform as applied to each class of vehicle which shall be defined
by the Director. Except for fees collected by the Director pursu-
ant to Section 36-1776, the inspection fee shall be collected with
the registration fee by the County Assessor at the time and place
of motor vehicle registration pursuant to Title 28, Chapter 3,
Article 1 and:
1. The Assessor of each county is constituted an agent of the
Department of Transportation for the collection of the emissions
inspection fee.
2. All monies received from inspection fees by the County Assessor
shall be immediately transferred by the collecting officer to the
Director of the Department of Transportation and by him to the emis-
sions inspection fund.
D. Any person whose vehicle has been inspected at an official emis-
sions inspection station shall, if such vehicle was not found to
comply with the minimum standards, have his vehicle repaired and
have the right within thirty consecutive calendar days but not there-
after to return such vehicle for one reinspection without charge.
E. The Director shall fix an emissions inspection fee before in-
spection certificates may be issued to the owner of any fleet emis-
sions inspection station. Such fee shall be uniform for each in-
spection certificate issued and shall be based upon the Director's
84
-------
estimated costs to the State of administering and enforcing the pro-
visions of this article as they apply to fleet emissions inspection
stations and the vehicles inspected therein. The Director shall
promptly transmit all such monies collected by him pursuant to this
article to the State Treasurer who shall deposit them in the emissions
inspection fund."
Based on other states' programs, an optimum contract period appears to be
5 years. Longer periods bring with them uncertainties about costs and polit-
ical factors. In addition, it would be important that the state be able to
terminate the contract as appropriate at the end of the 5 years (or sooner if
need be) with the option of taking over the program, renegotiating with the
same operator or contracting with another operator. Contracts of less than
5 years would be financially unattractive to potential contractors unless the
initial investments and startup costs were shared between the contractor and
the State, or similar arrangements made that would absolve the contractor from
making very high initial investments.
Arizona established a 5-year contract in House Bill 2319, Section 36-1775,
Part D 1: "A contract term or duration of five years with equitable compen-
sation to the contractor if the provisions of this article are repealed."
Minnesota established a 5-year minimum contract length: "Sec. 4
Any contract authorized by this section shall contain, in addition to other
provisions, a contract duration for actual operation of the inspection stations
of a minimum of five years, and provision for equitable compensation to the
contractor, if the provisions of this act are repealed prior to the expiration
of the contract term."
Length of Program - Termination or Extension of Contract
The overall duration of an I/M program itself does not have to be spec-
ified in the enabling legislation. However, in a contractor approach, the
exact time that the contract runs as well as contract termination procedures
and provisions are often included. A closely related issue is the fee paid
to the contractor. To keep the fee constant over the contract period, the
effect of inflation must be taken into account. Correcting for inflation, the
fee paid will be in excess of a contractor's costs at the start of a program
and below the contractor's costs at the end. The contract duration should
reflect the time period use to calculate the constant fee. This prevents
contractors from making excess profits now, and assures that the contractor
will still be performing inspections when costs exceed fees later on.
Data Collection and Studies
Whether Wisconsin selects a contractor or state-run I/M system, it will
be necessary to establish in the enabling legislation the authority (require-
ments, actually) to collect data and conduct studies of individual inspection
station performance, repair costs, and overall program effectiveness. Gener-
ally in a contractor system, the contractor collects the data, which is sub-
sequently analyzed by the appropriate state agency; alternatively, in a state-
run system, the state would collect and analyze the data and its effectiveness.
85
-------
In either approach, the director of the administrative agency is empowered by
the enabling legislation to collect and maintain data files.
California has stipulated in Section 8, Section 9889.58 of the Business
and Professions Code that information maintained in the records of all facil-
ities performing inspections shall include all of the following:
"(a) the number of maintenance and repair operations performed on
motor vehicles which failed to pass an inspection conducted by the
department pursuant to the provisions of this chapter.
(b) the correlation between maintenance and repairs recommended by
the department pursuant to subdivision (b) of Section 9889.51 and
maintenance and repairs performed.
(c) the percentage of maintained and repaired vehicles which passed
reinspection.
(d) the charges assessed for such maintenance and repairs.
(e) any other information deemed essential by the department."
When an RFP (Request for Proposal) is promulgated and rules and regula-
tions are established, a more complete and refined list of data requirements
should be set forth. It should include, but not be limited to, the following:
• vehicle identification number
• test results
• vehicle age
• repairs needed for failed vehicles
• cost of repairs performed on failed vehicles (labor/parts)
• analyzer calibration records (frequency, accuracy, etc.)
• vehicle license number
• owner's name
*
• number of cylinders
*
• vehicle weight class
*
• air injection code
An important element of data collection relates to the need for studies
of program effectiveness and periodic revision of certain program elements.
Such studies would be particularly important during the early planning stages
and, if a contractor were selected towards the end of the contract period.
The Minnesota statute makes the following provisions for data collection
and studies:
*
to allow for make/model specific cut-points
86
-------
"Subd. 2. (STUDIES, DATA COLLECTIONS, ANNUAL REPORT.)
The commissioner and the agency shall collect data and undertake
studies as are necessary to evaluate the cost, effectiveness, and
benefits of the motor vehicle inspection program. The director,
the commissioner, the commissioner of transportation and the
director of the energy agency or their designees, shall jointly
constitute an advisory committee to consider among other issues
related to motor vehicle inspection the following:
(a) the cost, effectiveness, and benefits of the inspection
program;
(b) whether vehicles weighing over 8,500 pounds should be in-*
eluded in the inspection program;
(c) whether mandatory inspection of motor vehicles should be
extended to other areas of the state;
(d) the desirability of certification, licensing, or bonding of
repair facilities for the protection of the public; and
(e) the desirability of allowing official inspection facility
personnel to make minor adjustments with the consent of the
motor vehicle owner.
The director of the agency, or his designee, shall be the chair^
man of the committee. The director and the committee shall seek
information from the general public, consumer groups, environ-*-
mental groups, and the repair and parts industry regarding these
matters, and may establish an advisory committee on motor vehicle
inspection if it deems advisable. The agency shall report on these
matters and the general operation of the motor vehicle inspection
program to the legislature on or before January 1, 1982 and each
four years thereafter."
Mechanic Training
Some states specifically have provisions in the I/M enabling legislation
that mechanic training courses be conducted. Generally, the important aspects
of this section are to establish the requirement for such training and define
which agency is to be responsible for setting up and administering the pro^
gram. It is also possible that the designated agency would hire a contractor
solely for the purposes of designing and operating a mechanic training pro-
gram. In the Minnesota legislation the following wording is used:
"Sec. 8....(b) The agency, in cooperation with the commissioner,
shall provide information on motor vehicle repairs and conduct
vehicle repair seminars and training programs for the public and
repair industry."
Public Information Program
Some mention of the type of public information program and the approx-«-
imate scope it should encompass should be made. Enabling legislation should
specify who is empowered to establish this effort. The methods of information
promulgation (mass media, direct mailings, etc.) may be specified, Alternately,
it may be sufficient to state that each motor vehicle owner affected by an
87
-------
I/M program should be made aware of certain aspects of the program; i.e.,
program goals, program requirements, location and hours of inspection facil-
ities, etc. If Wisconsin establishes a contractor-run network with computer
capabilities, it can require that the contractor provide consumer protection
information along with a fail report to all owners of vehicles that do not
meet standards. This information may include, but not necessarily be limited
to, a list of probable conditions that are causing the vehicle to be out of
compliance and a list of recommended repair centers.
It is important to specify when the public information effort will com-
mence and the level of effort over time. The actual dissemination of infor-
mation should begin sometime prior to the program's starting date. Usually
this occurs between 6 months and 1 year prior to the first inspection.
The actual wording of the section of the enabling legislation dealing
with this issue will depend on how the phasein sequence is handled.
Minnesota dealt with this matter in the following manner:
"Sec. 8. (Public Information, Training.)
(a) The agency, in cooperation with the commissioner, and in con-
junction with the official inspection station contractor, shall
design, prepare, and implement a public education and information
program for the motor vehicle inspection program, including, but
not limited to, materials for distribution, presentations, mass
media releases, and other appropriate public educational items.
The public education program shall commence a minimum of six months
before mandatory motor vehicle inspection is required.
(b) The agency, in cooperation with the commissioner, shall pro-
vide information on motor vehicle repairs and conduct vehicle
repair seminars and training programs for the public and repair
industry."
88
-------
SECTION 7
COST ANALYSIS
METHODOLOGY
The technique used in developing the cost analysis presented in this Sec-
tion was to focus on specific cost categories, enabling very straightforward
comparisons between a network of state owned and operated, centralized facili-
ties and an identical network of private contractor owned and operated cen-
tral Lzed facilities. Table 16 provides a detailed outline of specific cost
categories, and elements thereof, that were used in the cost analysis.
All costs specified in this section , except where otherwise indicated,
are reported in constant 1978 dollars (i.e., inflation is assumed to be
nonexistent). Methodologies used in developing costs for the specific
elements outlined in Table 16 are discussed below.
Initial Capital Costs
These costs reflect the initial expenditures required for obtaining and
improving land, constructing the test facilities, obtaining and installing
primary test equipment, ancillary equipment, office equipment, and maintenance
equipment. These items are categorized into three primary elements: building
investments, land investments, and equipment costs.
Building Investments--
Building costs are obviously dependent on specific designs and features
utilized. For the centralized options being considered here, a general design
description was developed and submitted to the Wisconsin Department of Trans-
portation, Bureau of Real Estate, for an assessment of the likely unit cost.
The general building design calls for a clear span, metal structure, utilizing
metal sandwich panel walls with normal wall and ceiling finish for the admin-
istrative areas, and no wall or ceiling finish in the inspection areas. Items
such as central heating and air conditioning the administrative areas and air
exchange and forced hot air heaters in the inspection area were included. No
provisions were made for more specialized systems such as exhaust fume collec-
tors; these are included in equipment costs under the general category of
facility furnishings.
Based on the general design features described above, and on general size
requirements, the Bureau of Real Estate estimated that the cost of constructing
the buildings would be $25 per square foot. This value was used in the cost
evaluations presented here.
89
-------
TABLE 16. OUTLINE OF PROGRAM COST CATEGORIES AND ELEMENTS
Primary category
I. Initial Capital Costs
II. One-Time Start-Up Costs
Principal element
1. Building Investment
2. Land investment
3. Equipment costs
1. Land acquisition
2. Facilities planning
a.
a.
b.
a.
b.
c.
d.
a.
b.
a.
b.
c.
Items included
Construction cost
Actual land cost
Pavement and landscaping
Primary test equipment
Ancillary equipment
Office equipment/furniture
Maintenance equipment
Site location studies
Title transfer costs
Design study
Bid evaluation
Construction monitoring
3. Program design
4. Develop data handling systems
software
5. Personnel training
Personnel salaries and overhead
III. Annual Operating Costs
prior to start-up
7. Initial public information progra
8. Mechanics training program
1. Facility personnel
2 . Maintenance
3. Utilities/services/supplies
IV. Annual Administrative Costs 1. Program administrative personnel
2. Enforcement
3. Consumer protection/quality
assurance
4. Public information
5. Training, licensing, certification
Develop equipment specifications
Develop subprograms (e.g., public
information, surveillance, quality
control, enforcement, etc.)
Define personnel organizational
structure
Define data handling needs
Plan program effectiveness
studies
a. Inspectors
b. Managers
c. Quality control personnel
d. Mechanics training
a. Wages, benefits, etc.
a. Equipment
a. Electric
b. Heat
c. Insurance
d. Miscellaneous
e. Taxes
a. Wages, overhead
90
-------
It is noted here that discussions with one I/M contractor, Hamilton Test
Systems, indicate that the basic building costs could be significantly more
than the $25 per square foot being used in this analysis. Apparently, the
general building design typically utilized by Hamilton is much more substan-
tial than that proposed here, and the cost increases accordingly. In fact, it
has been indicated that a construction cost in the range of $35 to $40 per square
foot would be reasonable. In spite of these differences in cost estimated, the
unit cost provided by the State was used here to represent both state and con-
tractor operated options. This was done primarily because it is likely that
the state would actually define the building specifications with regard to
general type and it is assumed that the most economical design would be selected.
The Wisconsin I/M Task Force has indicated that the program will eventually
be expanded to include safety and noise testing as well as the emission inspec-
tion. The buildings, therefore, are designed large enough to accommodate this
expansion without additional construction. An analysis of the specific inspec-
tion tasks and equipment to be used was made to define the general features re-
quired of an inspection facility. Literature searches and interviews with
individuals involved in operating similar programs resulted in defining the
specific building requirements. A conceptual floor plan for the basic type of
facility required for emissions, safety and noise testing is shown in
Figure 10. Initially, the facilities would be used primarily for emissions
testing; Figure 10, however, includes equipment that would be included when
the expanded program (i.e., safety and noise testing) is fully operational.
The floor plan shows a one-lane facility; building areas required for facility
configurations ranging from one to six lanes are presented in Table 17.
The cost for each facility is computed as the product of (1) the building
area, and (2) the unit cost, $25 per square foot. The total cost for the net-
work is thus the sum of the costs of the individual stations shown in Table 18.
The total cost for the construction of facilities, by county, is presented in
Table 19; the total cost of all facilities is $5,323,375. This figure will
not vary between a state owned and operated network and a contractor owned and
operated system, for those reasons cited previously.
Land Investments—
A number of issues beyond the obvious one of land area are extremely cru-
cial in estimating land costs. The basic unit cost, for example, is, in most
instances, lot-specific to the extent that the per square foot cost may easily
vary by a factor of three within any block; within any municipality, the unit
cost may vary by a factor of ten or more. Available lots may also be limited
with respect to size requirements, necessitating the purchase of lots exceeding
the general requirements, or even the purchase of unwanted structures. It is
obvious, then, that a precise unit cost for land cannot be provided here.
Alternatively, estimates were developed by the Wisconsin Department of Trans-
portation, Bureau of Real Estate, based on the general requirements regarding
size, access, zoning, etc., for each municipality. These estimates, shown in
Table 20, reflect early 1978 average market values of available, unimproved
commercially zoned land located generally within a major arterial corridor.
Again it must be noted that these estimates represent the average of a fairly
wide range in actual unit costs.
91
-------
N3
f
•
1
REST ROOMS 85 ft
ADMINISTRATION
1,000 ft 2
STORAGE/UTILITY
35O ft 2 |
Htodlight
Check
Track
STATION 1 STATION Z
CHECK IN DYNAMIC ALIGNMENT LOADED MODE EMISSION
i n NOISE R ANALYSIS
EMPLOYEE
REST AREA
300 ft 2
WAIT/COUNCIL
960 ft 2
j
' STATION 3 1 STATION -4
TIRES, VISUAL BRAKE and DYNAMIC BRAKE TEST
EXHAUST SYSTEM
M UNDER HOOD |
U
1 i— n
1 ... | r*ut:s>u m
1 J LJJ
ir T
^
>
TOTAL TEST AREA'3,200ft 2
TOTAL NONTEST AREA =2,695 ft2
TOTAL BUILDING AREA: 5,895 ft2
Figure 10. Conceptual floor plan for a combined safety, noise, and loaded-mode
emission inspection facility.
-------
TABLE 17. FLOOR AREA REQUIREMENTS FOR VARIOUS FACILITY CONFIGURATIONS-
EMISSIONS TESTING WITH CAPABILITY TO EXPAND TO INCLUDE SAFETY
AND NOISE TESTING
Floor area required, ft2
Configuration „, „ 1
e Test ., . . . .. Employee
Administration J.
area rest
1-lane
2- lane
3- lane
4- lane
5-lane
6-lane
3,200
6,400
9,600
12,800
16,000
19,200
1,000
1,000
1,000
1,000
1,000
1,000
300
350
410
450
500
550
Storage
350
400
450
500
550
600
Waiting
960
1,440
2,240
3,360
4,800
6,560
Rest
rooms
85
85
85
85
85
85
Total
5,895
9,675
13,785
18,195
22,935
27,995
Callender, J. H., Time Saver Standards for Architectural Design. McGraw-Hill.
1974.
TABLE 18. INSPECTION NETWORK REQUIREMENTS
County
Brown
Dane
Kenosha
Milwaukee
Ozaukee
Racine
Walworth
Washington
Waukesha
Municipality
Green Bay
Madison
Madison
Kenosha
Milwaukee
Greenfield
Meguon
Racine
Elkhorn
West Bend
Brookfield
Waukesha
Number of facilities
1
1
1
1
2
1
1
1
1
1
1
1
Configuration,
lane
4
4
3
3
6
3
2
4
2
2
4
3
Total network
13
46
93
-------
TABLE 19. BUILDING COST ESTIMATES
County Facility
configuration
Brown
Dane
Kenosha
Milwaukee
Ozaukee
Racine
Walworth
Washington
Waukesha
Total
4- lane
4- lane
3- lane
3- lane
6- lane
3- lane
2- lane
4- lane
2-lane
2-lane
4- lane
3- lane
Per facility Number of Total
cost, $ facilities required cost, $
454,875
454,875
344,625
344,625
699,875
344,625
241,875
454,875
241,875
241,875
454,875
344,625
1
1
1
1
2
1
1
1
1
1
1
1
454,875
454,875
344,625
344,625
1,399,750
344,625
241,875
454,875
241,875
241,875
454,875
344,625
5,323,375
TABLE 20. ESTIMATED LAND VALUES FOR COMMERCIALLY-ZONED
LAND IN NINE SELECTED WISCONSIN COUNTIES
County
Brown
Dane
Kenosha
Milwaukee
Ozaukee
Racine
Walworth
Washington
Waukesha
Municipality /area
Green Bay
Madison
Kenosha
Milwaukee
Greenfield
Meguon
Racine
Elkhorn
West Bend
Brookfield
Waukesha
*
Estimated value,
$/ft2
1.70
2.00
1.70
1.50
1.50
0.60
0.75
0.67
0.85
2.50
2.30
ft
Source: Wisconsin Department of Transportation,
Bureau of Real Estate.
94
-------
Specific lot size requirements are a function of facility configurations.
A general relationship exists between land area required and test facility size.
Specifically, a ratio of land area to building area can be derived based on
queuing and zoning requirements; for Wisconsin, this ratio is approximately
5:1. Since building area requirements have been derived (see Table 17) land
areas may be easily calculated.
•
Improvements to the land are also included in this category. This in-
volves primarily pavement and landscaping. Estimates provided by the Bureau
of Real Estate indicated that the unit costs for black-top paving and standard
finish landscaping are approximately $0.80 per square foot and $0.25 per square
foot, respectively. Total land investments, including improvements are pre-
sented in Table 21.
Equipment Costs—
The major equipment items required to operate a loaded-mode emissions test
facility were identified based on analyses of inspection task requirements and
conversations with individuals currently involved in these types of testing
programs. It is assumed here that equipment required to perform the safety and
noise aspects of the program will not be purchased until the expansion to in-
clude these inspections occurs. This will ensure that the most recent state-
of-the-art equipment be purchased.
The equipment cost estimates used in this study were developed primarily
from interviews with manufacturer's representatives. These interviews focused
on identifying the most appropriate type and model for various major items and
determining the general level of skill required to operate and maintain each.
Outlined in Table 22 are the equipment requirements and associated costs for
a loaded mode emission inspection program.
Equipment costs for any facility configuration, then, can be derived from
Table 22. A summary of equipment costs as a function of the facility config-
uration is shown in Table 23.
The total network cost for equipment can be computed based on the number
of facilities by configuration, developed previously. These costs, presented
in detail in Table 24, total $3,179,000.
In addition to these equipment costs, three additional items must be in-
cluded in the total network equipment costs; these include calibration vans
and equipment, security systems, and a central computer.
One calibration van is required for each maintenance/calibration person.
In Section 3, it was determined that five maintenance/calibration people would
be required. The cost summary for each van is presented below:
% ton light duty van $ 5,500
Spare analyzer 26,500
Tools, gases, etc. 1,OOP
Total cost per van $33,000
95
-------
TABLE 21. ESTIMATED LAND INVESTMENT REQUIREMENTS BY COUNTY
County
Brown
Dana
tenoeba
Milwaukee
Ozaufcee
Racine
Ualworth
Facilltiea
Municipality requlred
Madiaon 1
lenoaha 1
Klltnukee 2
Greenfield 1
Neguoa 1
Racine 1
Klkborn 1
Brookflald 1
Configuration
4- lane
3- lane
3- Ian*
6- lane
3-Une
2-lane
4- lane
2-lane
4-laoe
3-lane
Lot «iu
per facility
90,975
69,925
68,925
139,975
48,375
90,975
48,375
90.975
68.925
Land
coat per
2.00
2.00
1.70
1.50
1.50
0.60
0.75
0.67
2.50
2.30
Coat per
facility
181,950
137,850
117,173
209,963
103,388
29,025
68,231
32,411
227.438
158,528
Total
coat all
facilities
181.950
137,850
117,173
419.926
103,388
29,025
68,231
32,411
227,438
158.528
1,671.697
Totil
queu*
(ft2)
20,000
15,000
15,000
60.000
15,000
10,000
20,000
10.000
20.000
15,000
Total parking
areaa all
facillttea
(ft2)
5,940
4,725
4,725
17,550
4,725
3,105
5,940
3,105
5,940
4,725
Total paved
areas all
facllltlea
(ft2)
25,940
19,725
19,725
77,550
19,725
13,105
25,940
13,105
25,940
19.725
Paving
coat
pet ft2
(S)
0.80
0.80
0.80
0.80
0.80
0.80
0.80
0.80
0.80
0.80
Total
paving coat
20,752
15.780
15,780
62,040
15,780
10.484
20,752
10,484
20,752
15,710
239.620
Total
landscaped
area, all
(ft2)
-6,840
35,415
35,415
146,420
35.415
25.595
46.840
25,595
46,840
35.415
cost per ft2
0 25
0 25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
Total
landscaping
cost (S)
11,710
8,854
8,854
36,606
8,854
6,399
11,710
6,399
11.710
8,854
138,059
Total
improvement*
(S)
32,462
24,634
24,634
98,646
24,634
16,883
32,462
16,883
32,462
24,634
377.679
Total land
($)
214,412
162,484
141,807
518,572
128.022
45,908
100.693
49,294
58,002
259.900
183,162
2,049.376
-------
TABLE 22. MAJOR EQUIPMENT ITEMS REQUIRED FOR LOADED-MODE EMISSIONS TESTING
Program element
Itera
Remarks
Unit cost
($)
I. Emissions 1, Chassis dynamometer
2. Er&ission
IT. Data System 1. CRT Terminals
2. Minicomputer
Needed for loaded-mode emission test.
One unit per test lane required. Cost
based on co-avers at ions with manufacturers
(Clayton, Maxwell),
Since loaded-mod*? is used, analyzer should
be capable of measuring CO. HC, and NOx-
Extremely wide range in analyzer costs;
cheaper analyzers found to be inadequate.
Analyzers should be Capable of being tied
into computer data handling system. Costs
based on discussions with manufacturers
(ulss)u-Horiba, Hamilton Test Systems). One
unit per test lane required.
Two required per lane. Costs based on liter-
ature and discussions with manufacturer's
representative^ (Honeywell, Digital, Olivetti,
Speiry Univac), and experiences of other
states.
One required per facility (equivalent to
Digital PDP-11-05). Generally assumed to be
included in the cost of facility furnishings.
III. Miscellaneous 1. Miscellaneous tools Ar required.
14,000
26.500
2,500
80,000
1,000
-------
TABLE 23. EQUIPMENT COSTS AS A
FUNCTION OF FACILITY
CONFIGURATION
Number of „ .
1 Equipment costs,
1 126,500
2 173,000
3 219,500
4 266,000
5 312,500
6 359,000
98
-------
TABLE 24. EQUIPMENT COSTS FOR LOADED MODE TESTING NETWORK
County Municipality
Brown Green Bay
Dane Madison
Madison
Kenosha Kenosha
Milwaukee Milwaukee
Greenfield
Ozaukee Meguon
Racine Racine
Walworth Elkhorn
Washington West Bend
Waukesha Brookfield
Waukesha
Total network
Facility Number of
configuration facilities
4-lane
4- lane
3- lane
3- lane
6- lane
3-lane
2-lane
4-lane
2-lane
2-lane
4-lane
3-lane
Calibration vans and equipment (5 @ $33,000
Central computer
Security systems
Quality assurance van and
equipment (1 @ $33
1
1
1
1
2
1
1
1
1
1
1
1
each)
,000)
Equipment cost
per facility, $
266,000
266,000
219,500
219,500
359,000
219,500
173,000
266,000
173,000
173,000
266,000
219,500
Consumer complaints investigator's van and
equipment (1 @ $33,000)
Total cost
of equipment , $
266,000
266,000
219,500
219,500
718,000
219,500
173,000
266,000
173,000
173,000
266,000
219,500
3,179,000
165,000
250,000
14,300
33,000
33,000
3,674,300
-------
In addition, the quality assurance investigator and the consumer complaint
investigator would each have a calibration van and equipment at a cost of
$33,000 each.
The entire network would be tied into a central computer equivalent in
capability to a Digital PDP-11-35. Cost estimates were obtained from several
manufacturer's representatives, including Digital, Olivetti, Honeywell, and
Sperry Univac, and an average cost of approximately $250,000 was derived.
Each facility should be equipped with security systems to protect against
theft and/or vandalism. A contractor has suggested a cost of $1,100 per
facility for purchase and installation of security systems. This translates
to a total cost of $14,300 for the entire network. The total equipment cost
estimate, itemized in Table 24, is $3,674,300.
The capital costs anticipated for both the state and contractor operated
options are identical, and are summarized in Table 25.
TABLE 25. INITIAL CAPITAL COST SUMMARY
Category
Building investment
Land Investment
Item
Construction
Purchase
Paving
Landscaping
Item cost, $
5,323,375
1,671,697
239,620
138,059
Category cost, $
5,323,375
Equipment investment Facility equipment 3,179,000
Calibration vans 165,000
Central computer 250,000
Security systems 14,300
Quality Assurance van 33,000
Complaint investiga- 33,000
tor's van
Total capital costs
2,049,376
3.674,300
11,047,051
100
-------
One-Time Start-Up Costs
Implementation of an I/M program will require the expenditure of monies
for non-capital items and services on a one-time basis prior to the actual
start-up. Costs associated with this category are perhaps the most difficult
to define at this point primarily because the elements involve services
(program planning, design, development, etc.), which are inherently much more
variable in cost than, for instance, equipment or building costs. Considerations
used in developing cost estimates for each element are discussed with the
presentation of the individual estimates as follows.
Land Aquisition—
Included in this element are the costs for identifying and locating candidate
sites, negotiating purchase price, and completing title transfers. Site loca-
tion and price negotiation would involve approximately 200 man-hours of profes-
sional technical time, plus 40 man-hours of professional legal time for each
site. To translate man-hours to actual cost figures, a $20 per hour and
$50 per hour value were assigned to technical and legal hours, respectively;
this represents a total cost of $6,000 per site to cover location and negotia-
tion. Title transfer involves physical surveys, title searches, site plan
preparation, and miscellaneous support functions required to execute the
purchase. The cost associated with this component is estimated to be approxi-
mately 10 percent of the unimproved land value. No difference in cost is
anticipated between the state owned and contractor owned options.
For the network described previously, a total of 13 sites are required
reflecting a total unimproved land investment of $1,671,697. The cost for
land aquisition, then, is calculated below:
(13 facilities)($6,000/facility) + (0.10)($1,671,697)
= ($78,000 + $167,170) = $245,170
Facilities Planning—
This element reflects the costs associated with engineering and design for
the test facilities, bid review, and construction monitoring. Since the plan-
ning process involves bidding procedures, it is anticipated that the State
would be tied to various regulations specifying the minimum number of bids it
must receive and evaluate, etc. The contractor, on the other hand, may have
in-house capabilities in this respect, or, at least would not be tied to the
same bidding procedures as the State. In both instances the value of these
services is estimated to be a function of the total building cost. Although
it is difficult to quantify the State's disadvantage in this process, a value
of 15 percent of the construction cost is estimated for facilities planning
under a contractor system, while for the State-run option, a value of 20 percent
is used. Since the total building cost is estimated to be $5,323,375, the
planning cost can be calculated for both the state-run and contractor-run
options as:
101
-------
State-run
C0.20)($5,323,375) = $1,064,675
Contractor-run
(0.15)($5,323,375) = $798,506
Program Design—
The costs associated with program design reflect additional planning studies
required to establish specific formats for the operation and administration of
both the actual inspection program and adjunctive programs such as public infor-
mation, mechanics training, etc. These costs are likely to be quite variable
depending on factors such as the extent of in-house effort undertaken by the
State. In deriving an estimate, the experiences of other states were weighed
most heavily in our analysis of the likely requirements specific to Wisconsin.
Based on the analysis an estimated of $100,000 was derived as the program design
estimate for both contractor and state run alternatives.
Data Handling Software Development—
A comprehensive data handling software package will be required to provide
both basic record keeping and program analysis functions. In developing an
estimate experiences of other states, conversations with representatives of
commercial data processing firms, and an analysis by our own staff were taken
into consideration. Based on these discussions and our analysis of the likely
requirements specific to Wisconsin, an estimate of $200,000 was developed for
this element.
Personnel Training—
Personnel training will require both an ongoing effort as well as an
intensive initial program to essentially train and certify the entire staff
of inspectors, managerial, and maintenance/calibration personnel. A similar
effort will be required to provide a mechanics training program to adequately
prepare the repair industry for the maintenance phase of the program. This
will be discussed separately.
To develop cost estimates for training, it was considered that a logical
approach would be for the managers and assistant managers to be trained as
instructors, allowing a continuation of the training program after initiation
of the program without the necessity of a full time instructor. Managers would
be able, then, to train any new employees themselves. The managers, also
would be able to provide training for the inspectors and calibration/maintenance
personnel.
Cost estimates for training were developed based on information obtained
from the Colorado State University program. The estimated costs for training
was found to be $53.00 for each manager and assistant manager, and $16.00 for
each inspector and calibration/maintenance person.
10:
-------
For discussion with states and private contractors involved with the
programs, the personnel requirements were derived as follows:
• One manager and one assistant manager per facility
• Three inspectors per test lane
• One maintenance/calibration person for every 10 lanes
Applying these rates to the facility requirements developed previously,
the basic operating personnel requirements are:
• 13 managers
• 13 assistant managers
• 138 inspectors
• 5 maintenance/calibration persons
Using these personnel requirements and training costs derived previously,
the cost of having operating personnel can be determined. This is computed
as:
(13 managers)($53.00) + (13 assistant managers)C$53.00)
4- (138 inspectors)($16.00) 4- (5 maintenance/calibration persons)($16.00)
= $3,666.00
In addition to operating personnel, the state will be required to train both
a consumer complaints and a quality assurance investigator. A cost for inves-
tigator training was previously derived as $59.00. The cost of training the
two individuals necessary may be calculated as follows:
(two investigators/officials)($59.00) = $118.00
The total cost, then, is the sum of the cost of training operating personnel
plus the cost of training investigators, or:
$3,666.00 + $118.00 = $3,784.00
Personnel Salaries—
The costs for operating and administrative personnel were derived from
"Classification and Compensation Plan" 1977 to 1978, Department of Administration,
State Bureau of Personnel. Salaries were matched with position classifications
most closely matching job descriptions of the positions previously defined.
With one exception, salary levels used were those for "starting" personnel. The
notable exception was the position of station manager. Since the managers would
be involved in the many aspects of computer operation necessary in a highly
automated system as was defined previously, the managers salary was assumed
started at 25 percent more than the comparable position classification. Salaries,
by position, are shown in Table 26.
103
-------
TABLE 26. ESTIMATED HOURLY STARTING SALARIES FOR
ADMINISTRATIVE AND OPERATIONAL PERSONNEL
INVOLVED IN INSPECTION AND MAINTENANCE
PROGRAMS IN WISCONSIN
I/M Job title State classification Hourly^salary
Administrator Administrative officer 5 12.91
Legal counsel Attorney
(all types start at:) 7.47
Purchasing officer Purchasing agent 1 6.54
6.25
Contracts officer
Accountants Account examiner 1 3.85
or accountant 1 6.05
Engineer Environmental engineer 1 6.68
or engineering technician 1 5.21
Systems analyst Research analyst 1 5.42
or research analyst 2 5.78
Mechanic training program Program coordinator 7.09
coordinator or training officer 1 6.54
Consumer complaints Public information officer 4 7.70
investigator or public information officer 1 4.92
Public relations Public information officer 4 7.70
coordinator
Instrument repair Maintenance mechanic 3 5.91
technician
Inspection station Motor vehicle investigation 7.70
supervisor supervisor 3
Motor vehicle inspector Motor vehicle inspector 1 5.21
SOURCE: Bureau of Personnel
Wisconsin
(608) 266-3626
104
-------
In addition to salaries, a 25 percent overhead charge was added to cover
employee benefits and employee charged social security taxes.
All managerial personnel are assumed phased into the program 6 months
prior to start-up; inspectors and maintenance/calibration persons are phased
into the program 1 month prior to start-up.
Given the above defined phase-in and salary schedules, a total personnel
cost estimate for start-up can be derived:
(13 managers)($1,667.00 per month)(6 months)
4- (13 assistant managers)($1,125.00 per month)(6 months)
+ (5 maintenance/calibration persons)($1,000.00 per month)(1 month)
+ (138 inspectors)($867.00 per month)(1 month) 1.25J
= $428,028
The adminstrative personnel costs must also be included in the start-up
phase. For the State-run option, these persons would be phased-in 24 months
prior to start-up. For the contractor-run option, these persons would be
phased in 12 months prior to start-up. Based on personnel requirements and
salaries presented earlier, the costs associated with start-up can be computed
for both the state and contractor options. These are shown in Table 27
and 28, for the state and contractor options, respectively. The total
personnel cost for start-up, then, is the total of the operational personnel
and administrative personnel costs, or:
State-run
$428,028 + 230,834 = $658,862
Contractor-run
$428,028 + 175,418 = $603,446
Initial Public Information Program—
The experience this far with I/M program operation indicates a definite
requirement for an intensive public information effort prior to the actual
start-up of the program. Based on the experiences of other states, the effort
should begin approximately 12 months prior to start-up. This time requirement
is discussed in greater detail in Section 4. A preimplementation budget of
$0.12 per vehicle to be tested has been suggested. The average annual number
of vehicles to be inspected for the period of 1982 to 1987 has been projected
at approximately 1,700,000, which translates to an initial public information
expenditure of $204,000.
105
-------
TABLE 27. ADMINISTRATIVE PERSONNEL COSTS ASSOCIATED WITH PROGRAM
STARTUP, STATE-RUN OPTION
Number Annual _, .....
,. , Participation
Job tltle °* Sa^7 (months)
positions ($)
Administrator
Training officer
Legal advisor
Engineering coordinator
Systems engineer/analyst
Financal coordinator
Accountant
Consumer protection investigator
Quality assurance investigator
Consumer protection/quality
assurance supervisor
Clerical support
Total salaries for 24 months
Overhead @ 25 percent
Totals
1
1
1
1
1
1
1
1
1
1
2
12
25,000
13,000
15,000
15,000
11,000
15,000
12,000
15,000
15,000
15,000
9,000
24
12
6
18
1
24
6
1
2
12
24/each
Salary
startup period
($)*
50,000
13,000
7,500
22,500
917
30,000
6,000
1,250
2,500
15,000
36,000
184,667
46,167
230,834
Salary for participation during 24-month startup period (all positions).
106
-------
TABLE 28. ADMINISTRATIVE PERSONNEL COSTS ASSOCIATED WITH PROGRAM
STARTUP, CONTRACTOR-RUN OPTIONS
Number
Job title of
positions
Administrator 1
Training officer 1
Lena! advisor 1
Engineering? coordinator 1
Systems engineer analyst 1
Financial coordinator 1
Consumer protection 1
Quality assurance
investigators 1
Consumer protectlon/qualtiy
assurance supervisor 1
Clerical 1
Total salaries for
state personnel
Overheat! P 25 percent
Total state cost
Contractor personnel:
Administrator for station
operations 1
Legal counsel 1
Purchasing /con tracts
officer 1
Engineer /analyst 1
Inspector training
coordinator 1
Clerical 1
Total salaries for contractor
personnel
Overhead P 25 percent
Total contractor cost
Annual
salary
($)
25,000
13,000
15,000
15,000
11,000
15,000
15,000
15,000
15,000
9,000
25,000
15,000
13,000
11,000
13,000
9,000
Participation
(months)
12
6
4
6
1
6
1
2
6
12
12
6
12
12
2
12
TOTAL COST
Salary
startup period
($)*
25,000
6,500
5,000
7,500
917
7,500
1,250
2,500
7,500
9,000
72,667
18,167
90,834
25,000
7,500
13,000
11,000
2,167
9,000
67,667
16,917
84,584
- 175,418
Salary for participation during 12-month startup period.
107
-------
Mechanics Training Program—
A complete discussion of the anticipated mechanics training program is
presented in Section 5. Based on this discussion, the cost of training mechanics
was derived for three levels of participation ((1) minimum number of facilities
to accommodate the vehicle population, (2) maximum number of facilities where
each station would in theory reach a break-even point from revenue taken in
from inspections, and (3) a midpoint value of the maximum and minimum number
of facilities). For the purpose of this cost estimate, a 50 percent participa-
tion rate is assumed. This translates to a total of 1,640 dealers, repair
shops, and service stations, and a cost of $36,080 (based on $22 per mechanic
and one mechanic per shop). The additional two instructors will need to be
trained at an estimated cost of $150 each. The total initial startup cost for
the mechanics training program, then, is the total of the cost to train in-
spectors plus the cost to train mechanics:
$300 + $36,080 = $36,380
A summary of anticipated startup costs is presented in Table 29.
TABLE 29. SUMMARY OF STARTUP COSTS
Item
Land aquisition
Facilities planning
Program design
Data handling software development
Personnel training
Personnel salaries and overhead
Public information
Mechanics training
Totals
State-run
option
$ 245,170
1,064,675
100,000
200,000
3,784
658,862
204,000
36,380
$2,512,871
Contractor-run
Option
$ 245,170
798,506
100,000
200,000
3,784
603,446
204,000
36,380
$2,191,286
108
-------
Annual Operating Costs
Annual operating costs include all costs associated with the actual oper-
ation of the program. For the purposes here, the costs of adjunctive programs
(e.g., public information, inspection/mechanic training, etc.) are included
under "Annual Administrative Costs," which are discussed later.
Facility Personnel—
Annual determinants of costs associated with the operation of the inspec-
tion facilities are: (1) the total number of individuals and relative level
of job responsibility, and (2) the per-unit cost of wages and overhead.
In computing personnel costs, the personnel requirements and wage scale
derived previously were employed. The per-hour wage rates for various catego-
ries were derived from data obtained from the State of Wisconsin Bureau of
Personnel, Department of Administration, and the overhead estimates were based
on data from the U.S. Department of Labor and State data, and from conversations
with private contractors involved in operating I/M programs. The hourly over-
head rate was determined to be 25 percent of the basic hourly wage rate.
Applying the facility staffing requirements and annual salaries associated
with job category, the annual personnel costs can easily be computed. This
estimate, shown in Table 30, is assumed the same for both the contractor-
run and state-run options.
TABLE 30. ANNUAL PERSONNEL COSTS FOR FACILITY PERSONNEL
Job title
Manager
Assistant manager
Calibration/maintenance
Inspectors
Total salaries
Overhead at 25%
Total number
of positions
13
13
5
138
Annual
Salary ($)
20,000
13,500
12,000
10,400
Total annual salary
for all positions ($)
260,000
175,500
60,000
1,435,200
1,930,700
482,675
2,413,375
Maintenance—
Costs associated with equipment maintenance reflect equipment repair
and preventive maintenance expenditures. In this connection, the yearly
cost of these items was estimated to be 20 percent of the original equipment
cost. Specifically, this would be:
($3,179,000)(20 percent) = $635,800
109
-------
Utilities/Services/Supplies
Included in this element are the costs associated with electricity, heat,
water, building services, insurance, office supplies, uniforms, inspection
forms, etc. These costs were estimated based on several sources concerning
equipment and facility power requirements determined from manufacturers and
the general literature and the prevailing utility rates in the state, average
heating requirements data for similar facilities, insurance costs and general
building service requirements from existing programs.
Utilities-
Annual cost for utilities were derived from electric usages experienced
by other states. For loaded-mode emission testing in the absence of safety,
the rates were found to be: 120 kWh/day for each lane, and 325 kWh/day per
facility. An average per kilowatt cost of $0.05 kWh was obtained from
Wisconsin Power and Light. The annual cost for utilities, then, is calcu-
lated below:
(46 hours)(120 kWh/day)($0.05/kWh)(250 operating days/year)
+ (13 facilities)(325 kWh/day)($0.05/kWh)(250 operating days/year)
= $69,000 + $52,813 = $121,813 annually
Insurance—
It is assumed that the facilities would be covered by liability, fire,
theft and vandalism insurance. A contractor from another state has suggested
a cost of approximately $l,500/lane. Annual costs based on this estimate are
calculated below:
(46 lanes)($l,500/lane) = $69,000 annually
Computer Operation—
Based on discussions with a contractor from another state, and with repre-
sentatives of several data processing firms, an estimated central computer
operation cost for an automated inspection system of $0.15 per test has been
derived. This translates to an annual cost of $255,000 for central computer
operation.
Inspection Forms—
The inspection forms serve the purpose of reporting the test results and
authorizing as well as providing diagnostic information should repairs be
necessary. A cost of $0.03 per test has been derived based on the experience
of a contractor from another state. This computes to a total test forms
cost of $51,000 annually.
Calibration Costs—
The recurring annual cost of equipment calibration, in addition to per-
sonnel salaries previously presented, is defined as the cost of calibration
gases plus the operating cost of the maintenance/calibration vans. The total
annual calibration costs are outlined in Table 31, and were found to be
$55,000.
110
-------
TABLE 31. ANNUAL CALIBRATION COSTS
Item Cost ($)
Calibration gases (13 sets/year at $200/set) 2,600
Maintenance on van and equipment (20% of purchase price) 6,600
Operating cost ($0.15/mile, 12,000 miles) 1,800
Cost per calibration/maintenance van 11,000
Vans 5
Annually 55,000
Taxes—
Under a contractor-run option, costs for general property and real estate
taxes must be included. Taxes were calculated based on full value rates for
each individual municipality. General property is defined as the building
value and equipment; real estate is the land plus improvement. Total annual
taxes are itemized by municipality in Table 32. The "additional equipment"
category includes vans and cars, the central computer, and the facilities
security systems.
Uniforms—
Each facility employee is assumed to be furnished a set of uniforms.
From discussions with uniform suppliers, an annual cost per employee of
$125.00 was derived. This translates to a total annual cost of $21,125 for
169 uniformed employees.
The total annual cost for utilities, services, and supplies is provided
in Table 33 for both the state-run and contractor-run options.
Annual Administrative Costs
Costs involved in this category reflect the overall program administrative
effort. Specifically, the salaries of personnel involved in areas such as
enforcement, consumer protection, public information, training, and certifi-
cation are included. Also, the operating costs for quality assurance and
consumer protection vehicles fall into this category.
Program Administrative Salaries and Overhead—
Annual administrative personnel costs are computed from the personnel
requirements and salaries delineated previously. The annual cost computations
for both the state-run and the contractor-run options are provided in Tables
34 and 35.
Ill
-------
TABLE 32. ANNUAL TAXES - CONTRACTOR-RUN OPTION
N>
County
Brown
Dane
Kenosha
Milwaukee
Ozaukee
Racine
Walworth
Washington
Uaukesha
Additional
Total
Municipality
Green Bay
Madison
Madison
Kenosha
Milwaukee
Greenfield
Mequon
Racine
Elkhorn
West Bend
Brookfield
Waukesha
Equipment
Facilities/ General property
lanes value (S)
1/4
1/4
1/3
1/3
2/6 ea.
1/3
1/2
1/4
1/2
1/2
1/4
1/3
720,875
720,875
564,125
564,125
2,117,750
564,125
414,875
720,875
414,875
414,875
720,875
564,125
495,300
8,997,675
General property
tax rate*
0.02758
0.03174
0.03174
0.02931
0.04270
0.02974
0.02557
0.03322
0.03045
0.02185
0.02531
0.02412
0.04270**
-
General property Real estate
tax (S) value (S)
19,882
22,881
17,905
16,535
90,428
16,777
10,608
23,947
12,633
9,065
18,245
13,607
21,149
293,662
187,120
214,412
162,484
141,807
518,572
128,022
45,908
100,693
49,294
58,002
259,900
183,162
-
2,049,376
Real estate*
tax rate
0.02317
0.02704
0.02704
0.02556
0.03592
0.02524
0.02236
0.02826
0.02594
0.02012
0.02216
0.02124
-
-
Real estate
tax ($)
4,336
5,798
4,394
3,625
18,627
3,231
1,027
2,846
1,279
1,167
5,759
3,890
-
55,979
Total taxes
annually (S)
24,218
28,679
22,299
20,160
109,055
20,008
11,635
26,793
13,912
10,232
24,004
17,497
21,149
349,641
Source: Town, Village, and City Taxes - 1976, Bulletin Nos. 176, 276 and 376 combined, Wisconsin Department of
Revenue, Division of Research and Analysis, Bureau of Local Financial Assistance.
Additional equipment assuned housed in Milwaukee.
-------
TABLE 33. ANNUAL COST FOR UTILITIES, SERVICES, AND
SUPPLIES - STATE VERSUS CONTRACTOR-RUN OPTIONS
State-run option Contractor-run option
cost ($) cost ($)
Utilities 121,813 121,813
Insurance 69,000 69,000
Computer operation 255,000 255,000
Inspection forms 51,000 51,000
Calibration costs 55,000 55,000
Taxes 0 (exempt) 363,476
Uniforms 21,125 21,125
Total 572,938 936,414
113
-------
TABLE 34. ANNUAL ADMINISTRATIVE PERSONNEL COSTS -
STATE-RUN OPTION
Position Number
Administrator
Training officer
Legal advisor
Systems engineer/analyst
Financial coordinator
Accountant
Consumer protection
investigator
Quality assurance
investigator
Consumer complaints/quality
assurance supervisor
Hot-line operator
Clerical
Total salaries annually
Overhead @ 25 percent
TOTALS
1
1
1
1
1
1
1
1
1
1
2
12
Annual Total
salary Participation annual
(rate) (months) salary
($) ($)
25,000
13,000
15,000
11,000
15,000
12,000
15,000
15,000
15,000
9,000
9,000
12
6
2
12
12
12
12
12
12
12
12/each
128
25,000
6,500
2,500
11,000
15,000
12,000
15,000
15,000
15,000
9,000
18,000
144,000
36,000
180,000
114
-------
TABLE 35. ADDITIONAL ADMINISTRATIVE PERSONNEL COSTS
FOR CONTRACTOR OPTION
Position
state Number
personnel
Administrator 1
Training officer 1
Systems engineer/
analyst 1
Financial coordinator 1
Consumer protection
Investigator 1
Quality assurance
investigator 1
Consumer complaints/quality
assurance supervisor 1
Hot-1 tne operator 1
Clerical 1
Total state salaries
Overhead @ 25 percent
Total state cost
Administrator for station
operations 1
Legal counsel 1
Purchasing/contracts
officer 1
Engineer/analyst l
Clerical 1
Total constractor
salaries
Overhead @ 25 percent
Total contractor cost
TOTAL COST
Annual
salary
(rate)
($)
25,000
13,000
11,000
15,000
15,000
15,000
15,000
9,000
9,000
25,000
15,000
13,000
11,000
9,000
Participation
annually
(months)
12
6
6
6
12
12
12
12
12
12
1
12
12
12
Total
annual
salary
($)
25,000
6,500
5,500
7,500
15,000
15,000
15,000
9,000
9,000
107,500
26,875
134,375
25,000
1,250
13,000
11,000
9,000
59,000
14,750
73,750
208,125
115
-------
Vehicle Operating Costs—
The Quality Assurance and Consumer Complaints investigators will each
have a van equipped with an analyzer and calibration equipment. Assuming
an operating cost of $0.15 per mile, and annual travel of 12,000 miles, the
yearly operating cost for the two vans is:
(2 vehicles)(12,000 miles/vehicle)($0.15/mile) = $3,600
Public Information—
The actual cost of public information can only be determined by state
officials on an annual basis. A contractor from another state has suggested
$0.12 per vehicle to be inspected as a reasonable estimate of the anticipated
expenditure. The average projected population for 1982-1987 is 1,700,000
effected vehicles, which translates to an annual public information cost of
$204,000.
Personnel Training—
This element reflects the ongoing requirement to train new operating
personnel. The replacement rate, number of new inspectors annually, was
estimated to be 10 percent, based on experience of other states. An inspector
work force of 169 was previously derived, translating to 17 new inspectors
annually. The cost of training a new inspector was previously found to be
$16.00, therefore the entire cost is:
17 persons at $16/person = $272.00
Summary
The total cost for both the state-run and contractor-run options are
itemized in Tables 36 and 37.
FEE COMPUTATION
Annualized Costs
In order to compare costs of the two options and to devise a "break-even"
fee, all costs found in Tables 36 and 37 are converted into annual figures.
The steps involved in calculating these annual costs and the fees are summarized
below.
Initial Capital Costs —
The primary elements associated with this category are the costs associated
with land, buildings, and equipment. These costs were computed in constant
1978 dollars using appropriate amortization factors.
Since land yields services in perpetuity, the amortization factor is assumed
to be the marginal rate of return on capital. This factor, then, is sensitive
to the source of financing (i.e., equity, debt, or taxes). For this analysis,
a factor of 0.06 is assumed.
116
-------
TABLE 36. COST SUMMARY - STATE-RUN OPTION
I.
II.
III.
IV.
> Primary category
Initial Capital Costs 1.
2.
3.
One-Time Start-up Costs 1.
2.
3.
4.
5.
6.
7.
8.
Annual Operating Costs 1,
2.
3.
Annual Administrative Costs 1.
2.
3.
4.
Principal element
Building investment
Land investment
Equipment costs
Land acquisition
Facilities planning
Program design
Software development
Personnel training
Personnel salaries and overhead
Public information
Mechanics training
Personnel
Maintenance
Utilities/ services /supplies
Personnel
Vehicle operation
Public information
Personnel training
Element cost
($)
5,323,375
2,049,376
3,674,300
245,170
1,064,675
100,000
200,000
3,784
658,862
204,000
36,380
2,413,375
635,800
572,938
180,000
3,600
204,000
272
Total
category
cost ($)
11,047,051
2,512,871
3,622,113
387,872
-------
TABLE 37. COST SUMMARY - CONTRACTOR-RUN OPTION
oo
Primary category
I. Initial Capital Costs
II. One-Time Start-up
III. Annual Operating Costs
IV. Annual Administrative Costs
1.
2.
3.
1.
2.
3.
4.
5.
6.
7.
8.
1.
2.
3.
1.
2.
3.
4.
Principal element
Building Investment
Land investment
Equipment costs
Land acquisition
Facilities planning
Program design
Software department
Personnel training
Personnel salaries and overhead
Public information
Mechanics training
Personnel
Maintenance
Utilities/services/supplies
Personnel
Vehicle operation
Public information
Personnel training
Element cost
($)
5,323,375
2,049,376
3,674,300
245,170
798,506
100,000
200,000
3,784
603,446
204,000
36,380
2,413,375
635,800
922,549
208,125
3,600
204,000
272
Total
category
cost ($)
11,047,051
2,191,286
3,971,724
415,997
-------
Structures are assumed to have a 20-year service life and to yield equal
service throughout this period. The annual cost of each dollar invested in
structures, then, is:
Similarly, equipment is assumed to provide service for 5 years, thus the
annual cost per dollar invested in equipment is:
One-Time Startup Costs —
One-time startup costs, like capital costs, are incurred only during
initial startup. The startup costs are recouped over the first 5 years of
the project. Thus, the annual cost of each collar of expenditures is the same
as that for capital equipment, —
Annual Operating and Administrative Costs —
These costs are already presented as annual amounts. These amounts must
be added to the annualized capital and startup costs, to arrive at the total
annual cost of the whole project.
Annualized costs for each of the four categories are shown in Tables 38
and 39 for the state-run and contractor-run programs, respectively.
Effects of Inflation—
In order to eventually derive an estimate of the actual fee, which will
be uniform in actual dollars over time, the effects of inflation must be
considered. In this connection, it is assumed that inflation is 7 percent
annually. The effect, then, is that the amortization factors used must reflect
the market rate of interest, which is equal to the real rate of return on ca-
pital, (defined previously as 6 percent), plus the rate of inflation. The
annualized costs, then, reflecting inflation can be computed. These are shown
in Tables 40 and 41 for the state-run and the contractor-run options,
respectively.
Fee Calculation
With the cost data developed above, two fees for both the state-run and
contractor-run programs can be computed. The first fee, fc, reflects the
annual costs in real 1978 dollars. The second fee, fa, in actual dollars,
reflects the impact of inflation. These fees are calculated simply as the
total annualized cost divided by the number of annual inspections (expected
to be 1.4 million per year as the average over 5 years). The fees for both
options are shown in Table 42.
119
-------
TABLE 38. ANNUALIZED COSTS FOR THE STATE-RUN OPTION IN CONSTANT DOLLARS
Cost category
Cost ($)
Amortization factor Annualized cost ($)
(i = 0.06) (column 2 x column 3)
I.
II.
III.
IV.
Capital costs
1 . Land
2. Buildings
3 . Equipment
Startup costs
Operating costs
Administrative
costs
Total
2,049,376
5,323,375
3,674,300
2,512,871
3,622,113
387,872
0.0600
0.0870
0.2374
0.2374
1.0
1.0
122,962
463,134
872,279
596,556
3,622,113
387,872
6,064,916
TABLE 39. ANNUALIZED COSTS FOR THE CONTRACTOR-RUN OPTION IN CONSTANT DOLLARS
Cost category
Cost ($)
Amortization factor Annualized cost ($)
(i = 0.06) (column 2 x column 3)
I.
II.
III.
IV.
Capital costs
1 . Land
2. Buildings
3. Equipment
Startup costs
Operating costs
Administrative
costs
Total
2,049,376
5,323,375
3,674,300
2,191,286
3,971,724
415,997
0.0600
0.0870
0.2374
0.2374
1.0
1.0
122,962
463,134
872,279
520,211
3,971,724
415,997
6,366,307
120
-------
TABLE 40. ANNUALIZED COSTS FOR THE STATE-RUN OPTION IN ACTUAL DOLLARS
I.
II.
III.
IV.
Cost category
Capital costs
1 . Land
2. Buildings
3 . Equipment
Startup costs
Operating costs
Administrat ive
costs
Total
Cost ($)
2,049,376
5,323,375
3,674,300
2,512,871
3,622,113
387,872
Amortization factor
(i = 0.06)
0.1300
0.1420
0.2840
0.2840
1.2100
1.2100
Annualized cost ($)
(column 2 x column 3)
266,419
755,919
1,043,501
713,655
4,382,757
469,325
7,631,576
TABLE 41. ANNUALIZED
COSTS FOR THE CONTRACTOR-RUN OPTION IN ACTUAL DOLLARS
I.
II.
III.
IV.
Cost category
Capital costs
1 . Land
2. Buildings
3 . Equipment
Startup costs
Operating costs
Administrative
costs
Total
Cost ($)
2,049,376
5,323,375
3,674,300
2,191,286
3,971,724
415,997
Amortization factor
(i = 0.06)
0.1300
0.1420
0.2840
0.2840
1.2100
1.2100
Annualized cost ($)
(column 2 x column 3)
266,419
755,919
1,043,501
622,325
4,805,786
503,356
7,997,306
121
-------
TABLE 42. BREAK-EVEN FEES, fc, IN REAL 1978 DOLLARS,
AND fa IN ACTUAL DOLLARS F
AND CONTRACTOR-RUN OPTIONS
AND fa IN ACTUAL DOLLARS FOR THE STATE-RUN
Option Fee in real dollars Fee in actual dollars
State-run
Con tract or -run
4.33
4.54
5.45
5.71
Cost Schedule
From the implementation schedule derived in Section 8, cost schedules
were defined for both the state-run and the contractor-^run options; these
schedules are provided in Tables 43 arid 44, respectively. Capital costs
for land, buildings and equipment expenditures are anticipated to occur during
1980, Startup costs are spread evenly over the startup period, 2 years for
the state-run option, 1 year for the contractor-«-run program. Annual operating
and administrative costs begin with the mandatory inspection phase during 1981,
as do revenues. For the contractor, costs begin to be incurred during January
1981, while for a state-run program, cost demand begins in mid-1981. For the
state approach then, only 6 months of annual operating and administrative costs
and revenues are assumed for 1981, Registration projections derived previously,
and a $5.00 fee were assumed in determining the annual revenues.
Accumulative costs were compared to accumulative revenues for the period
1979 to 1987. As can be seen from Tables 43 and 44, a significant deficit
occurs until 1986 in the state-run option and 1987 in the contractor
option. These summaries may be somewhat misleading, however. Although the
capital costs of buildings and land were considered as debits, it must be
assumed that both would maintain some residual value; that is, at any time,
the initial investment (presumably plus interest at least equal to the rate of
inflation) could be recouped through the sale of the facilities. Even with a
very conservative assumption that the facilities have a residual value equal
to 80 percent of the original cost after 5 years (in 1985), the break-even
point would be reached.
122
-------
TABLE 43. COST SCHEDULE FOR A STATE-RUN PROGRAM, 1979-1987
Year
1979
1980
1981
1982
1983
1984
1985
1986
1987
Total
Capital
($)
0
11,047,051
0
0
0
0
0
0
0
11,047,051
Cost
Startup
($)
628,218
1,256,435
628,281
0
0
0
0
0
0
2,512,871
category
Annual
operating
0
0
1,811,057
3,622,113
3,622,113
3,622,113
3,622,113
3,622,113
3,622,113
23,543,735
Administrative
0
0
193,936
387,872
387,872
387,872
387,872
387,872
387,872
2,521,168
Accumulative
total
costs ($)
628,218
12,931,704
15,564,915
19,574,900
23,584,885
27,594,870
31,604,855
35,614,840
39,624,825
39,624,825
Accumulative
total ^
revenue ($)
0
0
3,186,695
9,716,695
16,411,195
23,274,345
30,310,345
37,523,635
44,918,635
44,918,635
Surplus/deficit
-628,218
-12,931,704
-12,378,220
-9,858,205
-7,173,630
-4,320,525
-1,294,510
+1,908,795
+5,293,810
+5,293,810
Assumes $5.00 fee. All figures in constant 1978 dollars.
-------
TABLE 44. COST SCHEDULE FOR A CONTRACTOR-RUN PROGRAM, 1979-1987
S3
Year
1979
1980
1981
1982
1983
1984
1985
1986
1987
Total
Capital
($)
7,372,751
3,674,300
0
0
0
0
0
0
0
11,047,051
Cost
Startup
($)
0
2,191,286
0
0
0
0
0
0
0
2,191,286
category
Annual
operating
($)
0
0
3,971,724
3,971,724
3,971,724
3,971,724
3,971,724
3,971,724
3,971,724
27,802,068
Administrative
($)
0
0
415,997
415,997
415,997
415,997
415,997
415,997
415,997
2,911,979
• Accumulative
total
costs ($)
7,732,751
13,238,337
17,626,058
22,013,779
26,401,500
30,789,221
35,176,942
39,564,663
43,952,384
43,952,384
Accumulative
total
revenue ($)
0
0
6,373,390
12,903,390
19,597,890
26,461,040
33,497,040
40,710,330
48,105,330
48,105,330.
Surplus/deficit
-7,342,751
-13,238,337
-11,252,668
-9,110,389
-6,803,610
-4,328,181
-1,679,902
+1,145,667
+4,152,946
+4,152,946
-------
SECTION 8
IMPLEMENTATION PLANNING
INTRODUCTION
Owing to the nature of inspection and maintenance (I/M) programs, the im-
plementation planning phase is extremely crucial with regard to overall program
success. Implementation planning can be discussed in terms of coordinating
and scheduling various efforts and activities such as securing necessary legis-
lation and funds, selecting the particular operating mode (State-run or Contractor-
operated), arranging for the selection of a contractor(s) to run and/or design
the inspection facilities, etc., in other words, coordinating all efforts aimed
at getting the program from the conceptual stage to the operational phase. With
regard to program success, a distinction can be made between success in terms
of (1) accomplishing all those tasks that result in the program being operational
by a specified deadline and designed and constructed to operate efficiently,
etc.; and (2) the public's acceptance and recognition of the program as an im-
portant mechanism for achieving a cleaner environment. The types of planning
that will enhance the success of the program in terms of the first definition
concern physical planning (e.g., construction planning) while in terms of suc-
cess from the viewpoint of public acceptance, the critical planning areas con-
sider policy planning (e.g., gradual implementation, gradually increasing strin-
gency factors, planning public information programs; in other words, planning
activity that focuses on "selling" the program to the public). Both types of
planning are considered in the following paragraphs.
In view of the relative importance of issues concerning scheduling and
phase-in, it is appropriate to provide a discussion of these issues; it is not
with the intention of deriving a detailed schedule for the implementation of
the program, rather the purpose here is to provide an indication of some of the
most critical factors in the scheduling and phase-in processes.
In this connection, three general types of issues can be considered.
First, the U.S. Environmental Protection Agency has set policy guidelines that
directly affect the schedule and phase-in requirements of the program. These
concern primarily the dates when the program has to be implemented and operating
fully. Second, there exists a general sequence to the efforts that will be
undertaken in connection with implementing the program that, even though quite
logical and perhaps very obvious, will be mentioned here for completeness.
Third, there are several issues relating to either scheduling or phase-in that
are quite subtle and have a potential impact on the program. These types of
issues have been identified through discussions with individuals who have been
involved in the implementation and/or operation of I/M programs and have the
insights that are obviously gained through such experience.
125
-------
IMMEDIATE ISSUES
The most immediate issues are those that require action of some sort by
EPA, either in connection with the revised State Implementation Plan (SIP) or
as a matter concerning the I/M program specifically. In that the I/M program
is an element in the SIP, there is obviously a strong connection between SIP
requirements and the tasks that must be accomplished immediately.as part of the
I/M effort. With regard to scheduling, EPA guidance defines several require-
ments concerning I/M that must be fulfilled prior to submitting the revised
SIP; these can be seen in the following excerpt from an EPA policy memorandum
dated 17 July 1978:
"The I/M Implementation Schedule
The specific items listed below must be included as a part of
the States' I/M implementation schedules with specified dates for
implementation of each item. The stringency planned for the program
and other factors affecting the potential for emission reductions
should also be indicated. Additional items if necessary because of
local factors may be required by U.S. EPA Regional Offices.
1. Initiation (or continuation) of public information
program including publicizing the I/M program in the
media, meeting and speaking with affected interest
groups, etc.
2. Preparation of a draft legislative package and sub-
mittal of legislation package to legislature if
additional legislative authority is needed.
3. Certification of adequate legal authority by
appropriate state official.
4. Initial notification of garages explaining program
and schedule of implementation.
it
5. Development and issuance of RFPs.
6. Award to contractor(s).
*
7. Initiation of construction of facilities.
*
8. Completion of construction of facilities.
9. Adoption of procedures and guidelines for testing
and quality control including emission analyzer
requirements (and licensing requirements for private
garages, if applicable).
Indicates that items may apply to some I/M programs and not to others.
126
-------
10. Notification of and explanation to garages of actions
in Step 9.*
11. Completion of equipment specification, and purchase and
delivery of equipment.
12. Development and adoption of cutpoints.
13. Initiation of hiring and training of inspectors or
licensing of garages.
14. Initiation of introductory program (voluntary main-
tenance with either voluntary or mandatory inspection)
if not previously initiated.
15. Initiation of mechanics training and/or information
program.
16. Initiation of mandatory inspection.
17. Initiation of mandatory repair for failed vehicles.
If certification of adequate legal authority occurs after
January 1979, the States may modify previous commitments to imple-
ment and enforce the elements of the schedule to conform to the
legal authority.* These modifications will be approved by the EPA
Regional Offices and must be consistent with the Administrator's
February 24, 1978, policy memorandum. The documents should be sub-
mitted by January 1, 1979. Any necessary adjustments to the schedule
may be made at this time but must be approved by the EPA Regional
Offices."
The requirement is that an I/M implementation schedule be prepared as part
of the SIP revision, and that the schedule consider the items listed above (if
applicable). The development of this section considers the above list of
schedule elements as well as several additional elements, and these are dis-
cussed below. The discussion of each element should provide some insight as
to how the I/M schedule requirement (defined above) should be addressed. How-
ever, the basic task is:
• formulate tentative plans for the format, scope, design
operation and implementation of the items listed in the
I/M Schedule requirements; this has to be accomplished
by 30 November 1978.
Indicates that items may apply to some I/M programs and not to others.
127
-------
which is followed by a second task involving:
• develop an I/M implementation schedule that will address
(at least) the relevant issues defined above for sub-
mittal as part of the revised SIP; this has to be com-
pleted prior to 31 December 1978.
A good starting point in this discussion concerns the legislative require-
ments indicated by Items 2 and 3 in the Implementation Scheduling requirements.
At this point, the specific I/M program scenario that will be implemented
in Wisconsin has been defined except for the operating agency whether it will
be a State-run program or contractor-run. Some differences exist in the issues
relating to scheduling depending on the operating mode selected, therefore
issues discussed here will include those that are common to both operating
modes as well as those peculiar to one or the other.
As a general comment, the implementation requirements are such that a
cogent planning effort should be underway even at this point in time to ensure
that the schedule requirements (discussed later) can be met. That the State
recognizes this requirement is obvious in that an I/M Interagency Task Force
has been established and is actively dealing with the matter of I/M in Wiscon-
sin. Several, rather crucial decisions must be made by the Task Force (or,
by those State officials represented directly by the Task Force) that will
directly affect the direction that the program effort will take. These deci-
sions concern issues such as whether the inspection facilities will be State
or contractor run, who will be responsible for the design and implementation
of various supporting programs (e.g., public information, mechanic's training,
etc.), and others. Perhaps the most crucial decisions are those that are yet
to be made concerning various technical and administrative issues, particularly
those that have to be included in the enabling legislation (see Section 6).
These are of fundamental concern because the enabling legislation must be
drafted fairly soon since the State Legislature convenes next in January 1979
for a 2-month session and, in order to meet the EPA deadline of 31 June 1979
for securing the legal authority to implement and enforce the program, must
be ratified during this session. The basic tasks indicated and the time frame
for their completion, then, are:
• define remaining technical and administrative aspects of
the program that are necessary to be included in the
enabling legislation; this should be accomplished by
30 November 1978.
• prepare enabling legislation; this should be completed
during December 1978.
*
To eliminate confusion, it should be stated at the outset that Items 4
and 10 in the Implementation Schedule elements are not required for the option
selected by the States and, therefore, will not be discussed here.
128
-------
In a very similar connection, a program budget must be derived in order to
secure the funds necessary to implement and operate the program. This establish-
ment of the required funds is also a legislative process and, therefore, must
also occur during the early 1979 State Legislative Session. This obviously
requires the preparation of a budget estimate and substantiating documentation,
probably by the I/M Task Force. The specific task, then is:
• prepare program budget request including actual estimates
and substantiating data; this should be accomplished prior
to 1 January 1979.
To carry this discussion a step further, the legislation and budget must be
approved by the State Legislature as a prerequisite for the advancement of the
program beyond the conceptual stage. It is unfortunate that there are no
checklists that can be followed or procedures that can be recommended to gua-
rantee rapid approval of the proposed legislation and budget by the State
Legislature. EPA guidance, however, is rather specific with regard to the
scheduling requirements for securing the proper authority to implement I/M,
as can be seen in the following excerpt from an EPA policy memorandum dated
17 July 1978:
"Authority to Implement I/M
Normally, adequate legal authority to implement a SIP revision
must exist for a revision to be approved. Where a legislature has
had adequate opportunity to adopt enabling legislation before
January 1, 1979, the Regional Administrator should require certifica-
tion that adequate legal authority exists for I/M implementation by
January 1, 1979. However, for many states there will be insufficient
opportunity to obtain adequate legal authority before their legisla-
tures meet in early 1979. Therefore, a certification of legal author-
ity for the implementation of I/M in these states must be made no
later than June 30, 1979. An extension to July 1, 1980, is possible,
but only when the state can demonstrate that (a) there was insuffi-
cient opportunity to conduct necessary technical analyses and/or (b)
the legislature has had no opportunity to consider any necessary
enabling legislation for inspection/maintenance between enactment of
the 1977 Amendments to the Act and June 30, 1979. Certification of
adequate legal authority, or other evidence that legal authority
has been adopted, must be submitted to the EPA Regional Offices to be
included in the SIP revision already submitted. Failure to submit
evidence of legal authority by the appropriate deadline will consti-
tute a failure to submit an essential element of the SIP, under
Sections 110(a)(2)(I) and 176(a) of the Act."
It is entirely likely (and logical) that during discussion regarding
the ]/M legislation the question will arise as to: what will happen if
we do not approve I/M legislation by the 31 June 1979 deadline? The answer
to this is that the State would not be able to submit an essential element of
the SIP, and that Sections 110(a)(2)(I) and 176(a) of the Act would apply.
Of particular interest are the provisions of Section 176(a), which deal with
sanctions that may be placed against states for noncompliance; this Section is
excerpted below:
129
-------
LIMITATIONS ON CERTAIN FEDERAL ASSISTANCE
SEC. 176. (a) The Administrator shall not approve
any projects or award any grants authorized by this Act
and the Secretary of Transportation shall not approve
any projects or award any grants under title 23, United
States Code, other than for safety, mass transit, or trans-
portation improvement projects related to air quality
improvement or maintenance, in any air quality control
region—
(1) in which any national primary ambient air
quality standard has not been attained.
(2) where transportation control measures are nec-
essary for the attainment of such standard, and
(3) where the Administrator finds after July 1.
1979, that the Governor has not submitted an im-
plementation plan which considers each of the ele-
ments required by section 172 or that reasonable
efforts toward submitting such an implementation
plan are not being made (or, after July 1, 1982, in
the case of an implementation plan revision required
under section 172 to be submitted before Julv 1,
1982).
(b) In any area in which the State or, as the case may
be, the general purpose local government or govern-
ments or any regional agency designated by such general
purpose local governments for such purpose, is not im-
plementing any requirement of an approved or promul-
gated plan under section 110, including any requirement
for a revised implementation plan under this part, the
Administrator shall not make any grants under this Act.
(c) No department, agency, or instrumentality of the
Federal Government shall (1) engage in, (2) support in
any way or provide financial assistance for, (3) license or
permit, or (4) approve, any activity which does not con-
form to a plan after it has been approved or promulgated
under section 110. No metropolitan planning organiza-
tion designated under section 134 of title 23, United
States Code, shall give its approval to any project, pro-
gram, or plan which does not conform to a plan approved
or promulgated under section 110. The assurance of con-
formity to such a plan shall be an affirmative responsi-
bility of the head of such department, agency, or instru-
mentality.
(d) Each department, agency, or instrumentality of
the Federal Government having authority to conduct or
support any program with air-quality related transpor-
tation consequences shall give priority in the exercise of
such authority, consistent with statutory requirements
for allocation among States or other jurisdictions, to the
implementation of those portions of plans prepared un-
der this section to achieve and maintain the national pri-
mary ambient air quality standard. This paragraph ex-
tends to, but is not limited to, authority exercised under
the Urban Mass Transportation Act, title 23 of the
United States Code, and the Housing and Urban De-
velopment Act.
130
-------
The implications of not approving I/M legislation are quite severe, as can
be seen from Section 176(a), and therefore should be considered in legislative
discussions on the proposed legislation.
The basic task, then, is:
• approve I/M legislation and corresponding funding; this in
general should be accomplished prior to 31 June 1979, but
considering the dates that the Legislature is in session,
approval should occur during January or February 1979.
The second element to be discussed concerns the initiation of a public
information program regarding I/M. In deciding on the particular program
details, several points should be considered. First, there are three basic
stages in the public information effort and the activity and timing of each
should be treated carefully. The first stage occurs during the period prior
to introducing the legislation to the Legislature, and extends through the
time that the legislation is approved. The intent is to inform the public
about the basic concepts of the program primarily to develop support from
those individuals whose representatives will be acting on the legislation in
the State Legislature. The effort may be directed more toward organized groups
who have both a recognized lobbying power and an inherent interest in promoting
air pollution reduction. The second phase occurs approximately 6 months to
a year prior to the start-up of the program and extends through the first year
of operation. This entails a very strong, visible effort to inform the public
about the details of the I/M program, particularly concerning the benefits
that the individual motorist is likely to derive from the program. Also, the
intent should be to ensure that the requirements for each motorist to obtain
an inspection are defined in detail so that essentially everyone knows what
to expect with regard to how he is notified as to when and where he will be
inspected, eliminate uncertainty regarding repair liability (repair cost
ceiling), where he can take his vehicle for repairs if required, etc. The
final phase is a continued effort after the I/M program is operating smoothly.
The intent would be to inform the public of the program's effectiveness in
reducing pollution. This would require a somewhat lower level of effort than
would the second stage.
The tasks associated with public information programs, then, can be
described as follows:
• develop program strategy including who will operate the pro-
gram (State franchise or private firm), level of activity
associated with each phase, implementation dates (approximate)
of each phase, etc.; this planning effort should be completed
prior to 31 November 1978.
• define details of the first phase of the public information
program and implement and conduct same; this should occur
during the period from approximately 1 November 1978 to
1 March 1979 (or until legislation is adopted.
131
-------
• define details of the second phase of the public information
program and implement and conduct same; this should begin
6 to 12 months prior to program start-up and extend through
the first year of full operation.
• define details of the third phase of the public information
program and implement and conduct same; this should follow
the completion of the second phase and continue as required.
The public information programs and schedules described above are the same
for both State-run and contractor-run options.
The next items from the list of I/M Implementation Schedule elements that
will be discussed are items 5, 6, 7, and 8; items 5 and 6 deal specifically
with the contractor option while 7 and 8 deal with either State-run or
contractor-run programs. Specifically, items 5 and 6 concern developing and
issuing requests for proposals (RFP's), and subsequent award of a contract(s)
to a private firm, while items 7 and 8 concern the construction of facilities,
which is a required step regardless of who operates the program. The basic
condition of who is to operate the program must be defined at the outset.
This obviously has to be completed during the initial program planning prior
to 30 November 1978.
Assuming first that contractor-operated inspection facilities are selected,
the first task would be to develop a detailed plan of what the program is to
include, and specifically, what the requirements for and responsibilities of
the contractor would be. These would be published as an RFP and distributed
to interested contractors, who would respond with proposal to establish and
operate the inspection facilities. The State would review and evaluate the
proposals and select a particular contractor from those submitting proposals.
The next items deal with the initiation and completion of facilities con-
struction. If the State-run option is selected, an additional task can be
identified and that concerns developing building designs, soliciting bids from
a (construction) contractor, and finally selecting a construction contractor.
Also, certain other steps are also as critical as construction start and com-
pletion dates, such as site selection and land purchases, etc.
The individual tasks associated with these items can be defined as follows:
• select operating agency in terms of State-run or contractor-
run; this has to be done prior to 30 November 1978.
Con tra c tor-run:
• prepare request for proposal; this would likely take 2 months
to prepare and would not be started until after the legisla-
ture and budget were approved; this task would occur, then
say during April and May 1979; this task would be accomplished
only for a contractor-run option.
132
-------
• assuming that the KFP's were issued during June 1979 and pro-
posals due in early July 1979, the proposals could be eval-
uated and a contractor selected by September 1979.
• contractor begins site search and purchases required land;
occurs during the period October 1979 through March 1980.
• contractor begins construction of facilities; construction
period May 1980 through December 1980.
State-run;
• if the State-run option is selected, a design/construction
contractor is required; preparation of invitation to bid is
required; this would occur after legislation and budget were
approved, say during April 1979.
• again, for State-run option, the bids for design/construction
would be evaluated and a contractor selected; this would
occur during June and July 1979.
• for State-run option, land investigation would precede
site selection; negotiation and purchase would occur
during period from July 1979 through March 1980.
• design plans would be developed for State-run option;
this would occur during the period August 1979 to August 1980.
• construction on State-run facilities begins; construction
period August 1980 to May 1981.
Selection, purchase, and delivery of equipment is listed next in the I/M
Implementation Schedule. It could be expected that a fairly substantial lead
time would be required between ordering and delivery of certain equipment
items. The intent, however, would be to stage equipment delivery over the
latter portion of the facilities construction period, so that equipment could
be installed as it arrives. This is the usual procedure used in construction
practice and should not be of extraordinary concern. Some time savings in
equipment purchase may be possible with the contractor option source competi-
tive bidding would not be required. The tasks involved here are as follows:
• Contractor Option;
Select equipment in accordance with State specifications,
purchase same; this would be done, say, during the period
May through December 1980.
Equipment delivery; occurs as required May through
December 1980.
133
-------
• State-Run Option;
Advertise for bids; occurs during period August 1980.
Select equipment suppliers, schedule deliveries; occurs
during the period September 1980 to August 1981.
Item 12 in the Implementation Schedule concerns the development and adoption
of cutpoints. Initial cutpoints can be selected based on vehicle emissions
data compiled by other states, and these can be refined during the early
stages of inspection once a sufficient cross-section of the vehicle population
has been tested. The initial cutpoints should be defined after some initial
study of existing data. Specific tasks include:
• review data from other programs, define initial cutpoints; this
can take place during the period 6 to 9 months prior to
startup;
• refine cutpoints to account for Wisconsin-specific data and
changing vehicle emissions characteristics; this occurs approx-
imately 6 months after initiation of testing and continues
throughout program.
Items 13 and 15 on the Implementation Schedule deal with hiring and train-
ing impactors and other personnel, and initiation of training programs for both
inspection personnel and the auto, repair industry. A distinction can be made
with regard to operating personnel and administrative personnel phase in.
Administrative personnel would be phased into the program 24 months prior to
beginning the testing while operating personnel, managers and inspectors,
would be phased in 6 months and 1 month prior to startup, respectively. No
differences in operating personnel phase-in occurs between the state- and
contractor-run options. Training courses for inspection personnel would begin
approximately 6 months prior to startup to train all new personnel, and the
training would continue throughout the program to train additional personnel
being brought into the system. The mechanics training program would begin
approximately 6 months prior to mandatory maintenance. A task that must be
carried out prior to implementing mechanic training is to define the nature of
the training program in terms of who will do the testing, what will be taught,
etc. The specific tasks involved include:
• hire administrative personnel; this would be accomplished
24 months prior to program start-up. (For state-run op-
tion; 12 months for contractor-run option.)
• hire inspection facility managers and assistant managers;
this would be accomplished 6 months prior to start;
• determine training program details including scope, who
will conduct training, where training is to be held, etc.,
this would be accomplished 1 year prior to start-up.
• begin mechanics/inspector training program; this would begin
6 months prior to beginning any testing (inspector training
phase would begin 1 month prior to start-up).
134
-------
The last items on the Implementation Schedule concern phasing in mandatory
inspections and mandatory maintenance. Although the Task Force has indicated
that the general procedure would be to have voluntary maintenance but mandatory
inspections during the first full year of operation, this proposal should be
reconsidered in view of the requirements for implementing mandatory I/M set
forth in the EPA guidance. The specific guidance on deadlines is provided
below:
D. "I/M Implementation Deadlines
Implementation of I/M "as expeditiously as practicable" shall be
defined as implementation of mandatory repair for failed vehicles no
later than two and a half years after passage of needed legislation or
certification of adequate legal authority for new centralized systems
and one and a half years after legislation or certification for decen-
tralized systems or for centralized systems which are adding emission
inspections to safety inspections. For the normal legislation deadline
of June 30, 1979, new centralized programs must start by December 31,
1981, and all others must start by December 31, 1980. For the case of
the latest possible legislation date, July 1, 1980, this means that a
new centralized program must start by December 31, 1982, while all
other programs must start by December 31, 1981. Where I/M can be
implemented more expeditiously, it must be. Each state implementation
schedule must be looked at individually to determine if it is as
expeditious as practicable. Implementation dates ordered by courts,
if earlier than these dates, take precedence."
It appears that there would be a chance for a full year of mandatory in-
spection, voluntary maintenance if the contractor option is selected and im-
plementation procedures generally along the schedule indicated up to this
points, which calls for start-up to begin in January 1981. Since the State-run
option would require approximately 6 additional months bringing start-up to
July 1981.
The tasks that can be identified here regarding phase-in are:
• For State-Run Option;
implement mandatory inspection, voluntary maintenance;
this would occur approximately July 1981 and run through
31 December 1981.
implement mandatory inspection, mandatory maintenance;
this would begin 31 December and continue throughout
the program.
135
-------
• For Contractor-Run Option;
implement mandatory inspection, voluntary maintenance;
this will occur approximately 1 January 1981 and run
through 31 December 1981.
implement mandatory inspection, mandatory maintenance;
this would begin 1 January 1982 and extend throughout
the program.*
The issues discussed above, again, must be defined in terms of the
schedule for implementation in the revised SIP. As a summary of the above
discussion, Table 45 is presented showing each task identified above and its
approximate implementation date.
*
The actual duration of the program beyond 1987 is open to speculation at this
time. Should the program not be needed as an air quality improvement measure
beyond 1987, the state would have the option of continuing, modifying, or
terminating it
136
-------
TABLE 45. IMPLEMENTATION SCHEDULE - SUMMARY
MSI iXD ITEM DESCRIPTION
I. PRELIMINARY PLANNING
A FORMULATE TENTATIVE PLANS FOR THE FORMAT, SCOPE, DESIGN, OPERATION, AND IMPLEMENTATION
OF BASIC I/M PROGRAM ELEMENTS
IN TBE TEXT)
II. ENABLING LEGISLATION, DRAFT BUDGET
A DEFINE TECHNICAL AND ADMINISTRATIVE ASPECTS OF THE PROGRAM THAT ARE NECESSARY TO IN-
CLUDE IS LEGISLATION
B. PREPARE ENABLING LEGISLATION
C. PREPARE PROGRAM BUDGET REQUEST
D. APPROVE I/M LEGISLATION AND FUNDING
III. PUBLIC INFORMATICS PROGRAM
A. DEVELOP PROGRAM STRATEGY
C. DEFINE DETAILS OF SECOND PHASE OF THE PUBLIC INFORMATION PROGRAM, IMPLEMENT PROGRAM
D. DEFINE DETAILS OF TBIRD PHASE OF THE PUBLIC INFORMATION PROGRAM, IMPLEMENT PROGRAM
IV. INSPECTION FACILITIES DEVELOPMENT
A. SELECT OPERATING AGENCY
1. IF CONTRACTOR-OPTION:
a. PREPARE RFP
b. CONTRACTORS RESPOND TO RFP, PROPOSALS REVIEWED, CONTRACTOR SELECTED
c. CONTRACTOR BEGINS SITE SEARCH AND PURCHASES REQUIRED LAND
d. CONTRACTOR CONSTRUCTS FACILITIES
2. IF STATE-RUN OPTION:
a. PREPARE INVITATION TO BID FOR FACILITY DESIGN AND CONSTRUCTION
b. EVALUATE BIDS, SELECT CONTRACTOR
c. LAND INVESTIGATION, SITE SELECTION, NEGOTIATION, AND PURCHASE
d. DEVELOP DESIGN PLANS
e. CONSTRUCT FACILITIES
1978
0 M
—
—
b 1 1
1»79
1 1 1 1 1 I 1 1 1 1 1
-t— 1
1 1 1
HM-
t-i
>-M
1980
1 \ I I I i I 1 I I 1
« 1 1
1981 1
1 1 I I I i 1 1 I | 1
A,
-------
TABLE 45 (continued)
u>
00
TASK AXD ITEM DESCUFriO»
EQUIPMENT PURCHASE
A. CONTRACTOR-RUN OPTION:
1. SELECT AND PURCHASE EQUIPMENT
2. TAKE DELIVERY OF EQUIPMENT AS APPROPRIATE
B. STATE-RU5 OPTION
1. ADVERTISE FOR BIDS
2. SELECT EQUIPMENT SUPPLIERS, PURCHASE EQUIPMENT, TAKE DELIVERY AS APPROPRIATE
DEVELOPMENT OF CUTPOINTS:
A. REVIEW DATA FROM EXISTING PROGRAMS, DEFINE INITIAL CUTPOMTS
B. REFINE OUTPOINTS BASED ON DATA COMPILED BT PtOQUM
PERSONNEL HIRIHG, TRAINIHG
A. ADMINISTRATIVE PERSONNEL HIRED AND BEGIN W**.
1. STATE-BBS OPTION
2. CONTRACTOR-RUN OPTION
B. INSPECTION FACILITY MANAGERS AND ASSISTANT MANAGERS HIKED/THAUIED
1. STATE-RON OPTION
2. CONTRACTOR-RUN OPTION
C. DETERMISZ TRAINING PROGRAM DETAILS INCLUDING SCOPE, ETC.
1. STATE-RLN OPTION
2. COHTRACTOR-RUN OPTION
D. INSPECTORS HIRED, BEGIN INSPECTOR AND MECHANIC TRAINING
1. INSPECTORS HIRED AND TRAINED
a. STATE-RUN OPTION
b. CONTRACTOR-RUN OPTION
2. MECHANIC TRAINING
a. STATE-RUN OPTION
b. CONTRACTOR-RUN OPTION
. PROGRAM PHASE-IS
A. STATE-RCS OPTION
1. IMPLEMENT MANDATORY INSPECTION VOLUNTARY MAINTENANCE
2. IHPLEMENT MANOATORY INSPECTION MANDATORY !1AINTENA»CF
B. CONTRACTOR-RL^ OPTION-
1. IXPLEKOI MANDATORY INSPECTION VOLUNTARY MAIKTESAHCE
2. IMPLEMENT MANDATORY INSPECTION, MANDATORY MAINTENAHCE
-------
SECTION 9
SUMMARY AND CONCLUSIONS
INTRODUCTION
Need for Inspection and Maintenance Program
Amendments to the Clean Air Act that were adopted during 1977 have
established that the National Ambient Air Quality Standards (NAAQS) for
pollutants such as carbon monoxide (CO) and photochemical oxidants (Ox) must
be attained in all areas of the U.S. no later than 31 December 1982. The
U.S. Environmental Protection Agency, the federal agency charged with the
responsibility of administering and enforcing the Clean Air Act and amendments
thereto, has set the requirement that each state containing an area (or areas)
currently in violation of the NAAQS must submit a revision to its State Imple-
mentation Plan (SIP) during January 1979 demonstrating compliance in all areas
by 31 December 1982. That all states will not be able to demonstrate total
compliance by the end of 1982 is recognized in the Amendments and provisions
are made for extending the compliance date to 31 December 1987. In order to
obtain the extension, however, the revised SIP to be submitted in January 1979
must include (among other things) a specific schedule for the implementation
of a motor vehicle emissions inspection and maintenance (l/M) program in those
nonattainment areas that have an urbanized population greater than 200,000.
Failure to submit an acceptable I/M schedule (or if a reasonable effort toward
submitting an acceptable schedule is not being made) will result in rather
severe sanctions being imposed on the state.
Preliminary reviews of the status of air quality control regions in the
State of Wisconsin have indicated that the NAAQS for Ox and/or CO will likely
not be achieved by 31 December 1982 in all instances. Given the requirements
of the Clean Air Act Amendments mentioned above, a decision was made to
initiate action that would serve to identify the overall requirements for I/M
in the State.
What Are Inspection and Maintenance Programs?
Beginning with 1968 model-year vehicles, automobiles manufactured in or
imported into the U.S. have had to comply with emission standards specified in
the Federal Motor Vehicle Emission Control Program (FMVECP). Under this pro-
gram, maximum emission rates are established for new vehicles, and manufacturers
must demonstrate through an auditing program that their vehicles are in compli-
ance with these emission limits. The emission standards specified by the
FMVECP require progressively more stringent control of emissions with each
subsequent model year.
139
-------
To comply with the emission standards, manufacturers have retained their
existing engine design concepts, but developed emission control devices (crank-
case ventilation control, catalytic converters, etc.) and revised certain sys-
tem parameter specifications (air-to-fuel ratio, ignition timing, etc.). This
approach to emission control ostensibly satisfied the requirements of the
FMVECP for new vehicles. However, surevillance studies conducted by EPA dis-
closed that the emission rate for these "controlled" vehicles generally in-
creased with time at a much greater rate than was expected, therefore reducing
greatly the overall effectiveness of the FMVECP. Further analyses determined
that the root causes of the rapid deterioration of these emission control sys-
tems could be traced to either improper or inadequate maintenance, or tampering
with the devices or system settings.
In light of these findings, effort has been expended on developing tech-
niques for reducing the air quality impact of poor maintenance practices and
tampering. One result of this effort is the evolution of the inspection and
maintenance concept.
In its most basic sense, inspection and maintenance refers to a program
where vehicle exhaust emission levels are measured during specified operating
conditions and compared with a specified standard for that particular vehicle
configuration. If the measured rate exceeds the standard, the need for some
form of maintenance, ajustment or repair is indicated. This is a very sim-
plistic explanation of I/M, but it does serve to define the basic concept in-
volved. A more precise discussion of various technical aspects of I/M may be
found in the EPA report, entitled, "Summary Report on Vehicle Emissions Inspec-
tion and Maintenance Programs."
A variety of approaches have been used to run I/M programs, but the major
types are generally in three organizational categories, as follows:
1. Government - Centralized test facilities operated by state,
city, or local government (as in New Jersey; Cincinnati, Ohio;
Portland, Oregon; and Chicago, Illinois).
2. Contractor - Centralized facilities operated by a private
corporation under contract to a government (as in Maricopa
and Pima Counties, Arizona).
3. Private Garage - Decentralized facilities operated by private
automobile service garages, certified or licensed by govern-
ment (as in Rhode Island and Nevada).
The major technical issues that need to be addressed in setting up an
I/M program include:
1. Type of Emissions Test - Idle or Loaded
2. Geographical Coverage
3. Organizational Approach
140
-------
4. Frequency of Inspection
5. Enforcement Procedure
6. Vehicles To Be Tested
7. Vehicles To Be Exempted
8. Data Handling Procedures
9. Adjunctive Programs (e.g., Public Information, Consumer Protection-
Mechanic Training, etc.)
BACKGROUND OF THIS STUDY
Given the likelihood of I/M being required in the State of Wisconsin, a
decision was made to establish an interagency technical committee comprised
of staff members from the Departments of Natural Resources and Transportation,
whose responsibility would be to develop the initial program framework and
provide technical support for state policy makers.
The initial effort by the committee was to review the most current litera-
ture relevant to I/M, and investigate a number of specific technical issues
that would eventually have to be addressed in the development of the I/M pro-
gram. From this literature review, a total of 55 possible program scenarios
were defined and evaluated. As a result, a final list of six specific program
options, which appeared to be the options that were best suited for the State,
was defined. The basic elements included in each of these options are delineated
in Table 46. Upon reviewing Table 46, it is quite apparent that there are many
similarities among the options. The primary differences relate to test type
(idle or loaded mode), operation (contractor-run centralized facilities, state-
operated centralized facilities, or private garage operation), and whether or
not additional types of inspections (i.e., safety and noise) are integrated
into the program.
A decision was made to limit the coverage of the I/M program to the nine
counties listed below:
Brown County Racine County
Dane County Walworth County
Kenosha County Washington County
Milwaukee. County Waukesha County
Ozaukee County
These counties represent the most highly urbanized areas within the state, and
are, therefore, the most appropriate for implementing I/M. Owing to the rural
nature of the remaining counties, there would likely not be a significant ad-
vantage to extending the program to statewide coverage at the present time.
A detailed, comparative analysis of the six options was performed that
considered costs, benefits, and resource requirements.1 With regard to costs,
the analysis considered several categories including (1) capital costs,
141
-------
TABLE 46. I/M OPTIONS ANALYZED
Option Geographic
no. coverage
Test mode
Operation and
operating agency
Vehicles to be inspected
Remarks
1 Nine counties Loaded Centralized facilities;
contractor operated
All passenger cars and light 30 percent stringency factor;
trucks with GW less than
8,500 pounds except those
less than 1 or more than
12 years old
Nine counties Loaded Centralized facilities; Same as Option 1
contractor operated
annual inspections; mechanic
training to be performed; safety
and noise inspections to be per-
formed , also"
30 percent stringency factor;
annual inspections; mechanic
training to be performed
3
4
5
6
Nine counties Idle Centralized facilities;
contractor operated
*
Nine counties Loaded Centralized facilities;
state operated
*
Nine counties Idle Centralized facilities;
state operated
Nine counties Idle Inspections performed
in private service
stations and garages
Same as Option 1
Same as Option 1
Same as Option 1
Same as Option 1
Same as Option 2
Same as Option 1 ( includes
and noise inspections)1"
Same as Option 2
Same as Option 2
safety
Includes Brown, Dane, Kenosha, Milwaukee, Ozaukee, Racine, Walworth, Washington, and Waukesha Counties
Safety and noise inspections would be statewide
-------
initial start-up costs, (3) annual operating costs, and (4) annual administra-
tive costs. These categories served as the basis for calculating the total
annual cost of each option; this total annual cost was translated to an inspec-
tion fee that would be charged for each inspection by dividing it by the expected
average annual number of paid inspections over the first several years of opera-
tion. The fees calculated for each are shown in Table 47 below.
TABLE 47. BREAKEVEN FEES IN CONSTANT 1978 DOLLARS FOR OPTIONS 1 THROUGH 6
Option
Key elements
Fee estimate
1 Centralized, contractor-run, loaded-mode $7.24
test, with safety and noise inspections
2 Centralized, contractor-run, loaded-mode 3.40
test
3 Centralized, contractor-run, idle-mode 3.15
test
4 Centralized, state-run, loaded-mode test, 6.87
with safety and noise inspections
5 Centralized, state-run, idle-mode test 3.13
6 Private garages and service stations 3.00 - 6.00
performing idle-mode tests
t
Constant 1978 dollars, paid retest.
Private garage fee is a function of the participation rate (i.e., the
number of garages participating); the range shown in the table reflects
a participation rate of about 35 to 75 percent.
Table 47 indicates that, in general, there will not be substantial differences in
the costs of similar options (e.g., Options 1 and 4, 2 and 3, or 3 and 5).
For example, a centralized network of idle-mode emission inspection stations
would require a fee of $3.13 if the State assumes operational responsibility,
while the fee would be $3.15 if a private contractor operates the network. A
fairly substantial fee differential is indicated in comparing inspection options
that include safety, noise, and emissions inspections, with options calling
only for emissions inspections. This differential can be seen in comparing
Options 1 and 2, where fees of $7.24 and $3.40 are indicated for centralized,
contractor-run, loaded-mode emissions testing, with or without safety and
noise inspections, respectively. Option 6 is somewhat different from the
first five in that private garages or service stations will conduct emissions
inspections. The estimated cost for an inspection under Option 6 is dependent
on the number of garages that participate in the program. As the participation
rate increases, each station's share of the inspections is reduced, thereby
requiring a higher fee for each inspection in order to break even. As is
indicated by Table 47, the range in the estimated fee is similar to the range
in fee estimates for Options 1 through 5.
143
-------
Benefits associated with each option were analyzed in detail. Two primary
categories of benefits are identified with I/M programs, including (1) reductions
in carbon monoxide and hydrocarbon emissions, and (2) improved fuel economy for
those vehicles undergoing maintenance because of the program. With regard to
quantifying these benefits, available data indicates that there are no differ-
ences in the level of emissions reduction or improvement in fuel economy
achievable across the six options, assuming, of course, that the quality of
both inspections and maintenance performed do not very from option to option.
Using EPA's Mobile 1 computer routine, average daily carbon monoxide and reac-
tive hydrocarbon emissions were computed for both 1977 and 1987.w Comparing
the estimated 1987 emissions with a I/M program, to the 1987 emissions without
an I/M program shows a decrease in total carbon monoxide emissions of approxi-
mately 29 percent, and a decrease in total reactive hydrocarbon emissions of
24 percent.
An estimate of the effect of an I/M program on fuel economy was also
derived for the nine counties. Under the assumption used in each scenario
(primarily with regard to the failure rate) it is estimated that by 1987,
an annual fuel (gasoline) savings of 8.64 million gallons could be realized
with an I/M program.
Other issues were raised, however, that indicated potential indirect
benefits from the centralized lane approach as opposed to the decentralized
garage options. Having a licensed private garage conduct both inspections
and the necessary repairs for failed vehicles, raises potentially serious
conflict of interest questions. Given the adverse publicity concerning
alleged unethical repair practives in the repair industry, and given the
technical difficulties in maintaning quality control on the several thousand
emission analyzers across the state, this option was considered to have
significant disadvantages in comparison to state or contractor centralized
lanes. Quality control and supervision would be much better and uniformity
of inspection results would consequently be far greater with centralized lanes.
Another issue that separates the options concerns the commitment of large
numbers of state employees. In the state-run approach there would be a far
greater number of new state employees, namely, the actual emissions inspectors.
This employment issue was seen as potentially significant in view of the
desirability of keeping the commitment of state manpower to a minimum. More-
over, the contractor approach allows for the option of state cancellation
either during or at the end of the 5-year initial period, if the state wanted
to take over the program itself.
Based in part on the information provided in the analysis of the six
options, the Interagency Task Force selected one specific option that appears
to best suit the needs of the State. This option is discussed in detail in the
report and is highlighted here in the following pages. Discussed are costs,
benefits, resource requirements, etc., associated with the program.
Vc
Two estimates for 1987 were developed; one with an I/M program in place and
the other without any I/M.
144
-------
OPTION DEFINITION
Essentially, the program selected involves establishing a network of
centralized emissions inspection stations where loaded mode testing will be
conducted. The basic loaded mode, centralized facility concept was selected
for several reasons. First, it was considered that the loaded mode option
offers several advantages over the idle mode, including more comprehensive
diagnostic capabilities, and more flexibility in testing procedures. Also,
there will likely be an NOX standard defined in the near future for motor
vehicles and NOX testing may become necessary as part of the I/M program;
NOx testing can only be performed with the engines under a load, as when a
loaded test is performed. The major disadvantage of the loaded mode test is
that it is slightly more expensive to perform since additional test equipment
is required. The incremental cost difference, however, is in the range
of $0.20 to $0.25 per test and is not considered to be significant.
The primary reasons for selecting the centralized facility approach over
private garages concerned program control and anticipated public acceptance of
the program. Specifically, the State would be able to exercise much closer
control over the inspection program with fewer personnel, which should result
in a much higher quality program than would be achievable if the decentralized
option was used. Further, it was considered that the public would be much
less skeptical of a program where inspections were performed by an impartial
entity who would not benefit from vehicles either failing or passing (primarily
since repairs are not performed at the centralized facilities, nor are any
individuals undergoing inspections considered "regular customers" who could
bias the inspector).
One rather significant aspect of the program has not yet been determined -
this concerns whether the State or a private contractor will be responsible for
the construction and operation of test facilities. It is hoped that the results
of the study being reported here will aid in arriving at a decision in this
matter.
Other aspects of the option have also been defined. The geographic coverage
will tentatively include only the nine counties considered previously, viz.,
• Brown County
• Dane County
• Kenosha County
• Milwaukee County
• Ozaukee County
• Racine County
• Walworth County
• Washington County
• Waukesha County
145
-------
The inspection frequency has been defined as annual with inspections
being staggered throughout the year.
The vehicle population to be tested consists essentially of all light-duty
vehicles (LDV's) and light-duty trucks (LDT's) with a gross vehicle weight of
8,000 pounds or less. Some exemptions will be made, however, for vehicles such
as farm trucks, research vehicles, and vehicles that are more than 15 years old.
The stringency level that will be used has been tentatively defined as 20
percent. Several supporting programs will also be established in conjunction
with the I/M program, including: (1) public information, (2) consumer protec-
tion, (3) quality assurance, and (A) mechanic's training. These programs may
be operated by the State or portions of each may be operated by contractors.
EMISSIONS INSPECTION SCENARIO
In order to illustate how the I/M program will work and where some of the
ancillary programs tie in, the following description of the test procedure is
offered.
The requirements for an emissions inspection in each instance will be
related to the annual registration procedure; that is, emissions inspections
will be required generally during the period when registration renewals are due.
To initiate the registration renewal process, the Division of Motor Vehicles,
within the Department of Transportation, will mail out registration renewal
forms to motorists within the nine counties approximately prior to the
registration renewal date. After receiving the material motorists will take
their vehicles to contractor (or state) operated stations for inspection.
At the inspection station, the motorist will present his renewal forms,
from which certain information will be collected and entered into a computer
file. This information would relate to items such as:
• vehicle and registration identification data
• vehicle configuration (body style, engine type, etc.)
• test type (first test, or retest).
If the vehicle is exempt, the owner is given an official waiver form printed
by the computer, and his registration form is stamped accordingly. He then
either mails or brings the stamped registration renewal material to the
Division of Motor Vehicles registration office where the registration trans-
action takes place.
Nonexempt vehicles proceed through the test lanes where the actual emission
measurements are performed. Based on the vehicle data that are input at the
beginning of the test, pass-fail criteria are automatically adjusted to the
specific vehicle being tested. If the vehicle passes the test, the registration
form is stamped appropriately and the motorist either mails or personnally
takes the stamped form to a Division of Motor Vehicles office where the
registration renewal is processed.
146
-------
If the vehicle fails inspection, the computer prints out a form stating
which standards are being exceeded, and by how much. The owner will be advised
of the probable cause for failure, and required to have the vehicle repaired
and inspected within a specified .number of days. The owner will then take
the vehicle (and the failure form) to a repair station where it is repaired
at the owner's expense. The mechanic completes the repair form indicating
the type of repair work performed.
The vehicle owner then takes the completed form and the vehicle back to
a contractor (or state) test facility for a free retest. If it now meets
emissions standards, the registration form is stamped and the owner completes
the registration process as described above.
If the vehicle fails the first retest, the vehicle owner is obliged to
go through the repair and reinspection cycle once again; however, if the
accumulated total of repair costs exceeds the repair cost limits, he will be
granted a waiver as before. The second retest (and those following if neces-
sary), however, will cost the same amount as the original test.
Should the motorist at any point in the above process have a complaint
concerning either the inspection or the maintenance phase, he may register
the complaint with the Department of Transportation. Depending on the nature
of the complaint, a variety of different actions may be taken. The motorist,
for example, may be referred to a public relations official for more informa-
tion about the program, or should any complaint uncover criminal actions, it
would be referred to the Attorney General's Office for criminal proceedings.
I/M PROGRAM NETWORK
Vehicle Population Projections
An important part of this study was deriving a reasonable estimate of
the number of vehicles that would actually be inspected during the period of
1982 through 1987. It was necessary to make accurate projections of the
motor vehicle population for each county in order to derive the network of
stations that would need to be constructed throughout the nine counties.
Using detailed county registration data provided by the Wisconsin Depart-
ment of Transportation, it was possible to make inspectable vehicle population
estimates using two different methods. The first method involved applying an
annual growth rate of 3 percent to the current vehicle population. The second
method was to derive separate growth rates for each individual county based
on vehicle population trends within that county, and to apply these growth
rates to the current population. The two resultant projections of inspectable
vehicle populations are shown in Table 48.
Then, to arrive at the number of actual inspections per year, the vehicle
populations shown in Table 48 were increased by 20 percent to account for re-
tests of failed vehicles.
147
-------
TABLE 48. 1987 INSPECTABLE VEHICLE POPULATION, USING
TWO DIFFERENT PROJECTION METHODS
County
Brown
Dane
Kenosha
Milwaukee
Ozaukee
Racine
Walworth
Washington
Waukesha
Total
Method I
117,789
219,871
84,772
638,456
48,608
121,438
50,530
56,528
202,836
1,540,918
Method II
119,335
221,928
76,908
523,051
56,516
109,278
46,831
66,073
235,399
1,455,319
For purposes of cost analysis, it was useful to calculate the average number
of inspections between 1982 and 1987. These projections, using Method II,
are shown in Table 49.
TABLE 49. INSPECTIONS REQUIRED 1982 TO 1987
Year
1982
1983
1984
1985
1986
1987
Inspections required
1,296,000
1,327,000
1,358,000
1,389,000
1,422,000
1,455,000
Average 1,375,000
148
-------
Network of Inspection Facilities
The annual capacity of a centralized emission inspection lane was cal-
culated based on the vehicle throughput time, the number of inspection-hours
per year, and an efficiency factor to account for random arrival of vehicles,
equipment down time, etc. The centralized facilities are typically highly
automated, multi-lane stations that utilize a 3-stop assembly line approach to
maximize efficiency. These facilities are capable of a 2-minute throughput
time. It was assumed that the facilities would be open 40 hours per week,
52 weeks per year, and operate at 67 percent efficiency. This translates to
an annual capacity of 41,808 inspections per year. By dividing the numbers
of inspections required in each county by the annual capacity of a single
lane, the total numbers of lanes needed for each county were derived.
In locating the inspection facilities, the maximum facility size was
limited to six lanes due to the problems associated with locating suitable
large parcels. To maximize consumer convenience, facilities were located in
or near the population centers of their respective counties. The defined
inspection network is presented in Table 50.
PROGRAM ADMINISTRATION AND PERSONNEL REQUIREMENTS
The operational and administrative personnel requirements for both the
state-run and contractor-run option were defined. Based on the experiences
of programs currently in operation, the operational personnel were defined as
shown in Table 51. These individuals would be involved in the inspection
station operation.
Administrative personnel requirements were also defined. The particular
administrative structure developed here reflects the minimum requirement;
it is likely that additional personnel, particularly consumer protection and
quality assurance investigators, may be required as the program progresses.
The structure for state-run and contractor-run options are shown in Figures 11
and 12, respectively.
Total numbers of persons employed by the program are shown in Table 51
for both a state-run and a contractor-run option.
I/M PROGRAM BENEFITS
Concern for controlling automative emissions stems from the fact automo-
bile traffic is responsible for approximately 75 percent of all urban carbon
monoxide (CO) emissions, 50 percent of hydrocarbon (HC) emissions, and 50 per-
cent of oxides of nitrogen (NOX) emissions. U.S. EPA data suggest that auto-
mobile transportation is responsible for as much as 1/4 to 23 percent of total
air pollution costs. A 1978 study by the National Highway Traffic Safety
149
-------
TABLE 50. INSPECTION NETWORK
County
Brown
Dane
Kenosha
Milwaukee
Ozaukee
Racine
Walworth
Washington
Waukesha
Total
Facility
4- lane
4- lane
3- lane
3- lane
6-lane
6-lane
3- lane
2-lane
4-lane
2-lane
2-lane
4-lane
3-lane
46 lanes,
Location
Green Bay
Madison
Madison
Kenosha
Milwaukee
Milwaukee
Greenfield
Meguon
Racine
Elkhorn
West Bend
Brookfield
Waukesha
13 facilities
Total numbers of persons employed by the program are shown in Table 51
for both a state-run and contractor-run option.
TABLE 51. PROGRAM EMPLOYEES
Personnal affiliation
Contractor (Administrative)
Contractor (Operating)
State (Administrative)
State (Operating)
Total
Number
State-run
0
0
12
169
181
of employees
Contractor-run
5
169
9
0
183
150
-------
DEPARTMENT SECRETARY
PROGRAM ADMINISTRATOR
I/M TASK FORCE
CLERICAL SUPPORT
CONSUME* PROTECTION/
QUALITY /ASSURANCE
COORDINATOR
QUALITY ASSURANCE
1NVCSTIGATOR
CONSUMER PROTECTION
INVESTIGATOR
MOT LINE OPERATOR/
CLERK
ADMINISTRATIVE FUNCTIONS
^•.^••r .«w ^^^ ^iv ^^r ^**+
-------
NJ
DEPARTMENT SECRETARY
PROGRAM ADMINISTRATOR —
ENGINEERING
COORDINATOR
CLERICAL
SUPPORT
1 » i— '
INFORMATION
TRAWNG sysTE|<5 FmANUAL
COORDINATOR ANALTST COORDINATOR
1
ACCOUNTANT
AOHIHISTRAT
OPERATIOHAL
\
\
\
I
jl/M TASK FORCE 1
1
1
1
j
1
1
1 1
CONSUMER PROTECTION/ 1
QUALI TV / ASSURANCE | *j
COORDINATOR |
* 1?
*
-------
Administration indicates that "the prorated societal cost of air pollution
caused by automobiles would be equivalent to from $24.30 to $64.30 per
vehicle."2 This same study states that "it is conceivable that national in-
spection and mandatory maintenance would reduce societal cost of pollution
$1.3 to $3.4 billion annually."
Besides these economic benefits and the benefit of decreased emissions
seen from I/M implementation, other important benefits may accrue. These in-
clude an improvement of fuel economy, which in turn has a positive effect on
gasoline consumption. Benefits have also been indicated for fleets that undergo
their own special maintenance programs.
Emissions Reductions
Emissions reduction is the primary benefit to be derived from I/M programs.
Although new vehicles are required to meet certain EPA specifications for
emissions, it has been shown that emission rates for in-use vehicles deteriorate
significantly unless adequate maintenance is performed. I/M has been suggested
as an effective means for ensuring that the necessary maintenance be performed
periodically, thus resulting in a significant decrease in emissions generated
by the motor vehicle population.
The emission reductions ("tail-pipe" reductions) refer to the decrease in
carbon monoxide (CO) and hydrocarbons (HC) from the I/M vehicles. The resultant
change in the concentrations of CO and HC in the ambient atmosphere is not
being considered here.
Various levels of reductions in emissions have been noted in ongoing I/M
programs. Actual reductions vary with the stringency factor, climate, etc.
Hamilton Test Systems, under contract to the State of Arizona, noted in a 1978
report3 that of those vehicles undergoing inspection and subsequent mainte-
nance, 25 percent reduction in idle CO emissions, and 41 percent reduction in
idle HC emissions were shown compared to those tested in 1976 (pre-I/M).
Hamilton Test Systems claims that the program is reducing by about 250 tons
daily the amount of CO and HC emitted into the atmosphere in the Arizona
counties covered by I/M, as well as saving motorists an estimated 30 million
gallons of gasoline annually.
Analyses performed by other states and federal agencies5 show similar
results.
Projected Reduction in Emissions
In order to estimate the magnitude of the reduction in emissions that
results over time from the implementation of an I/M program in Wisconsin, motor
vehicle emission inventories for both CO and HC were developed using EPA's
MOBILE I computer routine. Input data regarding vehicle-miles of travel (VMT)
by vehicle type, roadway functional class, and speed were provided by the Wiscon-
sin Department of Transportation.
153
-------
Inventories were prepared for each year beginning with 1983 through 1987
for each of the nine counties. Average daily emissions generated by light-
duty vehicles (cars and trucks) and by all vehicles were defined for two scen-
arios. The first scenario reflected the vehicle population emission charac-
teristics in the absence of an I/M program, while the second scenario reflected
the compounded effects of an I/M program beginning (mandatory maintenance) in
January 1982 on emissions each year. The percent reduction in carbon monoxide
and hydrocarbon emissions attributable to the I/M program from 1982 to 1987
is shown in Table 52 and Figures 13 and 14.
TABLE 52. PROJECTED PERCENT REDUCTIONS IN CO AND HC EMISSIONS 1983 TO
1987 DUE TO I/M
1983 1984 1985 1986 1987
Light-duty cars and trucks
CO 19 28 36 43 50
HC 14 20 27 35 42
All vehicles
CO
HC
14
12
20
17
25
23
29
30
35
36
Stringency rate = 20 percent.
The effects on emission reductions of increasing the stringency (failure
rate) to 30 and 40 percent were also studied. Increasing the stringency level
above 20 percent results in only very slight additional reductions in HC or CO,
The reason for this is that at 20 percent failure, nearly all of the gross
pollution emitters are failed, whereas the additional cars that fail when the
standards are set above this level only marginally exceed the standards. Repair-
ing these vehicles, then, has only a marginal effect on emission reductions be-
cause the worst polluters were already identified and repaired at the 20 percent
level.
The reductions shown in Table 52 occur with a stringency level of 20 per-
cent, which means that test standards are set such that 20 percent of the total
vehicles tested will fail and require repairs. U.S. EPA requires that the pro-
gram produce at least a 25 percent reduction in emissions in 1987 from vehicles
included in the program (which are basically the light-duty vehicles or
passenger cars, and the light-duty trucks, or all trucks under 8,500 Ibs
GVW) in comparison to the emissions that would be produced by these same ve-
hicles in 1987 without the program. The figures shown above indicate that
the proposed I/M program will, on the average for all counties, achieve a
154
-------
1400
1200 -
1000 -
v>
O
ft
v>
i
UJ
O
u
800
TOTAL co EMISSIONS FROM ALL VEHICLES-WITHOUT I/M
O TOTAL CO EMISSIONS FROM ALL VEHICLES-WITH I/M
ALDV AND LOT CO EMISSIONS-WITHOUT I/M
ALDV AND LOT CO EMISSIONS-WITH I/M
600 -
400 -
200 -
1983
1984
1985
1986
1987
YEAR
Figure 13. Daily CO emissions by year for LDV's and LDT's, and all
vehicles with and without I/M - 1982 through 1987.
155
-------
140
120
• TOTAL HC EMISSIONS FROM ALL VEHICLES-WITHOUT I/M
O TOTAL HC EMISSIONS FROM ALL VEHICLES-WITH I/M
ALDV AND LOT HC EMISSIONS-WITHOUT I/M
-WITH I/M
1982
1963
1984
1985
1986
1987
YEAR
Figure 14. Daily HC emissions by year for LDV's and LDT's, and all vehicles,
with and without I/M - 1982 through 1987.
156
-------
reduction of 50 percent and 42 percent for CO and HC, respectively, indicating
that program stringency is more than adequate to meet EPA's minimum standards.
Reductions by year are shown graphically for CO and EC in Figures. 10 and 11,
respectively.
Fuel Economy Benefits
One of the important benefits of I/M programs, in addition to the reduc-
tion in vehicular emissions, is potential fuel conservation. A properly tuned
engine operates with greater efficiency and therefore, consumes less fuel.
This improvement in fuel economy varies somewhat from one program to another
but most sources agree that a 5 to 10 percent fuel economy improvement for the
failed and maintained vehicles can be expected. This may understate the over-
all fleet improvement as some motor vehicle owners are likely to schedule tune-
ups just prior to having their cars inspected. One of the purposes of I/M is
to give an incentive to motorists to maintain their cars better than they nor-
mally would in the absence of I/M.
For the purposes of this study, it is assumed that the fuel economy im-
provement for vehicles that fail the emissions test and therefore undergo
maintenance, will be 7 percent averaged over a year. Applying this to the
projected vehicle population in the nine counties in 1987, the failure rate
chosen - 20 percent, and the relative travel distribution by various model
year vehicles, it is estimated that during 1987, approximately 5.76 million
gallons of gasoline would be saved as a result of the I/M program. Assuming
futther that the cost of gasoline in 1987 will be $0.80 per gallon, the fuel
cost savings associated with the 5.76 million gallons of fuel conserved is
$4.6 million. A detailed discussion concerning the derivation of the fuel
savings associated with the program is presented in Section 3, Benefits, and
Appendix C of the report.
Impact on Vehicle Performance and Life
The effects of inspection and maintenance programs on vehicle performance
and life are currently under study. Preliminary analyses in this area have
focused on various vehicle fleets and indicate that I/M does have a positive
effect on both vehicle performance and vehicle life, although specific, quan-
titative statistics are not yet available.
Some of the more notable findings to date regarding vehicle performance
come from programs established for fleets of vehicles by their owners. One
such program may be found in the City of Phoenix, Arizona. In order to reduce
on-the-road failures, an extensive preventive maintenance inspection program
was implemented for the city's vehicle fleet. Results of the program were
closely monitored resulting in the determination that: (1) the fuel consump-
tion rate during the first 6 months of the program decreased approximately
10 percent, much of which was attributable directly to the program; and (2) a
significant decrease occurred in the number of vehicles breaking down on the
road and requiring towing.
157
-------
I/M PROGRAM COSTS
Program Costs
The development of the specific costs presented in this section relies
on an analysis and breakdown of the program elements into specific cost com-
ponents. These cost components are based on the actual experiences of other
states that have implemented I/M programs very similar to the contractor-
operated centralized network described in this report. Arizona has an I/M
program similar in many ways to the one analyzed here. In addition, a thorough
analysis of the program functions and elements was undertaken to ensure
that the costs reflect as closely as possible the probable costs that will be
experienced when Wisconsin implements the proposed I/M program. However, it must
be realized that while conservative cost assumptions were made whenever fea-
sible, that there may be considerable variation in the individual cost elements
due to fluctuations in markets and in the economy.
Table 53 presents an outline of the various costs, broken down into their
component parts. Next, cost summaries for a state-run and a contractor-run
option are provided in Tables 54 and 55, respectively.
Inspection Fee Estimate
An estimate of the minimum inspection fee (breakeven fee) was calculated
in both constant 1978 dollars and actual (inflated) dollars for the period
from 1982 through 1987, for both the state-run and contractor-run options.
These fees were calculated by dividing the total annualized costs by the aver-
age number of registrations in this period (a free retest was assumed). For
the fee in actual (inflated) dollars, a 7 percent inflation rate was assumed.
The fees are shown in Table 56.
TABLE 56. BREAKEVEN FEES, fc, IN REAL 1978 DOLLARS,
AND fa, IN ACTUAL DOLLARS FOR THE STATE-
RUN AND CONTRACTOR-RUN OPTIONS
Option Fee in real (1978) dollars Fee in actual dollars
State-run
Contractor-run
4.33
4.54
5.45
5.71
ADJUNCTIVE PROGRAMS
Several basic support programs were investigated in this study. All of
these programs are important in terms of enhancing the overall effectiveness
of the program, keeping the public informed, and protecting the consumer from
potential abuses or inequities in the system. In brief the programs are as
follows:
158
-------
TABLE 53. OUTLINE OF PROGRAM COST CATEGORIES AND ELEMENTS
Primary category
Principal element
Item* included
1. Initial Capital Costs
1. Building investment
2. Land investment
3. Equipment costs
II. One-Time Startup Costs 1. Land acquisition
2. Facilities planning
3. Program design
111. Annual Operating Costs
A. Develop data handling systems
software
5. Personnel training
6. Personnel salaries and overhead
prior to startup
7. Initial public information program
8. Mechanics training program
1. Facility personnel
2. Maintenance
3. Utilities/services/supplies
IV. Annual Administrative Costs 1. Program administrative personnel
2. Enforcement
3. Consumer protection quality
assurance
4. Public information
5. Training, licensing, certification
Construction cost
Actual land coat
Pavement amd ;amdscaping
Primary test equipment
Ancillary equipment
Office equipment/furniture
Maintenance equipment
Site location studies
Title transfer costs
Design study
Bid efaluation
Construction monitoring
Develop equipment specifications
Develop subprograms (e.g., public
information, surveillance, quality
control, enforcement, etc.)
Define personnel organisational
structure
Define personnel organizational
structure
Plan program effectiveness
studies
Inspectors
Managers
Quality control personnel
Mechanics training
Wages, benefits, etc.
Equipment
Electric
Heat
Insurance
Miscellaneous
Taxes
a. Wages, overhead
159
-------
TABLE 54. COST SUMMARY - STATE-RUN OPTION
I.
II.
III.
IV.
Primary category
Initial Capital Costs 1.
2.
3.
One-Time Start-up Costs 1.
2.
3.
4.
5.
6.
7.
8.
Annual Operating Costs 1.
2.
3.
Annual Administrative Costs 1.
2.
3.
4.
Principal element
Building investment
Land investment
Equipment costs
Land acquisition
Facilities planning
Program design
Software development
Personnel training
Personnel salaries and overhead
Public information
Mechanics training
Personnel
Maintenance
Utilities /services /supplies
Personnel
Vehicle operation
Public information
Personnel training
Element cost
($)
5,323,375
2,049,376
3,674,300
245,170
1,064,675
100,000
200,000
3,784
658,862
204,000
36,380
2,413,375
635,800
572,938
180,000
3,600
204,000
272
Total
category
cost ($)
11,047,051
2,512,871
3,622,113
387,872
-------
TABLE 55. COST SUMMARY - CONTRACTOR-RUN OPTION
Primary category
I. Initial Capital Costs
II. One-Time Start-up
III. Annual Operating Costs
IV. Annual Administrative Costs
1.
2.
3.
1.
2.
3.
4.
5.
6.
7.
8.
1.
2.
3.
1.
2.
3.
4.
Principal element
Building Investment
Land investment
Equipment costs
Land acquisition
Facilities planning
Program design
Software department
Personnel training
Personnel salaries and overhead
Public information
Mechanics training
Personnel
Maintenance
Utilities/services/supplies
Personnel
Vehicle operation
Public information
Personnel training
Element cost
($)
5,323,375
2,049,376
3,674,300
245,170
798,506
100,000
200,000
3,784
603,446
204,000
36,380
2,413,375
635,800
922,549
208,125
3,600
204,000
272
Total
category
cost ($)
11,047,051
2,191,286
3,971,724
415,997
-------
• quality assurance increases the quality and uniformity of the
emission inspection and repair process
• mechanic training increases the quality of the emission repairs
• consumer protection protects the consumer from unneeded repairs
or inequities in the testing
• public convenience minimizes travel time and waiting at the
inspection lanes
• enforcement ensures a maximally effective system to ensure
compliance
• public relations provides comprehensive information to the
public on the needs, benefits, and procedures of the I/M
program
It is important to realize that these adjunctive programs interrelate and
overlap to a high degree. Some of the adjunctive program elements may serve
multiple purposes. For example, mechanics training serves to increase the
quality control of the repair or maintenance phase of the program, serves as
an important consumer protection element by encouraging more uniform, less
expensive emission tuneups and also may serve as a public relations mechanism
by orienting the mechanics to the purpose and benefits of the overall I/M
program.
Program Implementation
Implementation of Wisconsin's I/M program will proceed according to the
schedule shown in Table 57. This schedule has been specifically designed to
meet all applicable Federal requirements while at the same time displaying
differences between startup requirements applicable to the state-run and contractor-
run options. For example, from Table 57 it can be seen that under the
contractor-run option, a longer mandatory inspection-voluntary maintenance
"trial period" would be possible than under a state-run option.
CONCLUSIONS
The basic observation is that there are no significant differences involved
when' comparing State-run and contractor-run options. From a more or less sub-
jective viewpoint, however, there may be advantages to having a contractor
finance, set-up, and run the program, simply because it frees the State from
the direct responsibility of doing so, as well as eliminates the need for the
State to invest large sums of money in the program. It also appears that there
may be other types of advantages primarily with regard to how the public views
the program. It has been indicated that the public may be somewhat more re-
ceptive to a program run by a private organization compared with State-run;
these types of claims, however, are difficult if not impossible to substantiate.
In conclusion, it would appear that the primary considerations in selecting the
operating agency would likely be convenience and the impact on public per-
ception rather than any technical aspect of either option.
162
-------
TABLE 57. IMPLEMENTATION SCHEDULE - SUMMARY
00
TAS» an im Dcsamra
I. PRELIMINARY PUHKDIG
A. FOBTOLATE TENTATIVE PLANS F« THE FORMAT, SCOPE. DESIGN, OPERATIC*. AND IMPLEMENTATION
OF BASIC I/N PROGRAM EUXENTS
III TSE TEXT)
II. ENABLING LEGISLATION, DRAFT BUDGET
A. DEFINE TECHNICAL AND ADXB»IST«AIIVE ASPECTS OF THE PROGRAM THAT ARE NECESSACT TO IN-
CLUDE IN LEGISLATION
B. PREPARE ENABLING LEGISLATION
C. PREPARE PROGRAM BUDGET REQUEST
D. APPROVE I/M LEGISLATION AND FUNDING
III. PUBLIC INFORMATION PROGRAM
A. DEVELOP PROGRAM STRATEGY
D. DEFINE DETAILS OF THIRD PHASE OF THE PUBLIC INFORMATION PROGKAM, IMPLEMENT PROGRAM
IV. INSPECTION FACILITIES DEVELOPMENT
A. SELECT OPERATING AGENCT
1. IF CONTRACTOR-OPTION:
«. PREPARE RFP
b. CONTRACTORS RESPOND TO RFP, PROPOSALS REVIEWED, CONTRACTOR SELECTED
C. CONTRACTOR BEGINS SITE SEARCH AND PURCHASES REQUIRED LARD
d. CONTRACTOR CONSTRUCTS FACILITIES
2. IF STATE-RUN OPTION:
1. PREPARE INVITATION TO BID FOR FACILITT DESIGN AND CONSTRUCTION
b. EVALUATE BIDS, SELECT CONTRACTOK
C. LAND INVESTIGATION, SITE SELECTION, NEGOTIATION, AND PURCHASE
d. DEVELOP DESIGN PLANS
1978
0 II
—
_*-,
1979
-1— 1
(-»-!
H-«-
H
W-t
I960
1 1 1
1«U U
k
k,
1
-------
TABLE 57 (continued)
TASK *n> nut KSCUPTICH
• • M r«» mji *!•••
i t 11 i i i i i » i »j
1M1
AlOl* jrH*BJJA>0 ••jT
1 1 111 I 1 1 1 .. I 11 1 1 I I I I I I 1,11 •
EQUIPMENT PURCHASE
A. CONTRACTOR-SUN OPTION:
1. SELECT Aim PURCHASE EQUIPMENT
2. TAKE DELIVERY OF EQUIPMENT AS APPROPRIATE
B. STATE-RV5 OPTION.
1. ADVERTISE FOR BIDS
2. SELECT EQUIPMENT SUPPLIERS, PURCHASE EQUIPMENT, TAKE DELIVER AS APPROPRIATE
DEVELOPMENT OF CUTPOIBTS:
A. REVIEW MIA FROM EXISTIXC PROGRAMS. OfTISE IKTIAL CUTPOTRS
>. KEFIJIE CTTPOIKTS BASED 01 DATA CtWILED BT PIDOAH
PERSOKKEL elUMC, TUDIIK
A. AWUIIST1ATIVE PERSOQTCL HIKED AID BECDi UOM
1. STATE-ROU OPTIM
2. COSTRACTOR-RD« ORIO
B. ISSPECTIOH FACILITY MAHACERS AID ASSISTANT MASACERS HIREB/TRArHED
1. STATE-RUB OPTIOB
2. COSTRACTOR-RtW OPTIOI
C. DETOWIVI TRAINING PROGRAM DETAILS INCLUDDIG SCOPE, ETC.
1. STATE-RLTI OPTION
2. CONTRACTOR-RUN OPTION
D. INSPECTORS HIKED, BEGIN INSPECTOR AHD MECHANIC TRAINIHC
1. INSPECTORS HIRED AND TRAINED
a. STATE-RUN OPTIOII
b. CONTRACTOR-RUN OPTION
2. MECHAKIC TSAIKING
>. STATE-RUN OPTICS
b. CONTRACTOR-RUN OPTION
PROGRAM PHASE-IK
A. STATE-RC* OPTICS
1. IMPLEMENT MANDATORY INSPECTION VOLUNTARY HAIKTENANCE
2. IMPLm'.T riASDATOSY IXSPECTION MAHDATORY HAT»reHA.»CF
B. CONTRACTOil-RUK OPTION:
1. IXPLEME.NT MANDATORY INSPECTION VOLUNTARY HAIXTEHAIKX
2. IMPLTMEST MANDATORY INSPECTION, MANDATORY MMXTDUKI
I I I I I I I I
-------
REFERENCES
1. Midurski, T. P., et al. Phase II Final Report. GCA Corporation,
GCA/Technology Division, Bedford, Mass. Prepared for U.S. Environ-
mental Protection Agency, Region V, Chicago, Illinois. EPA 905/2-
78-003. September 1978.
2. Bayler, Ted and Leslie Eder. Impact of Diagnostic Inspection on
Automotive Fuel Economy and Emissions. National Highway Traffic
Safety Administration, Washington, D.C. 1978.
3. Bureau of Vehicular Emissions Inspection, Arizona Vehicular Emis-
sions Inspection Program Operation, Arizona Department of Health
Services. April 1978.
4. Arizona Department of Health Services. There's Something New in
the Air This Year. Arizona Vehicle Inspection Program.
5. Elston, John. New Jersey's Auto Emission Inspection Program: An
Assessment of One Year's Mandatory Operation. Department of Environ-
mental Protection. Paper Preapred at the Fourth North American
Motor Vehicle Emission Control Conference, Anaheim, California.
November 5 through 7, 1975.
165
-------
APPENDIX A
SENSITIVITY ANALYSES
GENERAL METHODOLOGY
Sensitivity analyses were performed on: (1) the affect of eliminating
two counties, Brown and Dane, on the costs associated with the Inspection/
Maintenance Program; (2) the affect of varying the stringency factor above
and below 20 percent; and (3) the affect of reducing the age exemption from
15 years old to 10 years old.
OPTION COSTS
The technique used in developing the cost analysis for the seven county
program was to utilize the same methodology and assumptions as appeared in
Section 7 of the main report. All costs reported in this Appendix, unless
otherwise noted, are in constant 1978 dollars. Costs are provided for both
a state-run and a contractor-run program, where different.
Initial Capital Costs
These items are separated into three categories: building investments,
land investments, and equipment costs.
Building Investments—
The cost for each facility in the seven county network, shown in
Table A-l, is computed as the product of: (1) the building area, and (2) the
unit cost $25/ft2. The building areas, as a function of facility configuration
have been previously presented in Section 7; the total cost for construction,
by county, is shown in Table A-2.
Land Investments—
Specific lot size requirements and unit costs for land, paving, and land-
scaping were derived in Section 7. Total land investments, including
improvements, are presented in Table A-3.
Equipment Costs—
Equipment requirements and costs as a function of facility configuration
were derived in Section 7. Total equipment costs by county are presented
in Table A-4.
The capital costs anticipated for both the state and contractor operated
systems are identical, and are summarized in Table A-5.
166
-------
TABLE A-l. INSPECTION NETWORK REQUIREMENTS
County Municipality
Kenosha Kenosha
Milwaukee Milwaukee
Greenfield
Ozaukee Meguon
Racine Racine
Walworth Elkhorn
Washington West Bend
Waukesha Brookfield
Waukesha
Total network
Number of facilities
1
2
1
1
1
1
1
1
1
10 facilities
Configuration
(lanes)
3
6
3
2
4
2
2
4
3
35 lanes
TABLE A-2. BUILDING COST ESTIMATES, SEVEN COUNTY OPTION
Facility
County c . i .
configuration
Kenosha
Milwaukee
Ozaukee
Racine
Walworth
Washington
Waukesha
Total
3-lane
6-lane
3-lane
2-lane
4-lane
2-lane
2-lane
4-lane
3-lane
Per facility Number of Total
cost, $ facilities required cost, $
344,625
699,875
344,625
241,875
454,875
241,875
241,875
454,875
344,625
1
2
1
1
1
1
1
1
1
344,625
1,399,750
344,625
241,875
454,875
241,875
241,875
454,875
344,625
4,069,000
167
-------
TABLE A-3. ESTIMATED LAND INVESTMENT REQUIREMENTS BY COUNTY,
SEVEN COUNTY OPTION
County MunicioalltT Faci-iti«* Configuration
Keoosba KmMha 1 3-lane
MilMukee KOvaok** 2 6-laae
Greenfield 1 3- lane
Ozaukee Meguon 1 2-lane
Walvorth Eikbora 1 2-lane
ON
00 Waukesha Brookfield 1 4- lane
Uautesha 1 3- lane
Lot size
per facility
(ft*)
68,925
139,975
68-925
48,315
48,375
90,975
68.925
Land
cost per
ft' (S)
1.70
1.50
1.50
0 60
0.67
2.50
2.30
Cost per
facilitv
(S)
117.173
209,963
103,388
29,025
32,411
227,438
158,528
Total
cost all
facilities
(S)
117,173
419,926
103,388
29,025
32,411
227,438
158,528
1.197,239
Total
queue
(ft:)
15,000
60,000
15.000
10,000
10,000
20.000
15,000
areas al.
facilities
(ft2)
4.725
17,550
4,725
3,105
3,105
5,940
4,725
Tctal paved
arcas a.l
facilities
ift')
19,725
77,550
19,725
13,105
13,105
25,940
19,725
Paving
(S)
0.80
o.ao
0.80
0.80
0.80
0 80
0.80
Total
pwrtng cost
(S)
15.780
62.040
15,780
10,484
10,484
20,752
15.780
182.336
T-tal
landscaped
area, all
facilities
(fe:)
35,415
146,420
35.415
25,595
25,595
46,840
35,415
Landscaping
coat per it-
0.25
0.25
0 25
0.25
0.25
0.25
0.25
0.25
Total
landscaping
coat (S)
8,854
36,606
8,854
6.399
11.710
6,399
6,399
11,710
8.854
105,785
Total
all facilities
(S)
24,634
98,646
24,634
16,883
32,462
16.863
16,883
32.462
24,634
288.121
Total laod
investment
all facilities
(S)
141,107
518,572
128,022
45.908
100,693
49,29*
58,002
259. 900
183,162
1.485.360
-------
TABLE A-4. EQUIPMENT COSTS FOR LOADED MODE TESTING, SEVEN COUNTY OPTION
... Facility Number of Equipment cost Total cost
P y configuration facilities per facility, ($) of equipment, ($)
Kenosha Kenosha 3-lane
Milwaukee Milwaukee 6-lane
Greenfield 3-lane
Ozaukee Meguon 2-lane
Racine Racine 4-lane
Walworth Elkhorn 2-lane
Washington West Bend 2-lane
Waukesha Brookfield 4-lane
Waukesha 3-lane
Total network
Calibration Vans and Equipment (4 at
Central Computer
Security Systems
Quality Assurance Investigator's van
1 219,500
2 359,000
1 219,500
1 173,000
1 266,000
1 173,000
1 173,000
1 266,000
1 219,500
33,000 each)
and equipment
Consumer Protection Investigator's van and equipment
219,500
718,000
219,500
173,000
266,000
173,000
173,000
266,000
219,500
2,427,500
132,000
250,000
14,300
33,000
33,000
2,889,800
-------
TABLE A-5. INITIAL CAPITAL COST SUMMARY, SEVEN COUNTY OPTION
Category
Building investment
Land investment
Equipment investment
Item
Construction
Purchase
Paving
Landscaping
Facility equipment
Calibration vans
Central computer
Security systems
Quality Assurance van
Consumer Protection van
Item Cost
($)
4,069,000
1,197,239
182,336
105,785
2,427,500
132,000
250,000
14,300
33,000
33,000
Category cost
($)
4,069,000
1,485,360
2,889,800
8,444,160
170
-------
One-Time Startup Costs
Costs in this category are for noncapital items and services on a one-
time basis prior to startup. Considerations used in developing cost estimates
for each element are discussed in Section 7.
Land Aquisition—
Costs for identifying and locating candidate sites, negotiating purchase
price, and completing title transfers were defined as $6,000/facility plus
10 percent of the unimproved land value. No difference is anticipated between
the state-owned and contractor-owned options.
For the network described previously, a total of 10 sites are required,
reflecting a total unimproved land investment of $1,197,239. The cost for
land acquisition, then, is calculated below:
(10 facilities)($6,000/facility) + (0.10)($1,197,239)
= ($60,000 + $119,724)
= $179,724.
Facilities Planning—
Costs associated with engineering and design for the test facilities,
bid review, and construction monitoring were defined previously as 15 percent
of the construction cost for the contractor-run option and 20 percent for the
state-run option. The total construction cost was previously defined as
$4,069,000, the cost for facilities planning, then, can be calculated as
follows:
State-run (0.20)($4,069,000) = $813,800
Contractor-run (0.15)($4,069,000) = $610,350
Program Design—
Costs for developing additional planning studies required to establish
specific formats for operation and administration of both the actual inspection
program and adjunctive programs such as public information, mechanics training,
etc. were previously defined as approximately $100,000 for both the state-run
and contractor-run alternatives.
Data Handling Software Development—
Costs for development of a comprehensive data handing software package
were previously defined as $200,000 for both the state-run and contractor-
run alternatives.
Personnel Training—
Cost estimates for training managers and assistant managers were defined,
in Section 7, as $53,00 each, while the costs for training inspectors and
calibration persons were found to be $16.00.
Applying per facility personnel requirements previously derived to the
seven county network results in the following personnel numbers:
171
-------
• 10 managers
• 10 assistant managers
• 105 inspectors
• 4 maintenance/calibration persons
Using these personnel requirements, and training costs derived previously,
the cost of training operating personnel can be computed as:
(10 managers)($53.00) + (10 assistant managers)($53.00)
+ (105 inspectors)($16.00) + (4 maintenance/calibration persons)($16.00)
= $2,-804.00
In addition, the state will have two investigators who will require
training. A cost of $59.00 was derived for investigator training, this
translates to $118.00 for training the two investigators.
The total cost, then, is the sum of the cost of training operating
personnel plus the cost of training investigators, or:
$2,804.00 + $118.00 = $2,922.00
Personnel Salaries—
Personnel salaries and phase in schedules were defined previously in
Section 7. Applying these schedules to the personnel requirements for this
option, a total operating personnel cost estimate for startup can be derived:
(10 managers)($1,667.00 per moth)(6 months)
+ (10 assistant managers)($1,125 per month)(6 months)
+ (4 maintenance/calibration persons)($1,000 per month)(1 month)
+ (105 inspectors)($867.00 per monthXl month)] 1.25
= $328,194
The administrative personnel costs for the startup period were defined
previously in Section 7. These costs are provided in Tables A-6 and A-7 for
the state-run and contractor-run options respectively. The total cost for
startup, then, is the sum of the cost for operating personnel plus administra-
tive personnel, or:
State-run $328,194 to $230,834 = $559,028
Contractor-run $328,194 to $175,418 = $503,612
172
-------
TABLE A-6. ADMINISTRATIVE PERSONNEL COSTS ASSOCIATED WITH
PROGRAM STARTUP, STATE-RUN OPTION
Number Annual Partlci tion
Job title f . Sa}fy (months)
positions (?)
Administrator
Training officer
Legal advisor
Engineering coordinator
Systems engineer /analyst
Financal coordinator
Accountant
Consumer protection investigator
Quality assurance investigator
Consumer protection/quality
assurance supervisor
Clerical support
Total salaries for 24 months
Overhead @ 25 percent
Totals
1
1
1
1
1
1
1
1
1
1
2
12
25,000
13,000
15,000
15,000
11,000
15,000
12,000
15,000
15,000
15,000
9,000
24
12
6
18
1
24
6
1
2
12
24/each
Salary
startup period
($)*
50,000
13,000
7,500
22,500
917
30,000
6,000
1,250
2,500
15,000
36,000
184,667
46,167
230,834
Salary for participation during 24-month startup period (all positions).
173
-------
TABLE A-7. ADMINISTRATIVE PERSONNEL COSTS ASSOCIATED WITH
PROGRAM STARTUP, CONTRACTOR-RUN OPTIONS
Number
Job title of
positions
Administrator 1
Training officer 1
Legal advisor 1
Engineering coordinator 1
Systems engineer analyst 1
Financial coordinator 1
Consumer protection 1
Quality assurance
investigators 1
Consumer protection/qualtiy
assurance supervisor 1
Clerical 1
Total salaries for
state personnel
Overhead f 25 percent
Total state cost
Contractor personnel:
Administrator for station
operations 1
Legal counsel 1
Purchasing/contracts
officer 1
Engineer /analyst 1
Inspector training
coordinator l
Clerical 1
Total salaries for contractor
personnel
Overhead @ 25 percent
Total contractor cost
Annual
salary
($)
25,000
13,000
15,000
15,000
11,000
15,000
15,000
15,000
15,000
9,000
25,000
15,000
13,000
11,000
13,000
9,000
Participation
(months)
12
6
4
6
1
6
1
2
6
12
12
6
12
12
2
12
TOTAL COST
Salary
startup period
($)*
25,000
6,500
5,000
7,500
917
7,500
1,250
2,500
7,500
9,000
72,667
18,167
90,834
25,000
7,500
13,000
11,000
2,167
9,000
67,667
16,917
84,584
- 175,418
Salary for participation during 12-month startup period.
174
-------
Initial Public Information Program—
As discussed in Section 7, a preimplementation budget of $0.12/test to
be performed has been suggested. The elimination of Brown and Dane counties
from the program would reduce the inspectable fleet to 1.1 million vehicles,
or 1,320,000 tests annually. This translates to an initial public information
expenditure of $158,400.
Mechanics Training—
As discussed previously, in Sections 4 and 7, an estimate of the initial
cost for a mechanics training program is $36,380.
A summary of anticipated startup costs is presented in Table A-8.
TABLE A-8. SUMMARY OF STARTUP COSTS, SEVEN COUNTY ALTERNATIVE
Item
Land Acquisition
Facilities Planning
Program Design
Data Handling Software
Development
Personnel Training
Personnel Salaries and Overhead
Public Information
Mechanic Training
State-run
Option
$ 179,724
813,800
100,000
200,000
2,922
559,028
158,400
36,380
$2,050,254
Contractor -run
Option
$ 179,724
610,350
100,000
200,000
2,922
503,612
158,400
36,380
$1,791,388
Annual Operating Costs
Annual operating costs include all costs associated with the actual opera-
tion of the program. For the purposes here, the costs of adjunctive programs
(e.g., public information, inspection/mechanic training, etc.) are included
under "Annual Administrative Costs", which are discussed later.
Facility Personnel—
Applying facility staffing requirements and annual salaries associated with
job category, the annual operating personnel costs can easily to calculated.
This estimate, shown in Table A-9, is assumed the same for either the contractor-
run or the state-run options.
175
-------
TABLE A-9. ANNUAL PERSONNEL COSTS FOR FACILITY PERSONNEL
J b T'tle Total number Annual Salary
of positions ($)
Manager 10 20,000
Assistant Manager 10 13,500
Calibration/Maintenance 4 12,000
Inspectors 105 10,400
Total salaries
Overhead at 25 percent
Total annual salaries
for all positions
($)
200,000
135,000
48,000
1,092,000
1,475,000
368,750
1,843,750
176
-------
Maintenance—
The yearly cost for equipment repair and preventive maintenance was
previously defined as 20 percent of the original equipment cost, or:
(0.20)($2,427,500) = $485,500
Utilities/Services/Supplies
Included in this element are the costs associated with electricity, heat,
building services, insurance, computer operation, inspection forms, calibration
costs, taxes and uniforms.
Utilities—
As previously defined, the electric usage requirements for loaded mode
testing are 120 kWh/day for each lane, plus 325 kWh/day for each facility.
Applying these rates and a $0.05/kWh cost provided by Wisconsin Power and
Light to the seven county network, the annual cost then for utilities is:
(35 lanes)(120 kWh/day)($0.05/kWh)(250 Operating day/yr)
+ (10 facilities)(325 kWh/day)($0.05/kWh)(250 Operating day/yr) = $93,125
Insurance—
An annual cost of $l,500/lane has been derived previously for liability,
fire, theft, and vandalism insurance. This translates to $52,500 annually
for insurance for 35 lanes.
Computer Operation—
A cost of $0.15/test was previously defined for computer operation costs.
Given a seven county total of 1,320,000 tests annually, this translates to
$198,000 annually.
Inspection Forms—
A cost of $0.03/test was previously derived for inspection forms. Given
a seven county total of 1,320,000 tests annually, this translates to $39,600
annually.
Calibration Costs—
In Section 7, an annual cost of $ll,000/calibration/maintenance person
was computed for annual calibration costs. Applying this rate to the four
persons required, this computes to $44,000 annually.
Taxes—
General property and real estate taxes must be included for a contractor-
run option. Total annual taxes, itemized by municipality are provided in
Table A-10.
Uniforms—
An annual cost qf $125.00 was derived in Section 7 as a per employee
cost for uniforms. This translates to $16,125 annually for 129 uniformed
employees.
177
-------
TABLE A-10. ANNUAL TAXES - CONTRACTOR-RUN OPTIONS
oo
County
Brown
Dane
Kenosha
Milwaukee
Ozaukee
Rac ine
Walworth
Washington
Waukesha
Additional
Total
Municipality
Green Bay
Madison
Madison
Kenosha
Milwaukee
Greenfield
Mequon
Racine
Elkhorn
West Bend
Brookfield
Waukesha
Equipment
Facilities/ General property
lanes value (S)
1/4
1/4
1/3
1/3
2/6 ea.
1/3
1/2
1/4
1/2
1/2
1/4
1/3
720,875
720,875
564,125
564,125
2,117,750
564,125
414,875
720,875
414,875
414,875
720,875
564,125
462,300
General property
tax rate*
0.02758
0.03174
0.03174
0.02931
0.04270
0.02974
0.02557
0.03322
0.03045
0.02185
0.02531
0.02412
0.04270**
General property Real estate
tax (S) value (S)
19,882
22,881
17,905
16,535
90,428
16,777
10,608
23,947
12,633
9,065
18,245
13,607
19,740
187,120
214,412
162,484
141,807
518,572
128,022
45,908
100,693
49,294
58,002
259,900
183,162
-
Real estate*
tax rate
0.02317
0.02704
0.02704
0.02556
0.03592
0.02524
0.02236
0.02826
0.02594
0.02012
0.02216
0.02124
-
Real estate
tax (S)
4,336
5,798
4,394
3,625
18,627
3,231
1,027
2,846
1,279
1,167
5,759
3,890
-
Total taxes
annually (S)
24,218
28,679
22,299
20,160
109,055
20,008
11,635
26,793
13,912
10,232
24,004
17,497
19,740
273,036
Source: Town. Village, and City Taxes - 1976. Bulletin Nos. 176. 276 and 376 combined. Wisconsin Department of
Revenue, Division of Research and Analysis, Bureau of Local Financial Assistance.
Additional equipment assumed housed in Milwaukee.
-------
The total cost for utilities, services, and supplies is provided in
Table A-ll for both the state-run and contractor-run options.
TABLE A-ll. ANNUAL COSTS FOR UTILITIES, SERVICES,
AND SUPPLIES - STATE VERSUS CONTRACTOR-
RUN OPTIONS, SEVEN COUNTY ALTERNATIVE
Item
Utilities
Insurance
Computer Operation
Inspection Forms
Calibration Costs
Taxes
Uniforms
Total
State -run
option cost ($)
$ 93,125
52,500
198,000
39,600
44,000
0
(exempt)
16,125
$443,350
Contractor -run
option cost ($)
$ 93,125
52,500
198,000
39,600
44,000
273,036
16,125
$716,386
Annual Administrative Costs
Costs involved in this category include salaries of personnel involved
in areas such as enforcement, consumer protection, public information, training
and overall program administration. Also, the cost for the public information
program, and operating costs for investigators' vehicles are included in this
category.
Program Administrative Salaries and Overhead—
Annual administrative personnel costs will not vary between the nine
county option presented in Section 7 and the seven county option presented
here. These costs are:
State-run $180,000
Contractor-run $208,125
179
-------
Vehicle Operating Costs—
As previously derived, the state will have two vehicles for mobile
investigators. Assuming an operating cost of $0.15/vehicle and annual travel
of 12,000 miles, the annual cost of vehicle operation may be calculated as:
(2 vehicles)(12,000 miles/yr)($0.15 per mile) = $3,600
Public Information—
A cost of $0.12/test was defined as a reasonable estimate of annual
public information costs. Applying this rate to an average annual number of
1,320,000 vehicles; this equates to $158,400 annually for public information.
Personnel Training—
A replacement rate of 10 percent of the inspector work force was defined
previously in Section 7. This translates to 13 new inspectors/year for the
seven county option. The cost of training a new inspector was previously
found to be $16.00, therefore the entire cost is:
(13 persons)($16.00/person) = $208.00
Summary
The total cost for both the state-run and the contractor-run options
are itemized in Tables A-12 and A-13, respectively.
FEE COMPUTATION
Annualized Costs
In order to compare costs of the two seven county options with those of
the two nine county options and to devise a "breakeven fee", all costs from
Tables A-12 and A-13 are converted into annual figures using the same
methodology as was presented in Section 7.
Annualized costs for both seven county options are presented in Tables
A-14 and A-15 in constant 1978 dollars and actual (inflated) dollars,
respectively.
Fee Calculation
Breakeven fees were calculated for both options in constant and actual
dollars. These fees are calculated by dividing the total annualized cost
by the total average number of vehicle registrations (expected to be 1.1
million). These fees, which reflect one free retest for failed vehicles,
are presented in Table A-16.
Cost Schedule
From the implementation schedule derived in Section 8, cost schedules
were defined for both the state-run and contractor-run options, these schedules
are provided in Tables A-17 and A-18, respectively.
180
-------
TABLE A-12. COST SUMMARY - STATE-RUN OPTION
00
Primary category
I. Initial capital costs 1.
2.
3.
II. One-time startup costs 1.
2.
3.
4.
5.
6.
7.
8.
III. Annual operating costs 1.
2.
3.
IV. Annual administrative 1.
costs
3.
4,
Principal element
Building investments
Land investments
Equipment costs
Land Acquisition
Facilities planning
Program design
Software development
Personnel training
Personnel salaries and overhead
Public information
Mechanics training
Personnel
Maintenance
Utilities/ services /supplies
Personnel
Vehicle operation
Public information
New personnel training
Element cost Total category cost
($) (?)
4,069,000
1,485,360
2,889,800
8,444,160
179,724
813,800
100,000
200,000
2,922
559,028
158,400
36,380
2,050,254
1,843,750
485,500
443,350
2,772,600
180,000
3,600
158,400
208
342,208
-------
TABLE A-13. COST SUMMARY - CONTRACTOR-RUN OPTION
Primary category
Principal element
Element cost Total category cost
($) ($)
I. Initial capital costs
II. One-time startup costs
00
III. Annual operating costs
1. Building investments
2. Land investments
3. Equipment costs
1. Land acquisition
2. Facilities planning
3. Program design
4. . Software development
5. Personnel training
6. Personnel salaries and overhead
7. Public information
8. Mechanics training
1. Personnel
2. Maintenance
3. Utilities/services/supplies
IV. Annual administrative costs 1. Personnel
2. Vehicle operation
3. Public information
4. New personnel training
4,069,000
1,485,360
2,889,800
179,724
610,350
100,000
200,000
2,922
503,612
158,400
36,380
1,843,750
485,500
716,386
208,125
3,600
158,400
208
8,444,160
1,791,388
3,045,636
370,333
-------
TABLE A-14. ANNUALIZED COSTS IN CONSTANT 1978 DOLLARS
oo
Cost Category
Cost
,_, Amortization factor
* (i = 0.06)
Annual ized
(column 2 x
cost (S)
column 3)
State-run option
I.
II.
III.
IV.
Capital costs
1 . Land
2. Buildings
3. Equipment
Startup costs
Operating costs
Administrative costs
Total, State-run option
1,485
4,069
2,889
2,050
2,772
342
,360
,000
,800
,254
,600
,208
0.
0.
0.
0,
1.
1.
,0600
,0870
,2374
.2374
.0
.0
89
354
686
484
2,772
342
4,730
,122
,003
,039
,730
,600
,208
,702
Contractor-run option
I.
II.
III.
IV.
Capital costs
1 . Land
2. Buildings
3. Equipment
Startup costs
Operating costs
Administrative costs
1,485
4,069
2,889
1,791
3,045
370
,360
,000
,800
,388
,636
,333
0
0
0
0
1
1
.0600
.0870
.2374
.2374
.0
.0
89
354
686
454
3,045
370
4,970
,122
,003
,039
,276
,636
,333
,409
-------
TABLE A-15. ANNUALIZED COSTS IN ACTUAL (INFLATED) DOLLARS
oo
Cost category Cost
, „•. Amortization factor
l'' (i = 0.06)
Annual ized
(column 2 *
cost ($)
column 3)
State-run option
I.
II.
III.
IV.
Capital costs
1 . Land 1 ,
2. Buildings 4,
3. Equipment 2,
Startup costs 2,
Operating costs 2,
Administrative costs
Total, State-run option
485
069
889
050
772
342
,360
,000
,800
,254
,600
,208
0.
0.
0.
0.
1.
1.
1300
1420
2840
2840
210
210
193,
577,
820,
582,
3,354,
414,
5,942,
097
798
703
272
846
072
788
Contractor-run option
I.
II.
III.
IV.
Capital costs
1 . Land 1 ,
2. Buildings 4,
3. Equipment 2,
Startup costs 1,
Operating costs 3,
Administrative costs
Total, Contractor-run option
485
069
889
791
045
370
,360
,000
,800
,388
,636
,333
0.
0.
0.
0.
1.
1.
1300
1420
2840
2840
210
210
193,
577,
820,
508,
3,685,
448,
6,233,
097
798
703
754
220
103
675
-------
TABLE A-16. BREAKEVEN FEES, fc IN CONSTANT 1978
DOLLARS, AND FEE IN ACTUAL DOLLARS
FOR THE STATE-RUN AND CONTRACTOR-RUN
OPTIONS; SEVEN COUNTY ALTERNATIVE
Option
State-run
Contractor-run
Fee in constant
1978 dollars
4.30
4.52
Fee in actual
(inflated) dollars
5.40
5.67
185
-------
TABLE A-17. COST SCHEDULE FOR A STATE-RUN PROGRAM, 1979 THROUGH 1987
oo
Year
1979
1980
1981
1982
1983
1984
1985
1986
1987
Total
Capital ($)
0
8,444,160
0
0
0
0
0
0
0
8,444,160
Startup ($)
512,654
1,024,946
512,654
0
0
0
0
0
0
2,050,254
Cost category
Annual operating
($)
0
0
1,386,300
2,772,600
2,772,600
2,772,600
2,772,600
2,772,600
2,772,600
18,021,900
Administrative
(S)
0
0
171,104
342,208
342,208
342,208
342,208
342,208
342,208
2,224,352
Accumulative
total costs
($)
512,654
9,981,760
12,051,818
15,166,626
18,281,434
21,396,242
24,511,050
27,625,858
30,740,666
30,740,666
Accumulative*
total revenues
($)
0
0
2,750,000
8,250,000
13,750,000
19,250,000
24,750,000
30,250,000
35,750,000
35,750,000
Surplus/
deficit
-9,301,818
-6,916,626
-4,531,434
-2,146,242
+ 238,950
4-2,624,142
+5,009,334
+5,009,334
Assumes a $5.00 fee. All figures in constant 1978 dollars.
-------
TABLE A-18. COST SCHEDULE FOR A CONTRACTOR-RUN PROGRAM, 1979 THROUGH 1987
oo
Year
1979
1980
1981
1982
1983
1984
1985
1986
1987
Total
Capital (S)
5,554,360
2,889,800
0
0
0
0
0
0
0
8,444,160
Startup ($)
0
1,791,388
0
0
0
0
0
0
0
1,791,388
Cost category
Annual operations
($)
0
0
3,045,636
3,045,636
3,045,636
3,045,636
3,045,636
3,045,636
3,045,636
21,319,452
Accumulative
.... . total costs
Administrative . .
($) C$)
0
0
370,333
370,333
370,333
370,333
370,333
370,333
370,333
2,592,331
5,554,360
10,235,548
13,651,517
17,067,486
20,483,455
23,899,424
27,315,393
30,731,362
34,147,331
34,147,331
Accumulative
total revenues
($)
0
0
5,500,000
11,000,000
16,500,000
22,000,000
27,500,000
33,000,000
38,500,000
38,500,000
Surplus/
deficit
- 5,554,360
-10,235,548
- 8,151,517
- 6,067,486
- 3,983,455
- 1,899,424
+ 184,607
+ 2,268,638
+ 4,352,669
+ 4,352^.669
-------
EMISSIONS
Two separate analyses were performed to determine the impact of varying
two program variables — stringency factor and vehicle exemptions — on total
emissions reductions within the nine-county area being considered. The results
of these analyses are described here.
Varying Stringency Factors
The emission reduction computations described previously were repeated
using stringency factors of 10 through 40 percent, in increments of 10 percent.
The reductions as a percentage of first, emissions produced from the light-
duty truck and car population, and second, emissions produced by the entire
highway vehicle population, are shown in Table A-19, below, for CO and HC.
TABLE A-19. EFFECT OF VARYING STRINGENCY FACTOR ON CO
AND HC EMISSIONS - PRESENTED AS PERCENT
EMISSIONS REDUCTION AS A FUNCTION OF
STRINGENCY FACTOR
Stringency factor
Pollutant Vehicles considered
10% 20% 30% 40%
CO
LDV
All
and LOT
highway
only
vehicles
43
29
50
35
55
38
57
40
HC LDV and LOT only 37 42 46 48
All highway vehicles 32 36 38 40
It is quite clear from the table above that the benefits associated with
increasing stringency diminish at a rather rapid rate, especially when the
stringency factor exceeds 20 percent. It can also be seen that the criterion
established by EPA for minimum reduction of 25 percent in the emissions from
the affected vehicles by 1987, would be met with a stringency factor even as
low as 10 percent.
Varying Vehicle Exemption Criteria
The emissions reductions shown above (and throughout the report) reflect
an inspectable vehicle population that consists of most passenger cars and
light trucks that are not older than 15 years. However, it may be of interest
to determine the emissions reductions achievable with a lower age exemption.
For this analysis vehicles older than 10 years were excluded from the inspectable
population and the emissions were computed for both CO and HC for 1987, for
various stringency levels, as before. The results are shown in Table A-20.
188
-------
TABLE A-20. EFFECT OF VARYING THE VEHICLE AGE
EXEMPTION ON EMISSIONS REDUCTIONS
FOR 1987
Percent reduction
Pollutant Vehicle categories
CO
HC
LDV
All
LDV
All
and LOT
highway
and LOT
highway
only
vehicles
only
vehicles
10%
37
26
35
30
<-j-j-ii£,<=
20%
43
30
39
33
30%
47
32
41
35
40%
51
34
42
36
Again, the scenario that would affect the fewest vehicles — that is a
10 percent stringency factor and an age exemption for vehicles older than 10
years — would still meet the EPA minimum reduction criterion.
189
-------
APPENDIX B
DETAILED DESCRIPTION OF METHODOLOGY FOR
CALCULATING EMISSION INVENTORIES
Emission inventories were calculated using the Mobile I computer program.
The Mobile I routine is based upon vehicle-specific emission factors for ve-
hicles operating through the EPA's Federal Test Procedure (FTP) urban driving
cycle. The program, thus, contains tables of emission levels for each model
year vehicle from 1950 to 1990 for various vehicle ages between 0 and 20 years
old. Separate tables are used for light-duty vehicle (LDV), light-duty truck 1
(under 6,000 Ib gross) LDT-1, light-duty truck 2 (between 6,000 Ib and 8,500 lb-
gross) LDT-2, heavy duty diesel, and heavy duty gasoline. Separate tables are
also given for three geographic regions: California, high altitude areas, and
the rest of the country. The latter tables are used for Wisconsin.
Since the basic emission factors are FTP specific, factors must be adjusted
to reflect driving patterns in local areas. Mobile I contains correction fac-
tors for temperature, speed, hot/cold/stabilized travel, air conditioning,
vehicle load, trailer towing, and humidity. Due to lack of reliable data for
Wisconsin, default values (FTP-specific conditions) are used for air condition-
ing, vehicle load, and trailer towing. Humidity affects nitrogen oxide only
and, thus, is irrelevant for our applications. Hot/cold/stabilized VMT is as-
sumed to be the same as national averages: 21 percent/27 percent/52 percent.
Temperature is taken at 75°F - this represents a typical July day when vehicle
emissions are most acute.
The most important correction factor is vehicle speed. Emissions are not
linear with respect to speed. So, whenever possible, speed classes must be
differentiated. For all counties except Brown and Dane, speed classes are
created by dividing travel between freeways, arterials, and local roads.
For a particular year, say 1987, the above factors give emissions per mile
traveled for vehicles of various ages. To get aggregate per mile emissions for
1987, the emission factors for the various aged vehicles are weighted by the
travel proportion for vehicles of that age (e.g., see the last column of
Table B-l). The data used in calculating travel proportions, the distribution
of vehicle ages and the travel of vehicles by age, are national averages con-
tained in Mobile I. A Wisconsin vehicle age distribution for a particular year
Is inappropriate since it would reflect low sales in periods of recession and
these cyclic fluctuations would be projected into the future periods.
To get aggregate emissions per mile for a particular county or region,
values must be combined across the various speed classes (freeways, arterials
local roads). This is achieved by taking weighted averages using vehicle
190
-------
TABLE B-l. TRAVEL WEIGHTING FACTOR CALCULATION
LIGHT-DUTY VEHICLES
Vehicle
age
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
(a)
Fraction total
registration
0.075
0.107
0.107
0.106
0.100
0.092
0.085
0.077
0.066
0.052
0.039
0.027
0.018
0.014
0.009
0.006
0.005
0.005
0.005
0.004
i(b-i ( \*(^ ((a)*(b)/sum)
Annual mileage (a)*(b) Travel fraction
accumulation rate
15,900
15,000
14,000
13,100
12,200
11,300
10 , 300
9,400
8,500
7,600
6,700
6,600
6,200
5,900
5,500
5,100
5,000
4,700
4,400
4,400
1,192.5
1,605.0
1,498.0
1,388.6
1,220.0
1,039.6
875.5
723.8
561.0
395.2
261.3
178.2
111.6
82.6
49.5
30.6
25.0
23.5
22.0
17.6
Sum: 11,301.0
0.106
0.142
0.133
0.123
0.108
0.092
0.077
0.064
0.050
0.035
0.023
0.016
0.010
0.007
0.004
0.003
0.002
0.002
0.002
0.002
191
-------
miles traveled (VMT) for the weighting fractions. To calculate total daily
emission levels, emissions per mile are multiplied by VMT. The raw VMT and
speed data used in this study are given in Table B-2 and Table B-3. These
data are interpolated to the analysis years of 1977 and 1987 and are given
in Table B-4 and Table B-5.
To calculate the effect of an I/M program on emissions, EPA derived -
Appendix N, credits (percent reductions) are applied to emission factors. I/M
credits are given for carbon monoxide and hydrocarbons, various technologies
of vehicles (technology 1 vehicles built prior to 1975, technology 2 vehicles
built from 1975 to 1979, technology 3 vehicles built in 1980 and technology 4
vehicles built after 1980) with and without mandatory maintenance, with strin-
gency levels of 10, 20, 30, 40 and 50 percent, and for the number of years I/M
has been in effect. In this study, I/M included mandatory maintenance, was at
a stringency level of 20 percent, and had been in effect for 5 years (from 1982
to 1987). These I/M credits are also specific to vehicle type. These credits
differ substantially from those found in the May 1977 version of Appendix N.
Current I/M credits apply to light-duty vehicles and light-duty trucks.
192
-------
TABLE B-2. DAILY VMT FOR BROWN AND DANE COUNTIES
Brown County - VMT analysis is for an area which is 85.4 percent of the
county population. VMT is approximately 10 percent low since some
local streets are omitted.
1974 1,441,506
2000 3,081,910
Average speeds are:
1974 31.6 mph
2000 23.0 mph
Vehicle types are
Auto 85.0%
Light truck 10.3%
Heavy truck (gas) 3.2%
Heavy truck (diesel) 1.5%
Dane County - VMT analysis is for an area which is 72.8 percent of the
county population. VMT is approximately 10 percent low since some
local streets are omitted.
1970 2,725,797
2000 4,278,454
Average speeds are:
1970 32.4 mph
2000 30.9 mph
Vehicle types are
Auto 85.0%
Light trucks 8.5%
Heavy trucks (gas) 4.0%
Heavy trucks (diesel) 2.5%
Source: Wisconsin Department of Transportation
Madison, Wisconsin.
193
-------
TABLE B-3. DAILY VMT AND AVERAGE SPEED
Kenosha Co.
Freeways
Arterials
Milwaukee Co.
Freeways
Arterials
Ozaukee Co.
Freeways
Arterials
Racine Co.
Freeways
Arterials
Walworth Co.
Freeways
Arterials
Washington Co.
Freeways
Arterials
Waukesha Co.
Freeways
Arterials
7 Counties
Local/
Collectors
LDV
304,200
895,300
3,404,300
6,078,700
182,000
521,500
324,100
1,204,200
147,700
621,200
166,800
786,200
814,000
1,926,700
2,017,700
LOT
4,900
72,000
201,900
308,100
1 1 , 300
34,100
11,600
110,200
8,900
76,300
9,600
82 , 300
47,900
179,900
151,800
1972
HDG
4,000
53,400
238,300
321,400
7,600
32,400
15,600
75,500
4,600
68,300
5,700
56,200
56,100
199,500
148,700
HDD
68,600
25,300
132,500
9,800
22,100
39,000
63,700
8,100
4,000
51,200
7,900
36,300
51,100
37,900
135,700
Average
speed
(mph)
65.0
32.6
48.5
24.5
62.9
38.6
64.5
29.6
64.6
39.7
65.0
43.3
60.8
36.2
20.0
4
LDV
368,000
1,423,800
4,441,200
5,525,200
444,500
612,700
550,700
1,568,100
322,500
826,800
351,600
826,700
1,474,200
2,558,100
2,092,800
LOT
22,000
128,500
270,500
374,100
34,200
40 , 700
27,300
141,500
32,900
105,700
39,800
118,500
117,600
275,900
157,200
1985
HDG
3,200
53,100
267,800
329,600
9,100
32,600
13,900
76,800
12,300
61,500
7,900
58,200
72,500
211,600
122,900
HDD
68,00
26,300
154,900
23,000
62,000
4,200
69,900
11,900
36,000
41,500
43,200
22,800
66,300
31,300
9,900
Average
speed
(mph)
53.9
35.1
41.2
25.1
54.2
36.3
54.2
33.2
53.6
40.6
53.2
38.2
53.1
35.9
20.0
LDV
732,400
1,706,200
5,073,200
5,704,200
549,300
749,400
1,022,400
1,654,300
964,200
992,000
691,100
948,700
1,591,800
3,362,600
2,381,300
LOT
41,300
102,000
328,600
375,800
34,500
39,000
43,600
92 , 300
100,400
100,600
52,200
71,700
118,500
281,400
179,400
2000
HDG
9,400
109,100
296,000
375,300
19,300
43,700
20,000
142,500
22,100
82,400
37,300
104 , 300
99,100
321,200
136,600
HDD
97,400
30,600
196,200
21,400
78,700
5,000
91,200
14,300
149,800
39,200
71,700
22,500
76,100
31,600
10,200
Average
speed
(mph)
53.4
36.1
47.0
24.0
54.3
36.4
53.6
34.0
52.8
41.5
53.0
38.2
54.6
35.9
20.0
Source: SEWRPC, Milwaukee, WI
-------
TABLE B-4. WISCONSIN VMT 1977
Kenoshn Co .
Freeway
Arterial
Mi I waukne Co .
Freeway
Arterial
0/,,'uikee Co.
Freeway
Arterial
K.IC in
-------
TABLE B-5. WISCONSIN VMT 1987
Kenosha Co.
Freeway
Arterial
T. VMT
(000)
521
1,674
% LDV % LDT 1 % LDT 2 % HDG
79.8
87.2
2.9
4.7
1.9
3.2
0.7
3.3
% HDD
14.8
1.6
Average
speed (mph)
53.9
35.1
Milwaukee Co.
Freeway
Arterial
Ozaukee Co.
Freeway
Arterial
Racine Co.
Freeway
Arterial
Walworth Co
Freeway
Arterial
Washington
Freeway
Arterial
Waukesha Co
Freeway
Arterial
7 County
Local
Brown Co.
All
Dane Co.
All
All (1 a t a is
l.ij>,lit duty
0.6 and 0
l''or Brown
5,232
6,277
567
711
737
1,811
.
464
1,063
Co.
499
1,047
1,750
' 3,706
2,382
2,912
5,451
derived
86.5
88.4
80.8
88.8
83.2
87.2
79.9
79.8
79.5
80.6
85.2
83.1
.8 87.8
.6 85.0
.1 85.0
directly
trucks are divided
.4.
VMT = (1
1} Table
3.2
3.6
3.7
3.5
2.5
4.7
4.9
6.1
5.4
6.9
4.1
5.4
4.0
8.7
6.8
from Tables
into LDT 1
(G) Value
2.1
2.4
2.5
2.4
1.6
3.2
3.2
4.1
3.6
4.6
2.7
3.6
2.6
1.6
1.7
A-3
and
For I
5.2
5.3
1.7
4.7
2.1
4.3
3.0
5.9
1.8
5.7
4.2
6.9
5.2
3.2
4.0
and A-4
LDT 2 in
Danp VMT
3.0
0.4
11.3
0.6
10.6
0.7
8.9
4.0
9.8
2.2
3.8
1.0
0.4
1.5
2.5
41.2
25.1
,
54.2
36.3
54.2
33.2
53.6
40.6
53.2
38.2
53.1
35.9
20
27.3
31.6
by linear interpolation
proportions of
= n i
.Table (G) Value
0.728
196
-------
REFERENCES
i. U.S. Environmental Protection Agency. Mobile Source Emission Factors.
For Low-altitude areas. Final Document. EPA-400/9-78-006. March 1978.
2. U.S. Environmental Protection Agency. Appendix N - Emission Reduction
Achievable Through Inspection and Maintenance of Light-Duty Vehicles,
Motorcycles and Light- and Heavy-duty trucks. Proposed Rule. Federal
Register 24(84):22177-22183. May 2, 1977.
197
-------
APPENDIX C
ESTIMATED FUEL SAVINGS IN 1987 RESULTING FROM I/M
Fuel savings from the implementation of I/M in selected counties is
calculated by determining program impact on the fuel consumption of LDTs and
LDVs under 16 years old. Four factors are critical in deriving these figures.
They are: (1) the stringency rate established, (2) average fleet fuel consump-
tion rate (for LDV, LDT1 and LDT2) measured in miles per gallon, (3) total
vehicle miles traveled (VMT) , and (4) actual fuel economy improvement resulting
from I/M.
The program will cover LDVs, LDTls and LDTZs. Since vehicles in each of
these categories exhibit different fuel consumption patterns, fuel savings
are estimated separately for each of them.
The formula used to calculate fuel savings is:
(VMTl (Wl
Gallons saved per year = v VI:.; ' x S x F x 322
where: VMT = daily vehicle miles traveled by the pertinent vehicle type
in selected counties in 1987
W = weighting factor to determine how many VMT are generated
by vehicles covered by the I/M program
FM = average fleet mileage for a fleet of a certain vehicle
type in 1987
S = stringency rate
F = improvement in fuel economy realized by failed vehicles
undergoing required maintenance
322 = factor to adjust daily VMT by yearly VMT
FUEL SAVINGS
LDV Fuel Savings
Table C-l presents an estimate of the total VMT generated daily by LDVs
in 1987. This figure must be adjusted to reflect VMT generated by LDVs less
than 16 years old. Table C-2 calculates travel weighting fractions for LDVs
by model year. These fractions are summed in Table C-3 resulting in W = 0.989.
-------
Also, applying the weighting fractions to EPA mile per gallon figures by model
year results in an average LDV fleet mileage figure of 24.622 miles per gallon.
TABLE C-l. ESTIMATED DAILY LDV VMT FIGURES FOR
SELECTED COUNTIES FOR 1987
„ ^ Daily vehicle miles traveled
County J .. , , .
J (in thousands)
Kenosha 2,195
Milwaukee 11,509
Ozaukee 1,278
Racine 2,548
Walworth 1,527
Washington 1,546
Waukesha 4,956
Brown 2,912.681
Dane 5,451.174
Local/collector* 2,382.8
Total 36,305.655
*
This figure represents total local and collector
roads VMTs for all the above counties except
Brown and Dane.
SOURCE: SEWRPC, Milwaukee, Wisconsin
Table C-4 presents potential fuel savings based on a total LDV VMT figure
of 36,305,655, a weighting factor of 0.989 and a fleet mileage rate of 25.622 mpg.
A range of stringency rates is used to illustrate the sensitivity of fuel
savings to this policy variable. A wide range of potential improvement in fuel
economy realized by failed vehicles since the data on this factor has been
inconclusive to date.
LPT 1 Fuel Savings
Table C-5 presents VMTs generated by LDTs in 1987. LDT1 generate
1,744,814 VMT. Table C-6 calculates travel weighting factors which are summed
in Table B-7 resulting in W = 0.9545. Applying the travel weighting factors
to estimated mile per gallon by model year figures results in an LDT1 fleet
mileage figure of 20.571 mpg.
Table B-8 presents LDTl fuel savings based on a 1987 VMT figure of
1,744,814 miles, a weighting factor of 0.953 and an average fleet mileage of
20.571 mpg. Again, several stringency rates and fuel economy improvement levels
are analyzed.
199
-------
TABLE C-2. TRAVEL WEIGHTING FACTOR CALCULATION FOR LIGHT-DUTY VEHICLES
v Vehicle _ *a* .. ,
Year Fraction total
age
registration
1987
1986
1985
1984
1983
1982
1981
1980
1979
1978
1977
1976
1975
1974
1973
Pre-
1973
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16+
0.075
0.107
0.107
0.106
0.100
0.092
0.085
0.077
0.066
0.052
0.039
0.027
0.018
0.014
0.009
0.025
Annual mileage (a) * (b) l(a) * (b)/sumj
n _. 6 travel fraction
accumulation rate
15900
15000
14000
13100
12200
11300
10300
9400
8500
7600
6700
6600
6200
5900
5500
23600
1192.5
1605.0
1498.0
1388.6
1220.0
1039.6
875.5
723.8
561.0
395.2
261.3
178.2
111.6
82.6
49.5
140.7
0.106
0.142
0.133
0.123
0.108
0.092
0.077
0.064
0.050
0.035
0.023
0.015
0.010
0.007
0.004
0.011
SOURCE: Mobile I, EPA; January 1978.
200
-------
TABLE C-3. EPA MPG SPECIFICATIONS AND AVERAGE FLEET MILEAGE
FOR LDVs COVERED BY I/M IN 1987
Year
1987
1986
1985
1984
1983
1982
1981
1980
1979
1978
1977
1976
1975
1974
1973
EPA mileage
standard
27.5
27.5
27.5
27
26
24
22
20
19
18
17.5
16.8
16.0
15.5
15.0
Totals
Travel fraction*
0.106
0.142
0.133
0.123
0.108
0.092
0.077
0.064
0.050
0.035
0.023
0.015
0.010
0.007
0.004
0.989
Column (2) x column (3)
0.989
2.948
3.949
3.698
3.358
2.839
2.233
1.713
1.294
.961
.637
.407
.255
.162
.110
.061
24.622
*From Table C-2
SOURCE: Federal Register, Book 1, Vol. 42, No. 126, p.33534,
Thursday, June 30, 1977.
201
-------
TABLE C-4. POTENTIAL ANNUAL LDV FUEL SAVINGS IN
1987 DUE TO I/M (IN GALLONS)
Increase in fuel
economy realized by
failed vehicles (%)
2
3
4
5
6
7
8
9
10
10
939,146
1,408,719
1,878,292
2,347,865
2,817,438
3,287,011
3,756,584
4,226,157
4,695,730
Stringency
20
1,878,292
2,817,438
3,756,584
4,695,730
5,634,876
6,574,022
7,513,168
8,452,314
9,391,460
level (%)
30
2,817,438
4,226,157
5,634,876
7,043,595
8,452,314
9,861,033
11,269,752
12,678,471
14,087,190
40
3,756,584
5,634,876
7,513,168
9,391,460
11,269,752
13,148,044
15,026,336
16,904,628
18,782,920
202
-------
TABLE C-5. ESTIMATED DAILY LDT VMT FIGURES
FOR SELECTED COUNTIES FOR 1987
Daily vehicle miles
., . travelled
County
LDT 1 LDT 2
Kenosha 93,671 63,391
Milwaukee 393,672 260,703
Ozaukee 45,829 31,215
Racine 103,439 69,680
Walworth 89,883 59,931
Washington 99,081 66,054
Waukesha 245,023 162,765
Brown 206,712 38,016
Dane 370,464 92,616
Local/Collector* 97,040 63,076
Total 1,744,814 907,447
This figure represents total local and
collector road LDT VMTs for all the above
counties except Brown and Dane.
SOURCE: SEWRPC, Milwaukee, Wisconsin and
GCA calculations.
203
-------
TABLE C-6. TRAVEL WEIGHTING FACTOR CALCULATION
LIGHT-DUTY GAS TRUCKS<6000 LBS (LDT 1)
Vehicle
Year
age
1987
1986
1985
1984
1983
1982
1981
1980
1979
1978
1977
1976
1975
1974
1973
pre-
1973
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16+
(a)
Fraction total
registration
0.061
0.095
0.094
0.103
0.083
0.076
0.076
0.063
0.054
0.043
0.036
0.024
0.030
0.028
0.026
0.1
(b)
Annual mileage (a) (b)
accumulation rate
15900
15000
14000
13100
12200
11300
10300
9400
8500
7600
6700
6600
6200
5900
5500
23600
969.9
1425.0
1316.0
1349.3
1012.6
858.8
782.8
592.2
459.0
326.8
241.2
158.4
186.0
165.2
143.0
476.0
Sum = 10462.2
(a) * (b)/sum
Travel fraction
0.0927
0.1362
0.1258
0.1290
0.0968
0.0821
0.0748
0.0566
0.0439
0.0312
0.0231
0.0152
0.0178
0.0158
0.0137
0.047
SOURCE: Mobile I, EPA, January 1978.
204
-------
TABLE C-7. MILEAGE ESTIMATES AND AVERAGE FLEET MILEAGE FOR LDT 1
COVERED BY I/M in 1987
Year Estimated mileage
1987
1986
1985
1984
1983
1982
1981
1980
1979
1978
1977
1976
1975
1974
1973
Total
22.00
22.00
22.00
22.00
21.84
20.64
19.36
18.00
17.50
16.92
16.80
16.47
16.00
15.81
15.6
Travel fraction"^ -
0.0927
0.1362
0.1258
0.129
0.097
0.0821
0.0748
0.0566
0.0439
0.0312
0.0231
0.0152
0.0178
0.0158
0.0137
0.953
:olumn (2) x column (3)
0.953
2 . 140
3.144
2.904
2.978
2.223
1.778
1.520
1.069
0.806
0.554
0.407
0.263
0.299
0.262
0.224
20.571
t.
K
Based on limited LDT 1 mileage figures,
available in the future.
From Table C-6.
More complete data may be
205
-------
TABLE C-8. POTENTIAL ANNUAL LDT 1 FUEL SAVINGS
IN 1987 DUE TO I/M (IN GALLONS)
Increase in fuel
economy realized by
failed vehicles (%)
2
3
4
5
6
7
8
9
10
Stringency level (%)
10
52,056
78,084
104,112
130,141
156,169
182,197
208,225
234,225
260,281
20
104,112
156,169
208,225
260,281
312,337
364,393
416,450
468,506
520,562
30
156,169
234,253
312,337
390,422
468,506
546,590
624,674
702,759
780,843
40
208,225
312,337
416,450
520,562
624,674
728,787
832,899
937,012
1,041,124
206
-------
LPT 2 Fuel Savings
LDT 2 generated VMT in 1987 are estimated in Table C-5 to be 907,447.
Table C-9 calculates travel weighting factors which are summed in Table C-10,
resulting in W = 0.9302. Applying the travel weighting factors to estimated
mile per gallon by model year figures results in an LDT fleet mileage figure
of 17.588 mpg.
Table Oil presents LDT 2 fuel savings based on a 1987 VMT figure of
907,447 miles, a weighting factor of 0.9304 and an average fleet mileage of
17.588 mpg.
SUMMARY FIGURES
Table C-12 presents combined fuel savings for all LDVs and LDTs covered
by an I/M program in selected counties for the year 1987. As a best guess
single estimate, 7,154,769 gallons will be saved if the stringency rate is
20 percent and failed vehicles undergoing repair experience a 7 percent improve-
ment in fuel economy.
If fuel prices increase at 2 percent per year (a conservative estimate)
and the current average price is $0.67 per gallon, a gallon of fuel will cost
$0.80 in 1987. Thus, I/M can potentially save consumers $5,723,800 in fuel costs
in 1987 alone. If 1,727,000 vehicles are covered by the program 518,100 will
fail. These vehicles will realize the fuel economy improvement and hence
receivi the monetary savings resulting from lower fuel consumption rates. The
average failed vehivle will save 13.81 gallons of fuel or $11.05 in 1987.
207
-------
TABLE C-9. TRAVEL WEIGHTING FACTOR CALCULATION LIGHT-DUTY GAS TRUCKS 6001 TO 8500 LB (LDT2)
to
o
co
Year
1987
1986
1985
1984
1983
1982
1981
1980
1979
1978
1977
1976
1975
1974
1973
Vehicle
age
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16+
(a)
Fraction total
registration
0.037
0.070
0.078
0.086
0.075
0.075
0.075
0.068
0.059
0.053
0.044
0.032
0.038
0.036
0.034
0.14
Annual mileage
accumulation rate
15,700
15,700
14,100
12,600
11,300
10,200
9,400
8,600
8,000
7,500
7,100
6,600
6,300
6,000
5,500
23,400
(a)&(b) t
580.9
1099.0
1099.8
1083.6
847.5
765.0
705.0
584.8
472.0
397.5
312.4
211.2
239.4
216.0
187.0
660.8
Sum=9461.9
((a)&(b)/sum)
ravel fraction
0.0614
0.1162
0.1162
0.1145
0.0896
0.0809
0.0745
0.0618
0.0499
0.0420
0.0330
0.0223
0.0253
0.0228
0.0198
0.07
Source: MOBILE1, EPA, January 1978.
-------
TABLE C-10. MILEAGE ESTIMATES AND AVERAGE FLEET MILEAGE FOR
LDT2s COVERED BY I/M IN 1987
*
Year Estimated mileage
1987
1986
1985
1984
1983
1982
1981
1980
1979
1978
1977
1976
1975
1974
1973
20.125
20.196
20.268
19.969
19.297
17.875
16.443
15.000
14.300
13.594
13.262
12.775
12.160
11.780
11.400
Travel fraction
0.0614
0.1162
0.1162
0.1145
0.0896
0.0809
0.0745
0.0618
0.0499
0.0420
0.0330
0.0223
0.0253
0.0228
0.0198
0.9302
Column ( 2) x column (3)
0.9302
1. 328
2.523
2.532
2.458
1.859
1.555
1.317
0.997
0.767
0.614
0.470
0.306
0.331
0.289
0.243
17.588
Based on limited LDT2 mileage figures.
become available in the future.
'"From Table C-9.
More complete data may
209
-------
TABLE Oil. POTENTIAL ANNUAL LDT2 FUEL SAVINGS IN 1987 DUE TO I/M, IN GALLONS
Stringency level, %
Increase in fuel economy
realized by failed vehicle, % -_ ^Q 30 40
2 30,908 61,815 92,723 123,631
3 46,362 92,723 139,085 185,446
4 61,815 123,631 185,446 247,262
5 77,269 154,539 231,808 309,077
6 92,723 185,446 278,170 370,893
7 108,177 216,354 324,531 432,708
8 123,631 247,262 370,893 494,524
9 139,085 278,170 417,254 556,339
10 154,539 309,077 463,616 618,154
TABLE C-12. POTENTIAL ANNUAL FUEL SAVINGS DUE TO I/M IN 1987, IN GALLONS
Increase in fuel economy
realized by failed vehicles, %
2
3
4
5
6
7
8
9
10
Stringency rate, %
10
1,022,110
1,533,165
2,044,219
2,555,270
3,066,325
3,577,385
4,088,440
4,599,495
5,110,550
20
2,044,219
3,066,325
4,088,440
5,110,545
6,132,659
7,154,769
8,176,880
9,198,990
10,221,099
30
3,066,330
4,599,495
6,132,659
7,665,775
9,198,990
10,732,154
12,265,319
13,798,479
15,331,649
40
4,088,440
6,132,659
8,176,880
10,221,099
12,265,319
14,309,539
16,353,759
18,397,979
20,442,198
210
-------
APPENDIX D
INTRODUCTION
Due to the harsh northern climate, some problems arise with respect to
winter operation of centralized test facilities in Wisconsin. The average
daily minimum temperature in Madison during the period from December to March,
for example, is 16.5°F; and in addition, over 45 inches of snow accumulates
there annually.1 Unless properly planned for, facility operation under these
conditions could cause equipment damages, inaccurate test results, and might
even pose serious health and safety problems.
Several commonly experienced problems associated with winter operation of
high volume emissions inspection facilities are presented here with possible
mitigating measures to consider in dealing with these problems.
PROBLEMS ASSOCIATED WITH WINTER EMISSIONS TESTING
Low Temperatures
In 1974, a panel established by the National Academy of Sciences,
Committee on Motor Vehicle Emissions reported that, "ambient temperature vari-
ations, commonly encountered in large sections of the nation during winter,
can significantly increase exhaust emissions of hydrocarbons and carbonmonoxide
above the emissions measured during the course of the CVS-CH(FTP) test."2 The
problem recognized here is that during initial startup, the engine requires
the carburetor to provide a rich air:fuel mixture to assure a combustible
mixture. This very rich mixture, as high as 1:1, is obtained by the engagement
of a choke valve. During warmup, the engine still requires a rich mixture,
but the degree of richness must be progressively reduced during the warmup
period. Eventually, the engine runs satisfactorily with the normal steady-
running fuel-air ratios.3
The initial stage of vehicle operation when engine and coolant temperatures
have not stabilized is referred to as cold mode operation. With cooler temper-
atures, the length of the cold mode cycle increases; the additional period of
time, however, is slight. After a vehicle has "soaked" overnight (8.5 hours)
for example, it would be in cold mode operation for 6.7 minutes at 75°F while
the same vehicle would be in cold mode operation for 7.0 minutes at 20°F.lt
This indicates that the percent of vehicles arriving at the inspection facility
while operating in the cold mode would be greater in the winter, though very
slightly. Cold mode operation is, however, characterized by very high emis-
sion rates of carbon monoxide and hydrocarbons relative to stabilized operation.5
211
-------
Another problem concerning winter temperatures has to do with the steep
temperature differential between ambient conditions within the test and the
outside air. Even the more sophisticated emission analyzers, undergoing fre-
quent quality control checks to minimize analyzer, sampling system, and cali-
bration error, while performing vehicle replication tests, can show under
varying ambient conditions total variability many times greater than the equip-
ment test variability.^ Frequent opening of inspection facility doors will
result in temperature variations within the inspection lane over time. A
common energy saving measure of lowering the thermostat at night might also
result in problems, especially if the analyzer is only calibrated daily.
Vehicles tested later in the day, when the lane has been heated up to more
comfortable temperatures will receive erroneous results.
It is likely that at certain times, especially at the end of the month
if inspector deadlines are set then, vehicles may encounter delays at the
inspection facilities and thus be forced to idle for lengthy periods in the
cold. The result of such a waiting period is a significant increase in tail-
pipe moisture. Again, if not properly planned for, this will effect test
results. Moisture from the tailpipe can find its way into the sampling line
and cause "hydrocarbon hangup" making erroneous not only that vehicle's test
data, but altering subsequent samplings as well.
One obvious safety problem associated with cold weather operation is the
possibility that in a test lane, when doors are closed, the ambient concen-
tration of carbon monoxide could reach unsafe levels making working conditions
dangerous.
Snow
Wisconsin, not unlike other northern states, will have to face additional
winter operation challenges with respect to snow accumulations. The major
impacts of snow-related problems concern safety, equipment damage, and con-
sumer convenience.
Studded snow tires pose a serious problem when a loaded-mode test is
employed. Most conventional dynamometers will be severly damaged by frequent
use with studded tires, as the steel rollers will be worn out quickly by the
friction caused by the metal studs. In addition, a stud could come loose
while the wheels are spinning on the dynamometer and be projected at high
speed in an unpredictable fashion posing a serious safety problem.
Another snow-related safety problem occurs when vehicles arrive at the
test lane covered with snow. Melting snow will result in slippery, wet floors
posing yet another threat to the safety of those in the lanes.
Snow can also pose a consumer convenience problem; motorists may encounter
delays or even the cancellation of testing operations while queuing areas are
plowed.
212
-------
Seasonal Variations in Gasoline
i
The saturated compounds in gasoline from area refineries can vary by as
much as 20 percent. Yet, the infrared analytical equipment commonly used in
emissions testing responds disproportionately to the relatively unreactive
saturated compounds and the reactive aromatics and olefins.7 In addition,
changing temperatures significantly effect the Reid Vapor Pressure (RVP) of
gasoline seasonally.8 These variables interacting with the temperature and
humidity changes, has been shown, under some circumstances, to accentuate
air/fuel mixture excursions well beyond normal. Taken collectively, testing
errors can be highly significant when considering these field test variables.
MITIGATING MEASURES
Impact of many of the problems discussed in Section 2 may be minimized
through proper planning, test procedures, and equipment.
By employing the loaded-test mode, problems associated with cold mode
operation may be minimized. Performing the high and low cruise components of
the test before the idle portion serves as a preconditioning method to normalize
engine temperatures and thus, the idle emission readings. Not only will this
minimize winter problems of cold mode operation, it will achieve the same
results when dealing with extremely hot summer temperatures as well.
Aside from reducing waiting times by the availability of additional lanes,
one solution to the tailpipe moisture problems is to heat sample lines, thus
minimizing hydrocarbon hangup problems.
To alleviate problems with temperature fluctuations, test facilities
should be equipped with analyzers that are self-contained in well-insulated,
heated/air-conditioned cabinets. During winter and summer months, the analyzers
should be recalibrated every few hours.
To assure against unsafe carbon monoxide levels in the test lanes, fresh
air circulatory systems should be utilized, and ambient CO monitors provided
as warning devices.
In anticipation of possible snowplowing delays, registration expirations
should be staggered in such a way that fewer vehicles would have to be tested
during the winter. Extended hours of operation should be offered on days fol-
lowing snow delays.
Since vehicles registered in Wisconsin are currently prohibited from using
studded snow tires, the associated safety and equipment problems will be avoided.
Motorists should be advised, however, that chains must be removed before the
vehicle can be tested. Should the state rescind prohibition of studded tires,
dynamometers with specially treated rolls are capable of withstanding studded
tires, but are, of course, more expensive.
To account for other seasonal variabilities in operating conditions and
fuels, different standards or tolerances may be applied either seasonally or
when adverse ambient conditions exist.
213
-------
REFERENCES
1. U.S. National Oceanic and Atmospheric Administration, Comparitive
Climatic Data, 1977.
2. Andreatch, A. J. and J. C. Elston. Evaluation of Idle Inspection and
Maintenance Equipment Network. SAE paper 740134. (Presented at Auto-
motive Engineering Congress.) Detroit, Michigan. February 1974.
3. Patterson, D. J. and N. A. Henein. Emissions from Combustion Engines and
Their Control. Ann Arbor Science Publishers, Inc. Ann Arbor, Michigan.
1974.
4. Midurski, T. P. and A. H. Castaline. Determination of Percentages of
Vehicles Operating in the Cold Start Mode. GCA Corporation, GCA/Technology
Division, Bedford, Massachusetts. Prepared for U.S. Environmental Pro-
tection Agency, Research Triangle Park, North Carolina. Contract No.
68-02-1376, Task Order 29, August 1977.
5. Ibid.
6. Elston, J. Auto Emission Inspection Test Variability. (Presented at the
70th Annual Meeting of the Air Pollution Control Association.) Toronto,
Canada. June 1977.
7. Ibid.
8. Patterson, D. J. and N. A. Henein. op. cit.
9. Elston, J. op. cit.
214
-------
TECHNICAL REPORT DATA .
(Please read Instructions on the reverse before completing)
RLPORT NO.
EPA-905/2-78-004
riTLl AND SUBTITLE
Evaluation of Motor Vehicle Emissions Inspection and
Maintenance Programs in Wisconsin - Phase 3
3. RECIPIENT'S
5. REPORT DATE
November 1978
6. PERFORMING ORGANIZATION CODE
AUTHORIS) Theodore P. Midurski, Lee A. Coda, Robert 0.
Phillips, Nancy K. Roy, Frederick M. Sellars, Thomas P.
Snyder, Donna L. Vlasak
8. PERFORMING ORGANIZATION
GCA-TR-78-38-G
3. PERFORMING ORGANIZATION NAME AND ADDRESS
GCA Corporation
GCA/Technology Division
Burlington Road
Bedford, Massachusetts 01730
1?. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
Region V Office
Chicago, Illinois
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-02-2607, TO No. 20
13. TYPE OF REPORT AND PERIOD COVERED
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
Recent data for the State of Wisconsin indicates that the National Ambient Air Quality
Standards for CO and Ox will not be attained in all areas of the state by 1982, even
if all reasonably available control technologies are applied. In view of this, it is
likely that the state will request from EPA an extension of the compliance date beyond
1982. In order for this request to be considered, the state must, among other things,
have adopted a firm schedule for implementing a motor vehicle inspection and mainte-
nance (I/M) program in the highly urbanized nonattainment areas. In this connection,
the State of Wisconsin is currently planning for the implementation of an I/M program.
As part of this effort, detailed analyses have been performed of the costs, benefits,
personnel requirements, direct and indirect impacts, and scheduling requirements asso-
ciated with the particular program option being considered. This document reports
these analyses.
KEY WORDS AND DOCUMENT ANALYSIS
i DESCRIPTORS
Automobile engines
Exhaust detection
Exhaust emissions
1S DISTRIBUTION STATEMENT
Unlimited distribution
b.lDENTIFIERS/OPEN ENDED TERMS
Automobile emissions
Inspection/Maintenance
Mobile source control
19.
UNCLASSIFIED f;
UNCLASSIFIED
' *
c. COSATI Field/Group
21. PRICE'.
EPA Form 2220-1 (9-73)
215
------- |