EPA-905/2-79-005
U.S. ENVIRONMENTAL PROTECTION AGENCY
Region V Office
Chicago, Illinois
Contract No. 68-02-2887
Work Assignment No. 7
December 1979
COMPARISON OF PARAMETER AND
EXHAUST TESTING APPROACHES FOR
A VEHICLE EMISSIONS INSPECTION
AND MAINTENANCE PROGRAM IN
MICHIGAN
Final Peport
Prepared by
Theodore P. Midurski
Frederick Sellars
U.S. Environmental Protection Agency
Region 5, Library (PL-12J)
77 West Jackson Boulevard, 12th Floor
Chicago, it 60604-3590
GCA CORPORATION
GCA/TECHNOLOGY DIVISION
Bedford, Massachusetts
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DISCLAIMER
This Final Report was prepared for the Environmental Protection Agency
hy CCA Corporation, OCA/Technology Division, Burlington Road, Bedford
Massachusetts 01730, in fulfillment of Contract No. 68-02-2887, Task Order
No. 7. The opinions, findings, and conclusions expressed are those of the
authors and not necessarily those of the Environmental Protection Agency.
Mention of company or product names is not to be considered as an endorsement
by the Environmental Protection Agency.
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ABSTRACT
The Michigan Department of State Highways and Transportation is in the
process of developing a motor vehicle emissions inspection and maintenance (l/M)
program for implementation in various nonattainment areas of the State. To date,
the effort has focused on identifying and assessing the various program alter-
natives available that satisfy the objectives of I/M. A primary issue at this
point concerns whether the program should use the emissions measurement concept,
or a concept involving parameter inspection.
Assessments of the specific requirements related to implementing I/M in
Michigan, including a first level assessment of alternative program approaches,
have been developed as part of this initial planning. Based on these initial
assessments, the need for a more detailed assessment of the parameter inspec-
tion concept was identified.
These detailed analyses of issues related to the parameter inspection
concept were performed by GCA/Technology Division, under a contract with the
U.S. Environmental Protection Agency. These analyses considered the emissions
reduction potential, costs, consumer and repair industry impacts, and administra-
tion requirements of four parameter inspection concepts. The results of these
analyses are reported here.
111
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CONTENTS
Abstract
Figures
Tables v
Acknowledgements X1
1. Introduction 1
Background 1
Program objectives 2
Overview of I/M programs 2
Report organization 3
2. Technical Considerations 5
Introduction 5
Derivation of concepts 6
Program requirements associated with parameter
inspection 6
Technical aspects of the high option 12
Technical aspects of the low option 25
3. Potential Effectiveness in Reducing Motor Vehicle
Emissions 28
Introduction 28
Potential for reducing emissions 28
Summary 53
4. Consumer Issues 55
Introduction 55
Program cost 55
Consumer convenience 56
Conflict of interest 58
Consumer protection 58
5. Impacts on the Automotive Repair Industry 64
Introduction 64
Demand for mechanics 64
Distribution of I/M created workload 65
Mechanics training requirements 66
Licensing or certification of repair shops and
mechanics 68
Quality assurance 68
6. Program Administration Requirements 73
Introduction 73
State personnel 73
Contractor personnel 76
7. Cost Analysis 78
Introduction 78
Decentralized approach 78
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CONTENTS (continued)
Centralized approach 84
Cost sensitivity analysis 103
8. Responding to Future Emissions Control Technology 107
Introduction 107
Implications of future technology 107
Control requirements for additional pollutants 108
9. Summary 110
Introduction 110
Overview of program concepts considered 110
Relative effectiveness in reducing emissions 113
Program costs 115
Other related impacts 116
References 120
Appendices
A. Diagrams showing various carburetor inspection and
adjustment procedures for the high option 122
B. Glossary 136
VI
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FIGURES
Number Page
1 Propane enrichment device 16
2 General representation of the impact of spark timing on fuel
economy and emission 32
3 Typical administrative structure 74
4 Generalized relationship between participation rate, R, and
costs and revenue associated with providing inspection
service 80
5 Conceptural floor plan — centralized facility for high option
parameter inspection program 87
6 Conceptual floor plan — centralized facility for the low
option parameter inspection program 88
7 Functional comparison of engine testing equipment 90
8 Cost comparison of engine/electrical test equipment 91
vn
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TABLES
Number Page
1 Inspection Parameters Considered in the High-Option
Scenario for the Michigan I/M Program , . . . 7
2 Inspection Parameters Considered in the Low-Option
Scenario for the Michigan I/M Program 8
3 Procedure for Ignition System Inspection 18
4 Impact of Maladjustment or Malfunction of Various Engine
Components on Emissions of CO, HC, and NOX 30
5 Impact of Maladjustment or Malperformance of Emissions
Control Components on HC, CO, and NOX Emissions 33
6 Engine Parameters and Emissions Control Systems Considered
in the EPA Restorative Maintenance Program 35
7 Observed Failure Rate for Major Systems and Parameters by
Manufacturer 37
8 Effects of Certain Engine Parameter Maladjustments on FTP
Emissions 38
9 Percentages of Vehicles Passing and Failing FTP for CO and
HC with Idle CO Parameter In and Out of Assumed
Specifications 39
10 Percentage of Vehicles in a 300-Car Sample with Various
Deficiencies Related to Emissions-Critical Components
and Systems 40
11 Major System Failure Rate for Vehicles that Did Not Pass
the Initial FTP Emissions Test 42
12 Frequency of Deficiencies in Specific Engine Parameters and
Components for Vehicles Taking the Initial FTP
Emissions 42
13 Pass/Fail Rates for the Four FTP Tests by Pollutant for
Individual Tests 44
Vlll
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TABLES (continued)
Number Page
14 Pass/Fail Rates for the Four FTP Tests by Pollutant for
the 300-Vehicle Sample 44
15 Comparison of Mean FTP Emissions Rates Before and After
Maintenance Routines 45
16 Repairs Required for 201 Vehicles Failing the Portland
I/M Standards 46
17 FTP Emissions Reductions From Failed Vehicles Undergoing
Maintenance for the Portland I/M - 1975 through 1977
Vehciles Only 47
18 Repair Costs Experienced in the Portland I/M Program ... 47
19 California Blue Shield Emissions Inspection Procedures . . 48
20 Summary of Inspection and Repair Activities of Private
Garages 50
21 Estimates of Emissions Reductions for Various I/M Programs
in California 51
22 Inspection Time Requirements 57
23 Distribution of I/M-Related Repair Work — Portland,
Oregon 65
24 Summary of Inspection Task Time — High Option 82
25 Summary of Inspection Task Time — Low Option 83
26 Cost Categories Considered in the Analysis of Centralized
Parameter Inspection Program 84
27 Equipment Requirements for Two Types of Centralized Para-
meter Inspection Facilities 91
28 Summary of Capital Costs for an Inspection Facility ... 92
29 Operational Personnel Salaries During Program Start-Up . . 94
30 Summary of Initial Start-Up Costs for a 38-Bay Inspection
Facility, and a 20-Bay Inspection Facility 95
31 Annual Personnel Costs - Operational Personnel 96
IX
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TABLES (continued)
Number Page
32 Summary of Annual Operating Costs for a 38-Bay Inspection
Facility and a 20-Bay Inspection Facility 97
33 Annual Administrative Personnel Costs — High and Low
Options 98
34 Cost Summary for a 38-Bay and a 20-Bay Inspection Facility . 100
35 Annualized Costs in Constant 1979 Dollars for a 38-Bay
Centralized Parameter Inspection Station for the High
Option 102
36 Annualized Costs in Constant 1979 Dollars for a 20-Bay
Centralized Parameter Inspection Station for the Low . . . 102
37 Cost Changes for a 38-Bay Centralized Inspection Facility
Associated with a 1-Hour Reduction in the Test Time
for the High Option 104
38 Cost Changes for a 20-Bay Centralized Inspection Facility
Associated with a 15-Minute Reduction in the Test Time
for the Low Option 105
39 Summary of Inspection Fee Estimates 106
x
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ACKNOWLEDGEMENTS
The authors wish to acknowledge the contributions of several individuals
and organizations to the study effort reported in this document. Much valuable
technical information and insight regarding various viewpoints on inspection
and maintenance concepts were obtained from the Environmental Activities Staff
of General Motors Corporation, and the I/M Technical Staff of the U.S. Environ-
mental Protection Agency's Office of Mobile Source Air Pollution Control. We
are particularly indepted to Ms. Susan Mortel of the Bureau of Transportation
Planning, Michigan Department of State Highways and Transportation, who served
as the State's coordinator throughout the program. Finally, we wish to acknowl-
edge the efforts of Mr. Gary Culezian and Mr. Carlton Nash of the U.S. Environ-
mental Protection Agency's Region V Office, who provided general direction
during the study.
XI
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SECTION 1
INTRODUCTION
BACKGROUND
Tn response to requirements set forth in the Clean Air Act Amendments of
1977 regarding expected nonattainment of air quality standards by the 1982
compliance date, the State of Michigan, through its Department of State High-
ways and Transportation, is currently involved in the early stages of planning
a motor vehicle emissions inspection and maintenance (I/M) program. To date
there has been a substantial amount of information published concerning most
aspects of T/M programs. Generally, this information focuses on programs that
involve measuring tailpipe emissions and comparing the measured concentrations
of carbon monoxide and hydrocarbons to standards that reflect the particular
emissions control technology used on the tested vehicle. If the emissions
concentrations exceed the standards, then some form of adjustment or repair is
required. This type of approach is being considered in Michigan,
Several alternatives are also being considered that involve a somewhat
different approach in that the emphasis is on individual engine parameters
rather than on emissions only. This approach is referred to as parameter in-
spection. Relatively little data exist regarding this approach to I/M, par-
ticularly in terms of direct comparisons with the tailpipe measurement approach.
The decision as to which type of program to implement must be based on
the evaluation of a variety of factors such as program cost, emissions reduc-
tions achievable, indirect impacts on affected consumers, enforceability, and
others. At the present time there appears to be little doubt that both pro-
grams represent a viable approach to I/M in terms of effecting desired reduc-
tions In the emissions levels of in-use vehicles. To the extent that the two
program types can be considered equivalent from the standpoint of emissions
benefits, the other factors such as cost, consumer impacts, enforceability,
etc. become more important in the overall process of program selection. A
necessary step In the T/M planning process is to consider these issues in rela-
tive terms for each basic type of program under consideration.
Initial analyses of T/M program issues and requirements for the State of
Michigan were recently performed by a consultant under an EPA-sponsored con-
tract.1 These analyses considered several specific program scenarios in terms
of costs, emissions reduction potential, and secondary impacts, and serve as
the basis for comparing the impacts of tailpipe measurement programs with the
program approaches considered in this document.
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PROGRAM OBJECTIVES
At this point in the planning urocess a decision has not yet been made
regarding the basic type of program (i.e., tailpipe measurement or parameter
inspection) to be adopted. One obstacle to reaching this decision point is
the lack of a clear definition of the implications of selecting one program
format over the other, in terms of costs, consumer acceptance, effectiveness
in reducing automotive emissions, and other impacts. The specific purpose of
this document is to assess the relative impacts associated with the two tvpes
of programs and also consider a range of options within each program type.
Given that specific program scenarios have not yet been specified, this assess-
ment is most appropriately presented as a discussion of a particular set of
issues common to both the parameter inspection and the tailpipe measurement
concepts. Further, the emphasis is on defining the relative implications of
the two programs rather than considering absolute impacts. Since this effort
considers a set of general program concepts, questions that are answered here
are also somewhat general in nature: undoubtedly, a different set of more
specific questions will evolve once a particular program option or set of op-
tions has been defined.
OVERVIEW OF T/M PROGRAMS
Beginning with 1968 model-year vehicles, automobiles manufactured in or
imported into the U.S. have had to comply with emissions standards specified
in the Federal Motor Vehicle Emission Control Program (FMVECP). Under this
program maximum emissions rates are specified for new vehicles, and manufac-
turers must demonstrate that their vehicles are in compliance with these emis-
sions limits. The emissions standards require progressively more stringent
control with each subsequent model year. Ultimately, the standards will re-
quire that new vehicles achieve a 90-percent reduction in carbon monoxide and
hydrocarbon emissions compared with baseline emissions rates that reflect the
1970 model-year vehicle fleet.
To comp]y with the emission standards, manufacturers have retained their
existing engine design concepts, but developed emission control devices (crank
rase ventilation control, catalytic converters, etc.) and revised certain
system parameter specifications (air-to-fuel ratio, ignition timing, etc.).
This approach to emission control ostensibly satisfies the requirements of
the FMVECP for new vehicles.
With regard to emissions control in the near-term future, it appears that
extensive use will be made of electronic parameter controls that will contin-
uously adjust emissions-critical parameters according to the operating charac-
teristics of the vehicle. Also, continued use will be made of exhaust treat-
ment devices, primarily improved catalysts and air injection. Manufacturers
nre attempting to design engine components that have limited adjustment ranges
in order to reduce the potential impacts of maladjusted parameters and
tampering.
Several studies conducted by the U.S. Environmental Protection Agency have
demonstrated that in-use vehicles generally emit both carbon monoxide and
hydrocarbons at much higher rates than is expected, given the control technology
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applied. These same studies have shown that the primary reasons for the high
emissions rates include improper or inadequate maintenance, and tampering with
either the control 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.
Tn 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, adjustment, or repair is indicated. This is a very sim-
plistic explanation of I/M, but it does serve to define the basic concept
Involved.
The most widely discussed format for I/M programs involves the tailpipe
measurement concept. The primary characteristic of this type of program is
that the vehicle either passes or fails the inspection as a result of the
levels of carbon monoxide and hydrocarbons measured in the exhaust stream.
Failure generally means that the motorist has to have some form of maintenance
performed on the vehicle and then return to the inspection station for a re-
test. Generally, the exact nature of the repairs required is not specified
by the inspection results.
Since the overall intent of I/M is to promote better maintenance of in-
use vehicles, a more direct approach to this end has been suggested. This
approach Involves requiring all vehicles to undergo inspection and adjustment
of specific components and systems that affect emissions. This concept is
referred to as either parameter or functional Inspection. The primary charac-
teristic of the parameter inspection concept is that it provides a direct tie
between the inspection and maintenance phases. These types of programs are
also being considered for implementation in the State of Michigan and are the
primary focus of this document.
REPORT ORGANIZATION
Beyond this introductory discussion, the report is organized into six ad-
ditional major sections. Section 2 provides a detailed explanation of the two
specific parameter inspection concepts that have been suggested as viable
nlternatlves to the tailpipe measurement approach to I/M. Specifically, this
section considers the actual inspection requirements in terms of the systems
nnd Individual components to be inspected, the inspection procedures, and the
requirements in terms of time, special equipment and expertise. Following
this description of inspection methods and requirements is Section 3, which
provides an overview of Issues related to the effectiveness of the parameter
Inspection concept. Tn discussing effectiveness, issues such as emissions
reductions, the expected frequency of failures in various components and sys-
tems, and the relationship between the program success and the ability of the
Inspectors and repair Industry to perform satisfactorily are considered.
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Section A provides a discussion of issues concerning the relative impacts of
various types of I/M approaches on consumers. Of particular concern are issues
related to protecting the consumer from possible abuse in terms of repair work
resulting from the inspections, and also warranty protection afforded through
Section 207 of the Clean Air Act Amendments. Section 5 provides a discussion
of the potential impacts of I/M on the repair industry. Considered are issues
such as training requirements, surveillance and control recmirements, and pos-
sible shifts in the job market resulting from the implementation of an I/M
program. A general discussion of the special administrative requirements im-
posed by the different approaches is provided in Section 6, while cost anal-
yses for each type of program are presented in Section 7. Section 8 discusses
issues related to future emissions control technology, and how this will affect
I/M program requirements. Finally, a summary of the various analyses is pre-
sented in Section 9. Two appendices are provided. Appendix A is a technical
presentation that supports the discussion in Section 2. Appendix B is a
glossary of terminology used in connection with I/M.
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SECTION 2
TECHNICAL CONSIDERATIONS
INTRODUCTION
The complete definition of a particular I/M program describes several
different elements that relate to the inspection procedures, administration,
failure rate, geographic coverage, support programs, affected vehicles, and
others. The immediate objective with regard to I/M planning in the State of
Michigan is to select the basic format that the program will utilize, in terms
of the type of inspection to be used (i.e., parameter or tailpipe measurement),
and where the inspections will be performed (i.e., private garages or cen-
tralized inspection facilities).
The decisions regarding test procedures and test location will have a
direct Impact on other elements of the program. An estimate of these relative
impacts will provide a useful function in the process of selecting a general
program format. The objective of this document is to provide an initial as-
sessment of several general parameter inspection scenarios with regard to pro-
gram cost, consumer protection and acceptance, the repair industry, emissions
reduction achievable, the overall administrative requirements, and several
indirect impacts. This assessment along with Reference 1 will serve as basic
technical support documents for State decision makers responsible for the
development of an I/M program in Michigan.
Of primary concern here are four general types of parameter inspection
programs that have been proposed for implementation in the State; these
include:
• centralized, high option;
• centralized, low option;
• decentralized, high option; and
• decentralized, low option.
In a general sense, the "high options" and "low options" listed above refer to
the intensity of the inspection process. More complete definitions of the
options are provided in subsequent paragraphs.
The purpose here is to consider the relative impacts of each of the four
parameter inspection concepts both with respect to one another, and with re-
spect to tailpipe measurement programs. Since the overall planning effort in
the State is not at the point where specific program options have been chosen,
the analyses reported here consider general formats that more or less reflect
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the extremes in the range of possibilities for parameter inspection programs.
This being the case, the reader is cautioned that the options discussed in this
document are not necessarily those that will be given detailed considerations
in subsequent analyses. The intent here is to consider concepts rather than
specific program scenarios.
DERIVATION OF CONCEPTS
The four parameter inspection concepts under analysis here were suggested
by the Michigan Department of Transportation as those that, in a general sense,
would be considered for implementation in the State. The specific concepts
were developed by other sources as is indicated below.
At this point each of the four concepts can be discussed in terms of being
either a high option or a low option. The high option, whether it is central-
ized or decentralized, involves a process whereby essentially all engine com-
ponents, systems, and subsystems that have either a direct or indirect effect
on emissions are evaluated by an inspector to ensure that the component, system,
or subsystem is functioning or adjusted according to the manufacturer's speci-
fications. Depending on the particular policies established, repairs and ad-
justments may or may not be performed as part of the inspection process. The
low option, on the other hand, involves an inspection of a relatively limited
number of engine parameters or components to ensure that they are operating or
adjusted properly. The specific parameters are generally those that tend to
require repair or adjustment most frequently and also have a significant impact
on the emission characteristics of the vehicle.
The parameters Inspected under the high option were specified by a con-
sultant working for the State on the development of I/M programs options.2
These parameters are listed in Table 1. The inspection parameters for the
low option were recommended by a major auto manufacturer^ based on the analysis
of preliminary data developed by the U.S. Environmental Protection Agency (EPA)
regarding restorative maintenance of in-use vehicles.** The parameters included
In the low option are listed in Table 2.
From the standpoint that neither option requires unusually expensive,
special purpose test equipment or an extraordinarily large floor area in order
to perform the Inspection, either the private garage or centralized approach
can be considered appropriate for both options at this point.
PROGRAM REOUTREMENTS ASSOCIATED WITH PARAMETER INSPECTION
Before discussing each option in detail, a general overview of the param-
eter inspection concept is in order. As indicated previously, four general
parameter Inspection formats are considered in this report. It is emphasized,
however, that these represent examples of how parameter inspection can be used
In an T/M program. Many other scenarios are possible although, in terms of
Inspection Intensity, these would probably reflect some point bounded by the
high and low options being considered here.
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TABLE 1. INSPECTION PARAMETERS CONSIDERED IN THE HIGH-OPTION
SCENARIO FOR THE MICHIGAN I/M PROGRAM
Parameter
Component
Carburetor system
Ignition system
Thermal air inlet
Heat riser
PVC components
EGR components
EVAP components
Air injection system
Spark delay system
Three-way catalyst
Reduction catalyst
Oxidation catalyst
Choke
Metering rod
Power valve
Idle adjustment
Float and valve
Vacuum break valve
Spark plugs
Timing
Wires
Distributor cap
Rotor
Vacuum advance
Magnetic trigger (electronic ignition)
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TABLE 2, INSPECTION PARAMETERS CONSIDERED IN THE LOW-OPTION
SCENARIO FOR THE MICHIGAN I/M PROGRAM
Parameter Procedure
Visual inspection Check for obvious disconnects or
tampering
Fuel filler inspection Check for modifications to or removal
of filler neck restrictor
Catalytic converter Visual inspection for presence and
general condition of converter
EGR check Determine that EGR valve responds
appropriately
Idle air-to-fuel ratio Use manufacturer's recommended method
to check and/or adjust air/fuel
mixture
All T/M programs are established through a legislative process that gen-
erally defines which vehicles are to be inspected, which vehicles are exempt
from the program requirements, the basis for granting waivers, the inspection
frequency, the stringency of the program (often expressed in terms of an allow-
able failure rate), where the inspections will be performed, how the tests will
be performed, etc., and also defines the responsibilities of various agencies
in the operation and administration of the program. Actual legislation can
(and does) vary widely from state to state regarding what is actually speci-
fied. The only requirement by EPA is that the legislation provides adequate
legal authority to implement an acceptable I/M program. The specific nature
of a state's enabling legislation may not be affected by the type (i.e., param-
eter or tailpipe Inspection) of program selected.
Since most I/M programs are being implemented in response to requirements
set forth in the Clean Air Act Amendments of 1977, the actual design of the
programs will necessarily be strongly influenced by specific requirements de-
llneated in the Amendments or defined otherwise by EPA policy. Of primary
concern here are the requirements specified by EPA policy. These requirements
pertain to Implementation deadlines, geographic coverage, minimum emissions
reduction achievable, and basic program format, and are presented in a memo-
randum'' from David G. Hawkins, Assistant Administrator for Air and Waste
Management.
With regard to implementation deadlines EPA policy requires the centralized
programs to be implemented by 31 December 1981 while decentralized programs
must be implemented by 31 December 1980. Under certain circumstances EPA may
grant an extension of the implementation date but not beyond 31 December 1982.
The primary concern is that the program be implemented as expeditiously as
practical. Based on the guidance provided by EPA, it can be assumed that the
only factors affecting the final, mandatory implementation of an I/M program
nre:
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• ability to enact appropriate legislation;
9 whether the centralized or decentralized approach is utilized;
• if the selected program is centralized, whether it is being
added to an existing inspection program (e.g., safety inspec-
tion) ; and
• possible additional factors that would enable the program to be
implemented before the final compliance date.
It can be assumed that regardless of whether the program selected for
implementation in Michigan is based on the parameter or tailpipe inspection
approach, the latest date for implementation that would meet EPA criteria is
31 December 1982. This is not to say that the type of inspection program
selected will not affect the actual implementation date since it is quite
likely that there would be a difference in the time required to prepare for
the implementation, therefore affecting the "earliest" practical implementa-
tion date.
Geographic coverage requirements specify the minimum area to be covered
by the I/M program. Specifically, EPA policy requires that all nonattainment
areas whose urban population is 200,000 or more must implement an I/M program
in the urbanized and fringe areas. Also, EPA reserves the right to consider
separately nonattainment areas with populations less than 200,000 to determine
whether I/M ought to be implemented. While there are no specific requirements
regarding geographic coverage that will affect or be affected by the type of
program selected, there is a relationship between the actual geographic cover-
age and the type of program selected based on practicality. Generally, the
use of centralized inspection facilities is limited to the more densely de-
veloped areas whereas both rural or semirural areas and urban areas can ef-
fectively be served by decentralized facilities. The specific geographic
coverage may influence the type of inspection process selected, as well. For
instance, it may be necessary to minimize the level of sophistication in the
testing procedure if very large rural areas are included in the program, be-
cause of the likelihood that many rural inspection facilities would not ex-
perience sufficient demand to warrant a highly trained specialist. Further,
a more sophisticated inspection process generally means that the quality as-
surance effort will necessarily increase substantially, which will increase
the program's cost.
EPA guidance also applies to the expected effectiveness of I/M programs.
Specifically, programs should be designed to achieve at least a 25 percent
reduction in exhaust hydrocarbon and carbon monoxide emissions from light-duty
vehicles by 1987, compared with the emissions that would have been produced by
these vehicles in 1987 without an I/M program. EPA has developed and pub-
lished6*7 a standard methodology for computing estimates of emissions reduc-
tions likely to occur as a result of I/M. These methodologies apply specif-
ically to programs that utilize the tailpipe measurement approach, and there-
fore are not appliable to parameter inspection. Paragraph 3(d) of Reference 6,
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which addresses alternative approaches to I/M,* states that "... approaches
other than those using an emissions test ... will be acceptable only if suffi-
cient data are provided to justify the emissions reduction claimed." Depending
on the exact nature of the substantiation required, any state proposing an alter-
native approach could be faced with a rather formidable task in supporting its
estimates of emissions reduction. It is noted that a pilot study of the ef-
fectiveness of an alternative I/M approach proposed by the State of Texas is
being planned. This study, which is being sponsored in part by EPA, will re-
quire a significant effort over a period of approximately 1 year. A more de-
tailed discussion of the study is provided later, but the point here is that
the effort required to evaluate the effectiveness of an alternative approach
is significant.
EPA has also defined several requirements for I/M programs in addition to
those mentioned above. Reference 5 states that all I/M programs must:
• include regular, periodic inspections for all vehicles for
which emission reduction credits are claimed;
• require maintenance and retesting of vehicles that fail the
emissions test;
• enforce the program by denying registration, or some equally
effective method, to prevent vehicles that fail the inspec-
tion from operating on public roads;
• establish quality control regulations and procedures for the
inspection system that assure the adequacy of test equipment,
require calibration of analyzers, and provide for a specific
records keeping procedure;
• provide for either a mechanics training program, or a program
to inform the public of repair facilities that have approved
emissions analyzers; and
• provide a public information program that will explain the need
for nnd concept of I/M, and identify where inspections can be
obtained and the operating hours of the inspection facilities.
EPA also lias established additional requirements that apply specifically to
programs utilizing the decentralized approach; these requirements are that:
*Alternative approaches to I/M imply any approach that does not involve emis-
sions testing to Identify vehicles that pass or fail the inspection.
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• All official inspection facilities must be licensed. Pro-
visions for the licensing of inspection facilities must en-
sure that the facility has obtained, prior to licensing,
analytical instrumentation that has been approved for use
by the appropriate state, local, or regional government agency.
A representative of the facility must have received instruc-
tions in the proper use of the instruments and in vehicle
testing methods and must have demonstrated proficiency in
these methods. The facility must agree to maintain records
and to submit to inspection of the facility. The appropriate
government agency must have provisions for penalties for
facilities which fail to follow prescribed procedures and for
misconduct.
• Records required to be maintained should include the descrip-
tion (make, year, license number, etc.) of each vehicle
inspected, and its emissions test results. Records must also
be maintained on the calibration of testing equipment.
• Summaries of these inspection records should be submitted on
a periodic basis to the governing agency for auditing.
• The governing agency should inspect each facility periodically
to check the facilities records, check the calibration of the
testing equipment and observe that proper test procedures are
followed.
• The governing agency should have an effective program of un-
announced/unscheduled inspections both as a routine measure
and as a complaint investigation measure. It is also recom-
mended that such inspections be used to check the correlation
of instrument readings among inspection facilities.
• The governing agency should operate a "referee" station where
vehicle owners may obtain a valid test to compare to a test
from a licensed station. At least one "referee" station must
be present in each I/M metropolitan area.
Although there has not been a direct policy statement issued by EPA, it has
been indicated that a further requirement for any I/M program using the de-
centralized approach is that emissions measurements be included. This require-
ment may be imposed to ensure that repairs or adjustments to vehicles resulting
from the inspection process do, in fact, impart a positive impact on individual
vehicle emissions.
Assuming that a tailpipe measurement task is an absolute requirement, an
argument could be made to use the measurement procedure as a screening device
so that only those vehicles that fail to meet the established emission stan-
dards have to undergo the maintenance routine prescribed by the program. This
approach significantly alters the nature of the program. In fact, it essen-
tially becomes a tailpipe measurement program with the added feature of
11
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mandatory parameter repair. Given the basis for many of the arguments sup-
porting parameter inspection over tailpipe measurement, and considering the
types of repairs routinely required as a result of failing a tailpipe test,
it is not clear that a combined approach would be supported by factions with
a strong preference for one type of program over the other.
In summary, it can be stated that many of the basic requirements imposed
by EPA regarding tailpipe measurement programs apply directly to parameter in-
spection programs, as well. There are several differences that should be of
concern to those contemplating parameter programs. These concern the need for
substantiating estimates of emissions reductions achievable with the parameter
program, and the possible requirement to include emissions measurement as part
of the program in order to receive EPA approval. With regard to basic program
requirements, it appears that most significant differences occur as a function
of whether a centralized or decentralized approach is used rather than whether
parameter inspection or tailpipe measurement is selected.
TECHNTCAI, ASPECTS OF THE HIGH OPTION
General
It is of interest to discuss the technical aspects of the four parameter
inspection concepts under consideration here. The specific topics treated in
this section relate directly to the inspection process in terms of what com-
ponents are inspected, how they are inspected, the possible rationale for in-
specting the components, and an indication of the time and level of expertise
required to perform the inspections.
The technical aspects of the four programs vary only as a function of
whether the high or low option is being considered. The discussion that fol-
lows, therefore, does not involve issues relative to the centralized approach
versus the decentralized approach.
Inspect ion Elements
The basic premise in any parameter inspection concept is that if specific
vehicle components and systems are maintained to design specifications, emis-
sions characteristics, driveability, and performance will be optimized in terms
of achieving the best balance of these attributes. The parameter inspection
concept is maintenance-intensive since the focus is directly on checking, re-
pairing, and adjusting specific components and systems that affect the emis-
sions characteristics of the vehicle. On the other hand, tailpipe measurement
programs may be considered less maintenance-intensive since these programs
focus more directly on vehicle inspections even though the primary objective
is to ensure that maintenance practices are adequate.
The inspection items for the high option were defined by a consultant8
working under contract to the EPA on a program to assist the State of Michigan
with the development of the initial I/M planning effort. The use of the pro-
posed inspection scenario in this effort does not necessarily reflect an en-
dorsement by either the State of Michigan or GCA/Technology Division.
12
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The general inspection scenario for this option requires that all light-
duty vehicles (with some yet-to-be-defined exemptions) undergo th* parameter
inspections and adjustments on an annual basis as outlined in Table 1. The
requirement is for all affected vehicles to undergo the complete maintenance
cycle; there is no screening performed to identify only those vehicles that
actually may need maintenance work performed.
The inspection process proposed for this option involves very detailed
inspection and adjustment of the carburetor and ignition system as well as both
visual and functional inspections of specific emissions control devices. It is
of interest to consider the individual inspection elements.
Carburetor System—
The proposed inspection requires that the choke and metering rods be ad-
justed, and that various visual inspections be made of the power valve, float,
and vacuum break valve. Idle speed and the air-to-fuel ratio (A/F) are to be
adjusted. In order to determine the time, equipment, and level of expertise
required, discussions were held with service managers at various auto repair
facilities, and with manufacturers' service representatives. Also, repair
manuals for different types of carburetors were reviewed in detail.
In general, the procedure proposed for this inspection element constitutes
a major carburetor tune-up. The exact procedures vary as a function of manu-
facturer and by model. Some models require major disassembly of the carburetor
and related equipment in order to perform the adjustments required under this
proposed inspection format. All models require the removal of the air cleaner.
The sequences depicted in Appendix A provide a general indication of both the
nature of the carburetor inspection and the degree of variability in the tech-
niques used to inspect and adjust three models manufactured by the Rochester
Division of General Motors.
In addition to the adjustments outlined above, the A/F must be reset. It
is not entirely clear that this step will be necessary (or, for that matter,
practical) on vehicles manufactured subsequent to 1981 since generally the
carburetors on these vehicles are equipped with limiter caps or plugs that pre-
vent any adjustments to the A/F unless these devices are removed. Once the
caps are removed, they cannot be replaced. One important function that these
caps perform beyond preventing readjustment (actually tampering) is that their
presence indicates that the A/F has not been altered and therefore it can be
assumed that it does not require adjustment. In fact, the following note ap-
pears in a service manual9 published by Rochester Products Division of General
Motors:
NOTE
Idle mixture screws have been preset at the fac-
tory and capped. Do not remove the caps during
normal engine maintenance. Idle mixture should
be adjusted only in the case of major carburetor
overhaul, throttle body replacement, or high idle
13
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CO as determined by state or local inspections.
Adjusting mixture by other than the following
method may violate Federal and/or California or
other state or provincial laws.
For vehicles that require the adjustment, one of three techniques is used.
The first A/F adjustment technique is referred to as the "lean drop"
method. This method is used on many 1975 through 1978 vehicles. It involves
the adjustment of the idle mixture until the highest idle engine speed is
achieved (as determined through the use of a tachometer). When this maximum
idle speed is obtained, the mixture is leaned (the A/F is increased) to the
point where a specified RPM drop occurs. This is the point where the optimum
A/F occurs for emissions, fuel economy and driveability.
The second technique is used primarily on pre-1977 Chrysler Corporation
cars. This process involves adjusting the A/F based on idle carbon monoxide
levels in the exhaust stream measured by an appropriate emissions analyzer.
The third technique is referred to as propane enrichment. On vehicles
that utilize carburetors having a limited range of idle mixture adjustment on
the rich side, the use of propane introduced into the fuel mixture provides an
artificial means of enrichment. The lean drop characteristics described above
are achieved in this manner. A recommended10 procedure for performing idle
mixture adjustment using propane enrichment is:
1. Set parking brake and block drive wheels. On cars equipped with
vacuum parking brake release, disconnect and plug hose at brake.
2. Disconnect and plug hoses as directed on the emission control
information label under the hood.
3. Engine must be at normal operating temperature, choke open and
nlr conditioning off.
4. Connect an accurate tachometer to engine.
5, Disconnect vacuum advance and set timing to specification shown
on the emission control information label. Reconnect vacuum
advance.
NOTE
On cars equipped with electronic spark timing,
check timing as directed on the emission label.
6. Disconnect crankcase ventilation tube from air cleaner.
14
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6A. On L-4 151 CID engines - disconnect crankcase ventilation hose
at vapor storage canister.
7. Insert hose with rubber stopper from propane valve into the
crankcase ventilation tube opening in the air cleaner (see
Figure 1).
7A. On L-4 151 CID engines - insert hose with rubber stopper from
propane valve into the positive crankcase ventilation hose at
the charcoal canister end of the hose.
8. Propane cartridge must be in a vertical position.
9. Slowly open propane control valve until maximum engine speed is
reached with the transmission in Drive (Neutral for manual shift)
NOTE
Too much propane will cause engine speed to drop.
10. Observe propane flow meter to ensure propane cartridge is ade-
quately full.
11. With propane flowing, adjust idle speed screw or solenoid to
the enriched RPM (starting point for lean drop setting - see
specifications).
NOTE
On some applications, it is necessary to remove
the air cleaner and tile to one side to gain
access to the idle speed screw. Install flexible
shaft tool over idle speed screw, re-install air
cleaner and proceed with adjustment.
12. Turn off propane. Place transmission in Neutral and run engine
at approximately 2,000 rpm for 30 seconds. Return to idle and
put transmission in Drive (Neutral for manual shift).
13. Check idle speed. If it is as shown on the emission control
information label, the idle mixture is correct. In this case,
proceed with Step 18.
14. If the speed is too low, carefully remove caps from mixture screws
and back out (richen) 1/8 turn at a time until speed on emissions
label is reached. If the speed is too high, carefully remove caps
from mixture screws and turn screws equally in (leaner) 1/8 turn
at a time until speed is reached.
15
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NOTE
If necessary, remove air cleaner and tilt to one
side to gain access to the idle mixture screws.
Install flexible shaft tool over idle mixture
screws(s), re-install air cleaner and proceed
with adjustment.
15. Turn propane on again to check maximum engine idle speed. If
speed is different from specification (enriched RPM - starting
point for lean drop setting), readjust idle speed screw on
solenoid to enriched RPM with propane flowing.
16. Turn off propane again, clean out engine at 2,000 rpm for 30
seconds in Neutral. Recheck idle speed with transmission in
Drive (Neutral for manual shift). It should be as shown on
the emission control information label. If not, repeat the
adjustment procedure as in Step 14.
17. If rough idle persists, turn mixture screws in until lightly
seated. Back these out equally to the average previous posi-
tion and re-run propane idle test starting with Step 9.
18. Turn off engine and remove propane tool. Connect crankcase
ventilation tube to air cleaner. On L-4 151 CID engines -
connect crankcase ventilation hose at vapor canister.
RUBBER STOPPER
INSTALLED IN
CRANKCASE VEN
TILATOR TUBE \
OPENING
PUSH
VALVE
FLOW
METER
CONTROL
VALVE
PROPANE
FUEL
CYLINDER*
•OBTAIN FROM
LOCAL SUPPLY
SOURCE
IDLE MIXTURE ADJUSTMENT
(PROPANE ENRICHMENT METHOD)
Source: Reference 10
Figure 1. Propane enrichment device,
16
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It is obvious that the carburetor inspection and adjustment proposed
under the high option is a very demanding process in terms of both time and
skill. Discussions with service personnel indicate that only a highly com-
petent mechanic should attempt to perform the adjustments required by this
option. The required skill level is increased if the mechanic is expected
to perform the adjustments on all types and makes of vehicles, which would
be expected in an I/M program.
Special equipment requirements are more or less limited to small tools
and special gauges, a propane enrichment device, and an emissions analyzer.
Also, a complete set of service manuals for all carburetor and vehicle
configurations is essential.
The time required to perform the complete carburetor inspection and
adjustment routine is highly variable from vehicle to vehicle. Generally,
estimates provided by service representatives range from 1 to 2*5 hours per
carburetor depending on the type of vehicle, the carburetor type and model,
what accessories (such as air conditioning) are on the vehicle, and the
mechanic's familiarity with the particular vehicle configuration.
Ignition System—
The proposed inspection scenario calls for the examination of seven
components of the ignition system, including:
• spark plugs;
• wires;
• distributor cap;
• rotor;
• vacuum advance;
• magnetic trigger; and
• timing.
The individual inspection procedures are outlined in Table 3.
The skill level required for this portion of the inspection is not as
great as for the carburetor phase. Generally, a mechanic experienced in
engine tune-up work should be able to perform the required inspections ade-
quately. The amount of time required to perform the inspections is quite
variable. Estimates provided by several automotive service managers indicated
that the time range is from 30 minutes to over 2 hours, again depending on the
particular vehicle being inspected.
There are no highly specialized equipment items required, although an
oscilloscope could be used to assess the condition of ignition wires. Use
of an osilloscope would likely be optional, based on its availability.
Thermal Air Inlet—
The following Is a typical procedure used to check the thermostatically
controlled valve in the air cleaner.
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TABLE 3. PROCEDURE FOR IGNITION SYSTEM INSPECTION
Element
Procedure
Spark plugs
Wires
Distributor cap
Rotor
Vacuum advance
• Remove from engine and examine for excess deposits or
signs of unusual oil deposits or fouling that might
indicate a more serious problem. Check for proper
plug type and gap.
• Clean exterior of wires. Remove any evidence of cor-
rosion on terminals. Inspect for evidence of checking,
burning, or cracking of insulation. Check for tight
fit at distributor cap and plugs. An engine analyzer
(oscilloscope) may be used to check resistance.
• Visually check interior and exterior of distributor
cap for cracks, carbon tracking, and terminal
corrosion.
• Visually check for cracks, carbon tracking, and ter-
minal corrosion.
• For transmission controlled vacuum advance:
First method:
1. Set parking brake and block drive wheels.
2. Run engine at fast idle.
3. Shift 3-speed transmission into third, 4-speed
transmission into fourth, or 5-speed trans-
mission into fourth and fifth. Do not release
clutch.
4. Engine speed should increase noticeably as
vacuum is applied to the distributor.
Alternate method:
1. Set parking brake and block drive wheels.
2. Connect a vacuum gauge to vacuum line at
distributor.
3. With transmission in neutral, run engine at
1,000 rpm. There should be no vacuum reading •
on gauge.
4. Shift 3-speed transmission into third, 4-speed
transmission into fourth, or 5-speed trans-
mission into fourth or fifth.
(continued)
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TABLE 3 (continued)
Element
Procedure
Vacuum advance
(continued)
Magnetic trigger
5. There should now be vacuum at the gauge.
If vacuum is not present in these tests:
1. Connect a test light (1893 bulb or smaller)
between the two connector terminals on the
solenoid.
2. Start engine. Test light should be on.
3. If light is not on, check for open circuit. If
there is no open circuit, replace transmission
switch.
4. Place 3-speed transmission into third, 4-speed
transmission into fourth, or 5-speed trans-
mission into fourth or fifth.
5. Light should go out.
6. If light does not go out, check for grounded
wire between solenoid connector and transmis-
sion. If wire is not grounded, replace trans-
mission switch.
All others:
- Set parking brake and block drive wheels. Place
transmission in Park or Neutral.
Disconnect and plug vacuum hose at distributor.
Apply at least 15" Hg of vacuum to the distributor
from an external vacuum source.
Engine speed should increase. Also, diaphragm
should hold vacuum for at least one minute.
- If either part of Step 4 fails to occur, replace
vacuum advance diaphragm.
No specific test identified.
Timing
Using tachometer and timing light, set timing as per
instructions on Emissions Control Information Label,
or service manual.
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1. Inspect air cleaner to ensure that all hoses and ducts are connected
and correctly installed. Inspect valve in snorkel for proper oper-
ation. If engine is warm (above room temperature) remove top of
air cleaner. Cool the temperature sensor with a cool wet rag.
2. If air cleaner has cold air intake hose, it must be disconnected.
3. Start engine. Watch damper valve in air cleaner snorkel. It may
be necessary to use a mirror to see inside the snorkel.
4. When engine is first started, valve should close. As air cleaner
warms up, valve should slowly open.
5. If valve doesn't close when the engine is started, check for
vacuum at the vacuum motor.
6. If vacuum is present, check for binding on the damper valve and
operating link. If damper moves freely, replace vacuum motor.
(Failure of the valve to close is more likely to result from
mechanical bind due to a damaged or corroded snorkel assembly
than from a failed motor. This should be checked first, before
replacing vacuum motor).
7. If no vacuum is present, check hoses for disconnects, cracks
or pinches.
8. If there are none, replace temperature sensor in the air
cleaner.
This task is not particularly difficult nor does it require specialized
tools or other equipment. The time required to perform the inspection can be
expected to range from 10 to 20 minutes.
Heat Riser—
The inspection procedure involves manually checking the heat riser valve
to ensure that it operates freely and that the operating mechanism (generally
n bimetalic sensor) is connected. The purpose is easily accomplished by a
mechanic who has a basic familiarity with the inspection requirements, in
less than one minute.
PCV Components—
The following procedure is used to inspect the PCV system:
1. Remove PCV valve from engine.
2. Shake valve, listen for rattle.
3. If valve does not rattle, replace valve.
4. Start engine. Check for vacuum through valve by placing thumb
over end of valve.
20
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5. If no vacuum is felt, check for plugged hoses or valve. Replace
valve or hoses if plugged.
6. Check PCV filter; clean or replace as necessary.
Exhaust Has Recirculation (EGR) System—
Ordinarily, this system does not usually require routine maintenance,
however it is possible to ensure that the system is functioning properly by
performing one of the following test routines:
1. Set parking brack and block drive wheels. Place transmission
in Neutral or Park.
2. With the engine at normal operating temperature, open the
throttle while feeling the bottom side of the valve
diaphragm.
CAUTION
Valve is hot. It may be necessary to wear
gloves to avoid burning fingers.
3. Valve diaphragm should move upward (open) as the engine
accelerates.
4. Valve diaphragm should move downward (close) as the engine
returns to idle.
NOTE
A slight vibration of the diaphragm plate may be
noticed on backpressure models. This is due to
the control valve modulating under light load and
does not indicate an undesirable condition nor
one requiring correction.
5. If valve diaphragm does not move, check for vacuum at hose
with engine at 2,000 rpm.
6. If vacuum is present, replace valve.
7. If there is no vacuum, check vacuum hose for restriction.
8. If there is no restriction in the hose and the engine is
thoroughly warmed-up, replace EGR temperature control
valve.
If the EGR is suspected of causing a problem or when there is a possi-
bility the EGR passages are plugged, a more detailed test may be performed.
21
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1. Connect accurate tachometer to engine.
2. With engine at normal operating temperature, run engine at 2,000
rpm in neutral.
3. Disconnect vacuum hose from EGR valve.
4. Engine speed should increase. If it does, the EGR valve is
operating and the passages are clear.
5. If the speed does not increase, check under the valve diaphragm
for movement as the hose is connected. If there is no movement
and there is vacuum at the hose, replace the valve.
CAUTION
Valve is hot. It may be necessary to wear
gloves to avoid burning fingers.
6. If the valve moves, but the speed does not increase, remove
and clean valve. Also clean passages in manifold.
7. To test the EGR vacuum temperature control, the engine must
be allowed to cool or the temperature sensor cooled to at
least 60°F. It should then block vacuum to the EGR valve.
If it does not, replace temperature sensor.
The inspection requires only a basic familiarity with the EGR system and
can be accomplished easily by an inspector with minimal training. The time
required for this inspection is approximately 2 minutes.
Evaporation Control System—
This system is inspected as follows:
1. Check all fuel and vapor lines and hoses for proper connections
and correct routing as well as condition. Remove canister and
check for cracks or damage. Replace damaged or deteriorated
parts as necessary. Replace filter in lower section of canister
at designated intervals.
2. Inspect the fuel tank, lines and cap for damage that could
cause leaks.
3. Remove fuel cap.
4. On threaded caps inspect rubber 0-ring for cuts, breaks,
swelling, or misposition. Inspect threads for wear or
damage.
22
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5. Install cap. Check for proper ratcheting as cap is tightened.
On cap with locking tabs, inspect gasket for an even imprint
from the filler neck.
6. Replace any damaged or deteriorated parts.
The inspection process is relatively simple, requiring basic familiarity
with the system and no special tools. The entire inspection, including
required maintenance, should take no more than 15 minutes.
Air Injection Reaction (AIR) System—
This system does not require routine periodic maintenance other than
inspecting the pump drive belt every 15,000 miles for tension, cracks,
fraying, or other signs of wear. The belt should be adjusted or replaced
as necessary. The air pump should never be oiled. The air pump cannot
be disassembled. If it becomes noisy or otherwise inoperative, it must be
replaced.
To inspect AIR system, the following procedure is followed:
1. Set parking brake and block drive wheels.
2. Start engine. Place transmission in neutral or park.
3. Feel for air exhausting from ports in diverter valve silencer or
from the muffler on the air by-pass valve. There should be none.
Momentarily accelerate engine.
4. As engine returns to idle, air should exhaust from diverter
valve silencer or from the muffler on the by-pass valve. In
most cases, the air can be heard. If in doubt, feel diverter
valve exhaust ports for air. It should exhaust for several
seconds.
5. If system does not perform properly, refer to the manufacturer's
service manual for complete diagnostic and service information.
This inspection task requires a basic familiarity with the AIR system. No
special tools or equipment are required. The test procedure, excluding any
maintenance or adjustment, should not require more than one to two minutes.
Spark Delay Valves—
See Ignition System.
Three-way Catalyst, Reduction Catalyst, Oxidation Catalyst—
The exhaust catalysts are visually inspected to determine that they are
present and not damaged. The inspection process requires a lift, a pit, or
a lighted mirror device since the catalyst is located under the vehicle.
Inspection time is approximately one minute.
23
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Discussion of the High Option
The obvious intent of the high option is to ensure that all systems and
components that affect carbon monoxide or hydrocarbon emissions are maintained
to manufacturer's specifications. From the standpoint of comprehensiveness
only, this option approaches the ideal in that it focuses on most of the items
and systems that can adversely affect emissions characteristics. Realistically,
however, the complete definition of the "ideal" program must be developed in
terms of practicality, cost effectiveness, public acceptance, etc., in addition
to the thoroughness of the inspection. In this overall context, then, the high
option becomes somewhat less than ideal. In fact, even without quantifying the
cost and other associated impacts, there is a tendency to question whether the
approach Is at all reasonable. This uncertainty is based primarily on the time
requirements and level of expertise needed to perform the inspections. The
overall inspection time has been estimated to have a range of from 1% to almost
5 houra per vehicle. This is clearly beyond the desired scope of most inspec-
tion programs.
An important consideration in parameter inspection programs in general is
whether the intent should be only to identify specific defects and maladjust-
ments and require the motorist to go elsewhere for repairs, or whether the
Inspection should include necessary adjustments and minor repairs. On one
hand there Is a question of consumer protection. Generally, it is considered
desirable to separate the inspection and repair process in the interest of con-
sumer protection. On the other hand, however, the issue of consumer convenience
argues for a combined inspection/repair approach. This is particularly rele-
vant to the high option since separating the inspection and repair phases
Imposes severe time and cost requirements on the motorist. Essentially, any
failure requires repair and retesting, since EPA's current policies require
"... maintenance and retesting of failed vehicles ..." as stated previously.
This results in extremely high costs for motorists whose vehicles fail any of
several inspection elements, particularly those involving the carburetor.
A related issue concerns whether or not the state or an agent of the state
can legally become directly involved in the repair of motor vehicles. This
type of Issue surfaces with a centralized approach where the state or an agency
contracted by the state operates the inspection facilities. If it is deter-
mined that it Is either not legal or not desirable for the state to be involved
In repairs, then the program must be limited to the performance of inspections
only. Tt appears that a parameter program of this type would be extremely
unpopular and difficult to manage.
Notwithstanding these preliminary observations, a more thorough assess-
ment of the costs, benefits, effectiveness, and indirect impacts associated
with the high option parameter inspection program is in order. In the context
of this report, the specific programs being evaluated reflect the extremes in
the range of possibilities.
24
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TECHNICAL ASPECTS OF THE LOW OPTION
General
Although there are many different systems and individual components that
affect the emissions characteristics of a motor vehicle, it is reasonable to
expect that only certain ones are likely to deteriorate in a manner that would
warrant periodic inspection. Moreover, it can be expected that some components
that are out of adjustment or that need repair will have a more significant
impact on emissions compared to other deficient components. These factors pro-
vide the basis for the low option concept.
Essentially, the difference between the high and low options is that the
low option focuses on a limited number of parameters — specifically, those that
both warrant periodic inspection and have a relatively significant impact on
emissions. A limited analysis of the causal aspects of high-emitting in-use
vehicles indicates that an annual inspection and adjustment of the parameters
listed in Table 2 would provide a reduction in the overall emissions rate from
the in-use vehicle fleet (this is discussed in detail in Section 3).
Inspection Elements
In contrast to the high option, the low option only considers five ele-
ments. Of these five, three involve visual inspections while the other two
require a functional check. Each inspection element is discussed in the fol-
lowing paragraphs.
Visual Inspection—
The intent here is to identify any obvious tampering with or damage to
the emissions control system and accessories. The exact nature of the visual
inspection will vary from vehicle to vehicle although several specific elements
will generally be common to all vehicles. The types of items to be examined
include lines and hoses, air cleaner, carburetor preheat duct, wires and elec-
trical connections, and drive belts. Also, the inspector must check to see
that all appropriate components are present.
The basic intent is to ensure that the emissions control system is intact
and that the system's operation is not impaired. Inspection criteria are based
primarily on the condition of the components to the extent that a visual inspec-
tion permits.
The skill level associated with this task is not exceptionally high.
Essentially, the inspector should be familiar with the general types of emis-
sion control devices used on different vehicles, and how to assess the condi-
tion of hardware (hoses, etc.). The actual inspection time is estimated to
range from 1 to 2 minutes.
Fuel Filler—
The primary concern is that the fuel neck restrictor is in place on all
vehicles that require the use of unleaded fuel. This can be checked by merely
removing the filler cap and visually inspecting for the presence of the
restrictors. A go/no-go gauge can also be used to ensure that the restrictor
25
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has not been enlarged to accept a leaded fuel nozzle. It is also suggested
that the filler cap be inspected to ensure that the 0-ring is not damaged or
deteriorated, that the proper racheting action occurs when the cap is replaced,
and that the threads on the cap and filler neck are not damaged.
The inspection requires only a basic familiarity with the fuel filler
components; the actual inspection time range is 30 seconds to 1 minute.
Catalytic Converter—
The intent of this inspection is to ensure that the converter has not been
removed and that there is no obvious physical damage to the converter housing.
This constitutes a reasonable inspection of the device since obvious damage to
the housing generally means that there is a strong possibility that internal
damage has also occurred. On the other hand, it is obvious that this type of
inspection would identify problems such as catalyst poisoning, which could
occur without the fuel filler neck having been modified.
The inspection procedure involves visually checking the converter for holes,
dents, or signs of overheating or burning. The inspection can be accomplished
without tools or special equipment, although a lighted mirror or similar
device could be incorporated. The inspection time requirement is less than
1 minute.
F.GR Check—
The process for inspecting the EGR system is the same for both options
and wan described in detail previously.
Idle Air/Fuel Mixture—
This procedure is the same as for the idle mixture inspection task dis-
cussed previously as part of the high option. The time requirement for this
task is estimated to be 20 to 30 minutes.
DiscusBJon of the Low Option
The obvious difference between the high and low options is the level of
Intensity involved. Whereas the inspection time requirement for the high
option Is discussed in terms of hours, the low option can be accomplished in
about 35 minutes. The question of the relative effectiveness of the two
options is of importance and will be considered in detail in a subsequent
section.
From the standpoint of inspection time, expertise, and special equipment
required, the low is much more reasonable than the high option. However, com-
pared to the tailpipe inspection approach, the low parameter inspection
requires a significantly greater amount of time to perform — generally 5 to
10 minutes for a tailpipe measurement inspection compared to approximately 35
minutes for the low parameter inspection. The additional time required is
directly reflected in the cost of the inspection. As stated previously, how-
ever, a major factor that can contribute to the attractiveness of a parameter
inspection program, particularly one on the scale of the low option, is the
ability to incorporate some of the more minor repair and adjustment work into
26
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the inspection process. For the low option, the most likely repair and adjust-
ment work would involve the carburetor adjustment and replacing minor compo-
nents such as vacuum hoses and lines found to be damaged.
In an overall sense, the low option appears to be much more practical than
the high option owing primarily to the fact that the inspection time and
undoubtedly the costs are more in line with what would be considered reasonable
for any type of mandatory inspection. Although it is shown here that the low
parameter inspection procedure requires more time than a tailpipe measurement
inspection, the actual difference is not so significant that a more detailed
assessment would not be warranted. This more detailed analysis would be appro-
priate if specific program alternatives were being compared and if comparisons
were made of the total inspection-maintenance-reinspection cycles. These
types of analyses cannot be conducted at this point since only general concepts
are being considered.
27
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SECTION 3
POTENTIAL EFFECTIVENESS IN REDUCING MOTOR VEHICLE EMISSIONS
INTRODUCTION
Given the context in which most I/M programs are implemented, a primary
measure of effectiveness is the overall reduction in emissions that is
achieved. The expected emissions reductions result from maintenance per-
formed in response to the program that would not have otherwise been under-
taken. The parameter inspection programs being considered here are excep-
tionally maintenance-intensive, therefore it is necessary to assess the
expected effectiveness very carefully to determine, at least in a basic
sense, whether the expected reductions in emissions warrant such a high
Level of vehicle maintenance. This section discusses the potential effective-
ness of applying various levels of inspection and maintenance to the general
vehicle fleet in terms of the relative levels of emissions reductions that
can be expected. The intent is not to develop a detailed quantitative assess-
ment of the emissions reductions expected with each program, but rather to
provide a discussion of the relative effectiveness of each type of program
in terms of emissions reduction potential.
It Is emphasized that the overall effectiveness of any I/M program is
determined by many other factors besides emissions reduction. In fact, an
even more important measure of effectiveness is the relative cost effective-
ness of each program alternative. Several additional factors, such as con-
sumer impacts, program flexibility, impact on the repair industry, etc, must
also be considered In evaluating the overall effectiveness of alternative
I/M approaches. The discussion provided in this section therefore provides
only a partial indication of the potential effectiveness of the four para-
meter inspection approaches under consideration.
POTENTIAL FOR REDUCING EMISSIONS
The effectiveness of any I/M program reflects the change in maintenance
practices that result. The most thorough inspection program is of little
value unless deficiencies in the various emissions-related systems and param-
eters are corrected. The underlying premise in parameter inspection is
that if all emissions-related components and systems are functioning in
accordance with the manufacturer's specification, the emissions characteris-
tics, driveability, and fuel economy should be optimized. Parameter inspec-
tion programs require that all affected vehicles be inspected periodically
to verify that the appropriate parameters are set according to the manu-
facturer's specifications. As one would expect, there are many individual
28
-------
parameters, systems, and components in today's motor vehicles that either
directly or indirectly affect emissions characteristics. A fundamental
concern in designing a parameter inspection program is to include as in-
spectable parameters, only those items that have a significant impact on
emissions, and that have at least a moderate potential for actually requir-
ing some form of maintenance. The intent of the discussion presented in
the following paragraphs is to indicate which specific vehicle systems, com-
ponents, and parameters have both a potentially significant impact on emis-
sions and a moderate likelihood of requiring maintenance on a periodic basis.
Factors That Affect Vehicular Emissions
If all possible I/M concepts could be expected to achieve the same result
with regard to maintenance, then only the relative differences in costs, con-
venience, political and public acceptability, and similar issues would have
to be assessed. The types of programs being considered here, however, are
not expected to be at all similar in terms of maintenance, therefore diff-
erences in effectiveness can also be expected. An overview of issues related
to emissions generation, emissions-related maintenance experience, and various
characteristics of the programs under consideration provides a basis for
understanding the nature of these differences.
The control of pollutants from spark ignition, gasoline engines is a
well understood science as is evidenced by the degree of control that is
currently achieved in the latest production vehicles. Essentially, control
is achieved through closely regulating various engine parameters and systems,
such as air/fuel ratio and timing, and by treating exhaust gases to ensure
complete combustion and convert certain pollutants to less noxious compounds.
In discussing these control concepts, separate consideration can be given to
basic engine components and systems that affect emissions, and emissions
control systems and devices that are used exclusively for controlling
specific pollutants.
The primary engine systems that are of importance include the induction
and the ignition systems. The induction system consists of those components
that introduce a charge of fuel and air into the combustion chamber such that
the composition of the charge is appropriate with respect to both the engine
output demand and the prevailing environmental conditions in which the engine
is operated. The primary components include the carburetor, intake manifold,
warm-up system, and related items. These components directly affect the
composition of the charge (that is, the air/fuel ratio) and hence the stoichi-
ometric balance, which essentially determines the composition of the exhaust
gases. Components such as the carburetor and warmup system are comprised of
a number of individual elements that function either independently or as a
complete system. Isolated malfunctions of many of these individual elements
can affect the emissions rate of HC, CO, or NOX. A summary of the most criti-
cal elements of each components, and an indication of how either a malfunction
or maladjustment of each element affects emissions are presented in Table 4.
29
-------
TABLE 4. IMPACT OF MALADJUSTMENT OR MALFUNCTION OF VARIOUS ENGINE
COMPONENTS ON EMISSIONS OF CO, HC, AND NOX
Impact of maladjustment
or malfunction
System Component
Element
CO
HC
NO.
Induction Carburetor Metering rods
Power valves
Float and valve
Idle setting
Choke
Vacuum break
Warm-up
components
Other
Ignition Timing
related
Quality
related
Heat riser
Thermal air
Choke
Air filter element
Intake manifold
Vacuum lines/hoses
Exhaust valves
Compression
Basic timing
Spark advances/
delay mechanisms
Spark plugs/wires
Coil
Distributor,
points, condenser
Electronic
components
High Moderate Low
High Moderate Low
Moderate Moderate
Moderate-high Moderate
High High Low
Moderate Low Low
Moderate Moderate
Moderate Moderate Low
— see carburetor —
Low
Low
Moderate
Moderate
Low
Low
Low
Moderate
Moderate
Moderate
High
Moderate
High
High
High
High
High
High
Low
Moderate
Moderate
Low
Low
Low
Low
30
-------
Once the air and fuel charge has been induced and compressed, a source of
ignition must be provided in order to initiate combustion. For Otto-cycle
engines, the ignition source is a spark generated by the ignition system.
Both the timing and quality of the spark are critical to emissions as well as to
fuel economy and performance since both directly affect the quality of the
combustion process. A general representation of the relationship between
ignition timing, and fuel economy and emissions is provided in Figure 2. As
can be seen from Figure 2, ignition timing has a fairly important impact on
HC emissions and fuel economy. Proper ignition timing is a function of
several parameters including engine speed and load, and operating mode (e.g.,
cold starting, accelerating, etc.). The general control of ignition timing
occurs in the distributor. Precise control as a function of engine speed and
power demand is accomplished through two spark advance mechanisms - the cen-
trifugal advance mechanism, which adjusts as a function of engine speed, and
the vacuum advance, which responds to varying power demands.
The quality of the ignition spark depends largely on the physical condi-
tion of the breaker points, condenser, rotor, distributor cap, ignition wires,
and spark plugs. Poor spark produces misfiring and inadequate charge combus-
tion, resulting in high HC emissions and poor fuel economy. The general
impact of maladjusted or malperforming ignition system components on emissions
is also illustrated in Table 4.
Several systems are employed only for the control of pollutants, there-
fore, if these are maladjusted or malperform, the resulting impact on emis-
sions is obvious. Included are systems that control tailpipe emissions,
crankcase emissions, and evaporative emissions in addition to those that
influence the combustion process to the extent that the production of undesir-
able exhaust compounds is minimized. Specific emissions control devides and
systems, and the types of emissions that they affect are listed in Table 5.
The previous discussion provides a very basic summary of the types of
special systems and parameter controls used to reduce HC, CO, and NOX emis-
sions from the existing vehicle fleet. It can be expected that the main-
tenance aspects of any I/M program tend to focus on the specific devices
and systems that have the largest potential impact on emissions. There are
several additional factors that must be considered. One of the more impor-
tant of these is the relative frequency of maladjustment of malfunction
of each component or system. This is discussed in the following paragraphs.
Frequency of Parameter Defects and Their Impacts on Emissions
Whereas the previous discussion identified specific systems and components
that contribute to excess emissions if not properly maintained, the discussion
here considers how often the various systems are found to actually require
repair or adjustment, and the relative impact that various parameters have on
emissions from in-use vehicles.
Several sources of information exist that provide a good indication of
the expected frequency of malperformance of various emissions-related systems.
One such source is data developed by the U.S. Environmental Protection Agency's
31
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KEY:
HC EMISSIONS
CO EMISSIONS
FUEL ECONOMY
-30°
-20
DEVIATION OF SPARK TIMING FROM MANUFACTURERS SPECIFICATIONS
Figure 2. General representation of the impact of spark
timing on fuel economy and emissions.
32
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TABLE 5. IMPACT OF MALADJUSTMENT OR MALPERFORMANCE OF EMISSIONS
CONTROL COMPONENTS ON HC, CO, AND NOX EMISSIONS
Impact of maladjustment
or malfunction
System
Component
CO
HC
NOX
Crankcase emissions PCV
control
Moderate
Moderate
Combustion control
EGR valve
Temperature sensor
High
High
Exhaust treatment AIR pump
AIR pump drive and
plumbing
Oxidation catalyst
Reduction catalyst
High High
Moderate-high Moderate-high
High
High
High
33
-------
Office of Mobile Source Air Pollution Control concerning the state of repair
of in-use 1975-76 model year vehicles. These data were developed as part of
a program referred to as the Restorative Maintenance (RM) program, which was
initiated specifically to investigate the causes for and possible resolutions
to the problem of much higher than expected emissions rates from the 1975-76
in-use vehicles.
The RM program involved analyzing engine parameters and systems that
directly affect the emissions characteristics of the so-called Technology II
(catalyst equipped) vehicle fleet. Many of these systems and parameters are
the same ones discussed in the previous paragraphs; the specific systems and
individual components considered are listed in Table 6. A sample (albeit an
admittedly small one) of the 1975 and 1976 model-year vehicles was analyzed
in detail by automotive technicians to assess the condition of the systems
listed in Table 6. This sample included a total of 300 vehicles - 102 manu-
factured by General Motors, and 99 manufactured by each of Ford and Chrysler.
The observed rate for failures (either malperformance or maladjustment of
the major systems, by manufacturer, is shown in Table 7.
As is shown in Table 7, the most frequent failures are found in the
ignition and carburetor systems. More specifically, the analysis indicates
that the most common failures are associated with:
• Improper idle mixture setting;
• Improper idle speed setting; and
• Improper timing adjustment.
The emissions impact of these three types of deficiencies was anlayzed using the
Federal Test Procedure (FTP) and correlating the observed deficiencies to the
resulting emissions measurements. Table 8 summarizes the results of a further
analysis that identified which deficiencies resulted in a statistically signi-
ficant difference in FTP emissions as compared to a no-deficiency case. This
table shows, for instance, that when comparing the emissions from General
Motors vehicles that have maladjusted idle CO (idle mixture), with General
Motors vehicles that have idle CO adjusted within specifications* without
regard as to whether other parameters are in or out of specification, statisti-
cally significant differences occur in each of the three FTP phases (cold
start, hot start, and stabilized) as well as in the composite FTP emissions
rate, for both CO and HC. The "At Least One" category compares vehicles that
had at least one of the three parameters within specification to similar
vehicles where all three parameters were within manufacturer's specification
simultaneously. This table is quite interesting in that it illustrates that
idle CO is a fairly important indicator of whether the vehicle is emitting
CO and HC at a rate that is higher than the mean for that particular type of
vehicle. Further, additional analysis of the actual emissions data for each
vehicle suggests that idle CO levels may in fact correlate acceptably well
*Since most vehicles do not have idle CO specifications, an idle CO value was
selected to define the difference between adjusted and maladjusted idle CO.
A value of 0.5 percent was selected for the idle CO specification, where
values greater than 0.5 percent are considered outside of tolerances.
34
-------
TABLE 6.
Major system
ENGINE PARAMETERS AND EMISSIONS CONTROL SYSTEMS CONSIDERED
IN THE EPA RESTORATIVE MAINTENANCE PROGRAM
Subsystem
Elements considered
Induction
system
Carburetor
system
Fuel delivery
Choke
Preheating
control
Ignition
system
Emissions
control
system
EGR
Heated air inlet door
Heated air inlet diaphragm
Temperature sensors, switches, modulators
Delay valve
Air filter element
Hoses, tubes, lines, wires
Carburetor assembly
Limiter caps
Tailpipe idle CO
Idle speed
External idle enrichment
Idle stop solenoid
Dashpot and other throttle modulators
Fuel filter element
Hoses, lines, wires
Choke adjustment
Vacuum diaphragm
Electrical controls
Hoses, lines, wires
Exhaust heat control valve assembly
Actuating diaphragm
Coolant temperature sensing switches
Check valve
Hoses, lines, wires
Distributor assembly
Initial timing
Spark plugs and their wires
Vacuum advance diaphragm
Spark delay devices
Coolant temperature sensing switches
Hoses, lines, wires
Dwell
EGR valve assembly
EGR valve backpressure transducer
EGR time delay solenoid
Venturi vacuum amplifier
High speed modulator
Vacuum reservoir
Coolant temperature sensing switches
Hoses, lines, wires
(continued)
35
-------
TABLE 6 (continued)
Major system
Subsystem
Elements considered
Air injection
Crankcase
emissions
subsystem
Exhaust
system
Evaporative
emissions
subsystem
Miscellaneous
Air pump assembly
Bypass and/or dump valves
Check valve
Electrical PVS
Solenoid vacuum valve
Floor pan switch
Vacuum differential control
Drive belt, attaching hardware
Hoses, lines, wires
PCV valve assembly
Filters
Hoses, lines, wires
Exhaust manifold, tailpipe,
Muffler catalyst
Evaporative canister
Canister filter
Hoses, lines, wires
Engine assembly
Engine oil and filter
Cooling system
Mechanical valve adjustment
Carburetor and intake manifold mounting bolts
Belt tensions
Hoses, lines, wires
36
-------
TABLE 7. OBSERVED FAILURE RATE FOR MAJOR SYSTEMS AND PARAMETERS BY MANUFACTURER
Ul
Manufacturer
(No. of vehicles)
General Motors (102)
Ford (99)
Chrysler (99)
Total (300)
Percent of
Induction
2
9
3
6
Carburetor
49
55
94
66
Ignition
22
25
32
26
EGR
9
18
19
15
vehicles
AIR
0
2
0
1
PCV
0
1
1
1
failing
Exhaust
0
0
0
0
Evaporative
1
1
2
1
Perc«
Miscellaneous
0
2
1
1
mt of vehicles with
least one failure
59
69
96
74
-------
TABLE 8. EFFECTS OF CERTAIN ENGINE PARAMETER MALADJUSTMENTS ON FTP EMISSIONS
00
Statistically significant
Manufacturer
General Motors
Ford
Chrysler
All vehicles
FTP
Timing
Idle CO X
Idle speed ;
At least one
Timing
Idle CO
Idle speed X
At least one X
Timing
Idle CO X
Idle speed X
At least one j X
Timing X
Idle CO X
Idle speed j
At least one X
Hydrocarbons
Cold Hot
start start
impact
resulting from deficiency
Carbon monoxide
FTP
i
XX X
X
x
X X
XX X
X X
X
X
X
X
X
X
X XX
X X X
X X XX
XX X
X
Cold
start
X
X
X
X
X
X
X
Hot
start
X
X
X
X
X
X
X
X
Stabilized
X
Oxides of nitrogen
Cold Hot
start start C
XXX
X
X
X X
X
X
X !
X
X
X
-------
with the ability to pass the FTP for CO and HC. This is indicated by
considering the pass/fail rates for vehicles undergoing the FTP as a function
of whether or not the idle CO parameter is within (assumed) specification;
Table 9 shows these rates for FTP CO and HC by manufacturer.
TABLE 9. PERCENTAGES OF VEHICLES PASSING AND FAILING FTP FOR
CO AND HC WITH IDLE CO PARAMETER IN AND OUT OF
ASSUMED SPECIFICATIONS
Manufacturer
General Motors
Ford
Chrysler
All
No. of
vehicles
outside
CO
specifi-
cation
28
15
75
118
Percent of vehi-
cles outside idle
CO specification
that failed FTP
for CO, (HC),
and [NOX]
96 (71) [18]
53 (27) [20]
87 (73) [311
85 (67) [26]
No. of
vehicles
in idle
CO
specifi-
cation
74
84
24
182
Percent of vehi-
cles in idle CO
specification
that failed FTP
for CO, (HC),
and [NOX]
7 (0) [27]
10 (7) [31]
13 (13) [38]
9 (5) [30]
Table 9 shows that there is a reasonable degree of agreement between idle
CO and the ability to pass the FTP for either CO or HC, while there is no
apparent agreement for NOX. it appears that the idle CO parameter would
be valuable to consider in both the inspection and maintenance phases.
This conclusion is supported by numerous other EPA test programs, as well.
In addition to analyzing the impacts of ignition timing, idle CO, and
idle speed on emissions characteristics, the RM study also considered the
impact of each component and system listed in Table 6 on emissions. As a
first step, each vehicle in the sample was inspected in detail to identify
the frequency of maladjustment, defects, disablements, or other impairments
to each element. The results for the "as received" sample are shown in
Table 10. This rather detailed look at the types of components found to be
in need of repair or adjustment is of importance here because it provides
an indication of which specific elements might be appropriate to consider
in a parameter inspection program from the standpoint of maximizing the
potential for identifying needed repairs. This particular sample is rele-
vant in connection with I/M programs because the vehicles represented were
generally about 1 year old when inspected (all had accumulated fewer than
15,000 miles) and, assuming that no deficiencies existed when each vehicle
was new, in this sense can be assumed to reflect annual deterioration for
certain (although, obviously, not all) parameters.
-------
TABLE 10. PERCENTAGE OF VEHICLES IN A 300-CAR SAMPLE WITH VARIOUS
DEFICIENCIES RELATED TO EMISSIONS-CRITICAL COMPONENTS
AND SYSTEMS
Percentage of vehicles
Major
system
Induction
Carburetor
Ignition
j ^ f,+^.^^ „ „
Component /element
Heated air inlet door
Heated air inlet diaphragm
Temperature sensors
Delay valve
Air filter element
Hoses, tubes, wires, etc.
Carburetor assembly
Limiter caps
Idle mixture
Idle speed
External idle enrich
Idle stop assembly
Dashpot and throttle
Fuel filter
Fuel hoses and lines
Other fuel
Choke adjustment
Vacuum diaphragm
Electrical controls
Choke lines and wires
Exhaust heat control
Actuating diaphragm
Coolant temperature
switches
Check valve
Hoses, lines and wires
Other choke-related
Distributor
Initial timing
Spark plug and wires
Vacuum advance
Spark delay devices
Coolant temp, switches
Other hoses and wires
Not
applicable
0.3
0.3
0.6
99.7
0.0
0.0
0.0
0.0
0.0
0.0
80.7
88.0
99.4
0.3
0.0
0.0
0.3
7.3
32.0
0.3
68.3
78.7
79.7
97.0
60.7
100.0
0.0
0.0
0.0
1.0
78.0
76.0
0.0
No
deficiency
99.4
99.0
98.4
0.3
100.0
96.0
98.7
54.7
62.3
75.3
18.3
12.0
0.3
99.7
99.3
100.0
88.7
90.7
66.0
98.0
31.7
21.0
20.0
39.0
39.0
0.0
98.4
81.0
98.3
98.3
20.7
23.7
96.7
Maladjusted,
disabled,
defective,
or otherwise
deficient
0.3
0.7
1.0
0.0
0.0
4.0
1.3
45.3
37.7
24.7
1.0
0.0
0.3
0.0
0.7
0.0
10.0
2.0
2.0
1.6
0.0
0.3
0.3
0.0
0.3
0.0
1.6
19.0
1.7
0.7
1.3
0.3
3.3
(continued)
40
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TABLE 10. (continued)
Percentage of vehicles
Major
system
EGR
AIR
PCV
Exhaust
Evaporative
Component /element
EGR valve
EGR valve transducer
EGR time delay
Venturi vacuum amplifier
High speed modulator
Vacuum reservoir
Coolant temp, switches
Hoses, wires, lines
Air pump
Bypass valve, pump valve
Check valve
Electric PVS
Solenoid vacuum valve
Floor pan switch
Vacuum differential
control
Drive belt and hardware
Hoses, lines, wires
PCV valve
Filters
Hoses , lines
Exhaust, manifold, and
muffler
Catalytic converter
Canister
Canister filter
Hoses, lines
Not
applicable
0.7
77.3
86.7
73.0
99.3
94.3
22.0
2.3
65.7
65.7
65.7
97.7
96.3
99.0
87.0
65.7
65.3
0.3
0.3
0.3
0.0
2.0
0.0
0.0
0.0
No
deficiency
96.0
18.0
12.6
27.0
0.7
5.7
77.4
90.7
34.3
34.3
34.3
2.3
3.7
1.0
13.0
34.3
34.0
99.7
99.7
99.0
100.0
98.0
100.0
99.7
99.0
Maladjusted,
disabled,
defective,
or otherwise
deficient
3.3
4.7
0.7
0.0
0.0
0.0
0.6
7.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.3
0.0
0.0
0.7
0.0
0.0
0.0
0.3
1.0
41
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The question of which deficient parameters contribute most to high emis-
sions must also be considered. The initial FTP emissions testing performed
on the 300-vehicle sample resulted in 175 vehicles failing. A detailed anal-
ysis of the individual engine parameters and emissions control systems for
these 175 vehicles was then performed as part of the RM program. As a result,
the failure rate for each emissions-related element of the 175-vehicle group
was identified. These are summarized in Table 11, which shows the percentage
of vehicles with deficiencies by major system. Again, it is shown that the
carburetor system is prone to a much higher deficiency rate than all other
systems, although the ignition and EGR systems also appear to have a signifi-
cant deficiency rate. A closer analysis of these three systems shows that
deficiencies are most likely to occur in eight specific elements or parameters.
These are listed along with their respective deficiency rates for both the
175-vehicle group that failed and the 125 vehicle group that passed the initial
FTP test, in Table 12.
TABLE 11. MAJOR SYSTEM FAILURE RATE FOR VEHICLES THAT DID NOT
PASS THE INITIAL FTP EMISSIONS TEST
Major system
Percentage of the 175-vehicle sample with
deficiencies in the major system
Induction
Carburetor
Ignition
EGR
AIR
PCV
Exhaust
Evaporative
Engine assembly and miscellaneous
At least one deficiency
6.3
84.0
36.0
23.A
1.1
0.6
0.0
2.3
1.7
91.4
TABLE 12. FREQUENCY OF DEFICIENCIES IN SPECIFIC ENGINE PARAMETERS AND
COMPONENTS FOR VEHICLES TAKING THE INITIAL FTP EMISSIONS
Number and (percentage) of
vehicles with deficiencies
Major system
Component/parameter
For vehicle
group failing
For vehicle
group passing
Carburetor
Ignition
EGR
Disabled limiter cap
Maladjusted idle mixture
Maladjusted idle speed
Maladjusted choke
Maladjusted timing
Defective or disabled EGR valve
Defective EGR transducer
Disabled hoses or lines
112
102
52
21
45
10
10
(64)
(58)
(30)
(12)
(26)
(6)
(30)*
24
11
22
9
12
0
(19)
(9)
(18)
(7)
(10)
(0)
—
—
*0nly 33 of the 175 vehicles were equipped with this component.
42
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Also as part of the RM program, maintenance was performed on certain
emissions-related systems to determine its impact on the ability to pass the
FTP emissions test. This was accomplished by comparing the FTP pass/fail
rate for the initial test, which was performed on all vehicles in the "as
received" state, with pass/fail rates for subsequent FTP tests after various
maintenance scenarios were performed. Of the 300 vehicles that received the
first test, 113 were retested after correction of all observed maladjustments
other than idle speed and idle mixture. This retest included 19 vehicles
that passed and 94 vehicles that failed the first test. Of those 113 vehicles
taking the second test, 74 failed at least one standard (CO, HC, or NOX); two
of these 74 had previously passed the first test. The emissions control com-
ponents of all 300 vehicles were then inspected. The FTP emissions levels
was made accordingly. At this point, a total of 148 vehicles had passed the
FTP (either test 1 or test 2). The 152 vehicles that had failed were in-
spected to determine whether the idle speed and idle mixture parameters were
within specification and adjustments were made as required (for those vehicles
without an idle CO specification, the manufacturer's recommended procedure for
resetting idle parameters was followd). Of the 152 vehicles inspected, nine were
found to be within specifications. The remaining 143 vehicles were retested, and
60 of these were able to pass. The 74 vehicles that failed the third RTP emissions
test, and the nine vehicles that were found to be within specifications for idle
speed and idle CO then received major tuneups, which included correction of defec-
tive emissions control components. These 83 vehicles were then tested, and a
total of 56 vehicles passed. The pass/fail rate for each of the four tests by
pollutant are shown in Table 13 as a function of the number of vehicles tested,
and in Table 14 as a function of the entire 300-vehicle sample.
A more quantitative indication of the impacts of the maintenance per-
formed in conjunction with the RM tests can be provided by considering the
mean emissions rates for vehicles before and after undergoing the maintenance.
Comparisons of these mean emissions rates for individual maintenance proce-
dures and combinations of maintenance are provided in Table 15. This table
shows that the most dramatic decrease in mean FTP emissions occurs as a result
of maintenance performed prior to Test 3. This maintenance involves correct-
ing maladjusted idle parameters (mixture and speed).
The RM study provides a significant amount of data that is directly use-
ful in assessing the proposed parameter inspection concepts. Even at this
point it becomes obvious that an I/M program need not require that all sys-
tems, components, and parameters that influence emissions be inspected on a
periodic basis. This is particularly relevant to the "high" option discussed
previously, which called for both annual inspection and adjustment of numerous
components that, based on the RM data as well as on conversations with service
personnel, would not be expected to contribute significantly to reducing emis-
sions rates from in-use vehicles. In fact, if failures developed for many of
the components suggested in the high option — particularly in connection with
the carburetor — the result would be driveability related problems, which most
motorists would be likely to have repaired regardless of whether an I/M pro-
gram exists. The RM data tend to support the general experiences of states
43
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TABLE 13. PASS/FAIL RATES FOR THE FOUR FTP TESTS BY POLLUTANT
FOR INDIVIDUAL TESTS
Number and (percent) of vehicles failing
Test No. No. of vehicles —
CO HC NOX At least one
1 300 116 (38.7) 88 (29.3) 86 (28.7) 175 (58.3)
2 113 51 (45.1) 40 (35.4) 27 (23.9) 74 (65.5)
3 143 23 (16.1) 25 (17.5) 46 (32.2) 74 (51.7)
4 83 15 (18.1) 15 (18.1) 37 (44.6) 56 (67.5)
TABLE 14. PASS/FAIL RATES FOR THE FOUR FTP TESTS BY POLLUTANT
FOR THE 300-VEHICLE SAMPLE
Number and (percent) of 300-vehicle sample failing
Test No. No. of vehicles
CO HC NO At least one
x
1 300 116 (38.7) 88 (29.3) 86 (28.7) 175 (58.3)
2 300 51 (17.0) 40 (13.3) 27 (9.0) 74 (24.7)
3 300 23 (7.7) 25 (8.3) 46 (15.3) 74 (24.7)
4 300 15 (5.0) 15 (5.0) 37 (12.3) 56 (18.7)
44
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TABLE 15. COMPARISON OF MEAN FTP EMISSIONS RATES BEFORE AND AFTER
MAINTENANCE ROUTINES
Tests involved
Conditions compared
No. of
Vehicles
Mean FTP emissions rate in gm/mi and
(percent change)
CO
HC
NO
Test 1 only
Tests 1 and 2 only
Tests 1 and 3 only
Tests 1, 2, and 3
Tests 1, 3, and 4
Tests 1, 2, and 4
All vehicles as received 300
After
After
After
After
After
After
After
After
After
After
test
test
test
test
test
test
test
test
test
test
1
2
1
3
2
3
3
4
2
4
113
113
75
75
68
68
72
72
36
36
20.
28.
23.
29.
10.
34.
9.
13.
11.
26.
10.
26
01
20 (-17.2)
13
56 (-63.7)
12
93 (-70.9)
55
98 (-11.6)
82
88 (-59.4)
1.
1.
1.
1.
1.
1.
1.
1.
1.
1.
1.
32
66
48 (-10. £•
68
10 (-34.5)
89
01 (-46.6)
36
22 (-13.2)
69
13 (-33.1)
2.
3.
•>
—
3.
2.
2.
3.
2.
3.
3.
89
20
7*.
;C
10
76
84
45
95
30
09
(-15.3)
(+4.7)
(+2.9)
(-14.5)
(-6.4)
-------
currently operating I/M programs with regard to the types of repairs that
failed vehicles require in order to pass the emissions tests. As an example,
the Portland I/M program, which is currently undergoing extensive analysis by
the U.S. EPA, has developed data concerning the types and costs of repairs
required to bring vehicles that failed the emissions test into compliance with
the standards. Table 16 summarizes the types of repairs made on a sample of
201 vehicles that had failed the idle mode emissions test used by the Portland
program. This table indicates that the primary maintenance procedures included
carburetor adjustments, timing adjustments, and routine tuneups. Many of the
individual items, such as air filters, oil, dwell, points and condenser, and
others are part of the tuneup and do not necessarily reflect required mainte-
nance. The estimated emissions reductions for the failed vehicles (model years
1975-77 only) that subsequently underwent maintenance are shown in Table 17.
Although data are not available concerning the impact of individual maintenance
procedures, the overall impact depicted by Table 17 is quite similar to that
shown in Table 15.
TABLE 16. REPAIRS REQUIRED FOR 201 VEHICLES
FAILING THE PORTLAND I/M STANDARDS
Number
Repair item (and percentage)
of vehicles
requiring maintenance
Spark plugs
Spark plug wires
Points and condenser
Distributor and rotor
Spark timing controls
Carburetor
Choke
Intake system
Air filter
Engine oil
Idle speed
Timing
Dwell
AIR
EGR
PCV
Valves
68
41
40
27
33
170
81
12
68
37
116
111
48
11
11
10
9
(34)
(20)
(20)
(13)
(16)
(85)
(40)
(6)
(34)
(18)
(58)
(55)
(24)
(5)
(5)
(5)
(4)
46
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TABLE 17. FTP EMISSIONS REDUCTIONS FROM FAILED VEHICLES UNDERGOING
MAINTENANCE FOR THE PORTLAND I/M - 1975 THROUGH 1977
VEHICLES ONLY
FTP emissions rate in gm/mi and (percent reduction)
L/onaiL.i.on
Before maintenance
After maintenance
CO
40.9
19.4 (-53)
HC
2.87
1.60 (-44)
NO
X
2.32
2.37 (+2)
The cost data for the Portland study support the general premise that
most of the maintenace required to bring a vehicle into compliance is fairly
minor in nature. The Portland statistics indicate that average repair cost
for the 1975-77 vehicles that failed the test was $23.35; it certainly is not
necessary here to substantiate the fact that $23.35 does not purchase a sig-
nificant amount of automobile repair work. A more detailed summary of repair
costs for the Portland program is provided in Table 18.
TABLE 18. REPAIR COSTS EXPERIENCED IN THE PORTLAND I/M PROGRAM
Repair costs ($)
Model year category Percentiles
Sample mean ($)
25 50 75 90
1972-74
1975-77
1972-77
C Z--_ -=- -3 - —
34.97
24.46
29.47
5
7
6
— a — — -ss-: .: . ---T-. —
11
14
14
41
37
38
78
59
70
Whether or not the same types of repairs would result from a parameter
inspection program depends largely on the inspection items included. It is
likely that a very rigorous inspection program, such as the high option,
would result in additional repair work, hence higher total repair costs.
Considering only those vehicles that failed the emissions measurement inspec-
tion, it could be argued that a parameter inspection might have isolated the
specific deficiency more readily, and therefore reduced the incidence of
unnecessary repair. This is not to say that the total inspection plus main-
tenance costs would be less for the parameter inspection approach.
If the assumption is made that the proposed parameter inspection program
and the RM program are approximately equal in terms of identifying and correc-
ting emissions-related deficiencies, then it might be valid to conclude that
the effectiveness (in terms of emissions-reduction only) of parameter inspec-
tion programs is likely to be at least equal to a tailpipe inspection program
such as Portlands. The basic assumption that the parameter inspection program
and the RM program are equal, however, is undoubtedly not valid, owing
47
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primarily to the fact that RM inspections and maintenance were performed by
highly skilled automotive technicians working without the time constraints
that would be imposed in an I/M program, and utilizing diagnostic equipment
that probably would not be available in most private repair shops and garages.
The RM program may be considered as providing an indication of the upper
limit of effectiveness for a parameter inspection program. In theory, the
parameter inspection approach is potentially as effective in reducing emis-
sions as the tailpipe measurement approach provided that the inspection
routine includes those parameters and components that are most often found
to be in need of repair, replacement, or adjustment in order to pass a tail-
pipe measurement inspection. This assumes, of course, that the quality of
both the inspection and maintenance performed is comparable.
Issues Related to the Quality of Inspections and
Maintenance Performed
The ability of those individuals involved in performing the inspections
and subsequent maintenance to adequately identify and resolve emissions-
related deficiencies is crucial to the success or failure of any I/M program,
regardless of approach. Several factors can be identified that directly
affect the quality of either inspections or maintenance. Several factors
apparently have a very dramatic impact on the quality of inspections and
repairs, as are indicated in the following discussion of a study performed
in California.
Two separate I/M program approaches are currently being used in California.
The first program, which began in 1964, involves the use of licensed private
garages to perform idle-mode emissions testing and limited parameter inspec-
tions of all light-duty vehicles. This program is referred to as the "Blue
Shield" program. A summary of the inspection procedures is provided in
Table 19.
TABLE 19. CALIFORNIA BLUE SHIELD EMISSIONS
INSPECTION PROCEDURES
1. Inspection of external emission
control devices (e.g., air pumps,
exhaust gas recirculation valves)
to ensure that they are installed
and operating properly.
2. Correction of any ignition defects
which are causing engine misfiring.
3. Check and adjustment (if necessary)
of ignition timing, idle air/fuel
mixture, and idle speed.
Source: Reference 12
48
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The second program, which began in March 1979, involves a centralized
approach and is operated for the State by a private contractor. The actual
inspection procedures used are different from those used in the decentralized
program in that only emissions measurements are preformed — no repairs or ad-
justments are included.
The relative effectiveness of the centralized and decentralized approaches
was studied during the early summer months by the California Air Resources
Board (GARB). The intent was to:
• Compare the effectiveness of the two programs
• Identify methods for improving the effectiveness of
each program, and
• Estimate the relative effectiveness of the two programs
in future years.
To assess the private garage program, the following evaluation criteria
were defined.
• Determine the extent to which emissions related defects
are identified
• Determine the change in idle emissions as a result of repairs
or adjustments made at the station
• Determine costs
• Determine the extent of intentional and unintentional failure
to perform inspections properly, and
• Determine impacts of different levels of quality control and
surveillance on inspection effectiveness.
To evaluate the performance of both the centralized and private garage
systems, GARB used vehicles that were specially prepared so that each one
had one or more well-defined, emissions related defect, such as improper air/
fuel ratio, maladjusted ignition timing, or disconnected EGR valve. First,
these vehicles were taken to the inspection stations by a GARB employee who
did not identify himself as such, but merely posed as a motorist who required
an emissions test; this is referred to as the "blind phase." The second phase,
or "open phase," used the same vehicles with the same defects; however, upon
entering the test facility the GARB employee identified himself to the inspector
and explained the actual purpose of the visit. Although not coached by the GARB
employee, the inspectors were aware that they were being monitored closely.
Some basic results of the evaluation are summarized in Table 20.
From Table 20, it can be seen that even under 100 percent monitored condi-
tions when mechanics knew their performance was being evaluated, only 55 percent
of the emissions measurements were properly recorded. It is intuitively obvious
49
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TABLE 20. SUMMARY OF INSPECTION AND REPAIR ACTIVITIES OF PRIVATE GARAGES
Private Garage
Phase I
Blind Phase
Phase II
Open Phase
Centralized
82%
Percentage of time emissions analyzers
were used
Percentage of time emissions data
recorded on the Certificate matched
the levels measured
Percentage of time ignition analyzers
were used
Percentage of time spark timing and rpm
were measured
Percentage of time misadjusted carburetors
were detected and properly adjusted
Percentage of time EGR tampering was
detected and corrected
Percentage of time other defects were
detected and corrected
Percentage oC time unnecessary repairs
were performed
Average time to obtain a Certificate,
including waiting time
Average waiting time before inspection
began
Average cost of inspection and adjustments
Average cost of additional repairs
(per Certificate)
Data available from Northern California survey only.
^Preliminary data.
Source: See Table
94%
100%
46%
43%
31%
6%
7%
36%
2%
28 min
13 min
$14
$1.15
55%
80%
83%
48%
37%
48%
13%
58 min
19 min
$14
$0.40
100%
—
100%
(rpm only)
—
28%
28%
—
19 min
15 min
$11 (inspect
ion only)
$301
50
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that they were being evaluated. Why, then, this large discrepancy? The in-
spectors, it would seem, are either inadequately or improperly trained on
emissions measurements.
It can be assumed that the "blind phase" of the program represents the
typical performance by private garages, while the "open phase" represents the
best the mechanic could do within the time constraints (it should be noted
that, on average, an extra 24 minutes were spent on the inspection when the
mechanic knew he was being watched). From Table 20, it can be seen that under
"normal" circumstances, maladjusted carburetors and malfunctioning EGR devices
were detected and repaired only 6 percent and 7 percent of the time, respec-
tively. Even when the inspectors were aware of being evaluated these items
were correctly identified and repaired only 48 percent and 37 percent of the
time, respectively.
Even under complete surveillance, the garages mechanics detected and cor-
rected carburetor maladjustments only 48 percent of the time. Data from the
Portland (Oregon) Study* identifies the carburetor as the single most repaired/
adjusted item on vehicles failing the State Inspection Test. One could con-
clude, then, that the effectiveness of an I/M program may be severely affected
by the inability of the mechanics to identify carburetor maladjustments.
The frequency of unnecessary repairs increased from 2 percent to 13 per-
cent when inspectors were aware that they were being monitored. This appears
to indicate that the tendency is for mechanics to "try too hard" to correct
problems and that there is a basic inability to determine what repairs actually
should be.
Perhaps the most important measure of the effectiveness of the two types
of I/M programs is the actual reduction in emissions achieved. GARB developed
estimates of the actual emissions reductions resulting from the two program
types currently in operation, and from a private garage option utilizing 100
percent enforcement. These estimates are shown in Table 21.
TABLE 21. ESTIMATES OF EMISSIONS REDUCTIONS FOR VARIOUS I/M PROGRAMS
IN CALIFORNIA
Percent of Estimated initial reduction
H in emissions (percent)
problems identified
Program _ _
CO HC NOX CO HC NOX
Current centralized
Current private garage
90
6
90
6
25
7
32
2
25
2
4
1
Private garage with
100 percent enforcement 48 48 37 17 13
*Portland Study Interim Analysis: Observations on 6-Months of Vehicle
Operation. U.S. Environmental Protection Agency. Emissions Control
Technology Division. January 1979.
51
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The results of the California study are interesting in terms of a
general comparison of centralized and decentralized inspection programs, as
well as in terms of the impact that the quality and motivation of inspectors
can have on a program, regardless of whether it involves parameter inspection
or tailpipe measurement. In terms of effectiveness, it would be extremely
difficult to argue that a decentralized program, be it parameter inspection
or tailpipe measurement, would be. nearly as effective as a centralized program,
primarily because of the much larger problem assicated with ensuring inspec-
tion quality. The problem of ensuring adequate quality control increases as
a function of inspection intensity, therefore one could very easily speculate
regarding the types of problems that would likely be associated with maintain-
ing quality control for a decentralized, high option, parameter inspection
program. Also important is the apparent difficulty that was encountered in
detecting and correcting various deficiencies. This rather poor showing
argues for the use of an emissions test as the final determinant of whether
or not a vehicle has been satisfactorly inspected or repaired. As mentioned
previously, EPA may require emissions measurement as part of any decentralized
1/M program to ensure that inspections and repairs are performed adequately.
Other issues have a potential affect on the quality of either the inspec-
tion or maintenance. One rather significant one is whether or not repairs to
vehicles failing the inspection are allowed to be made at the inspection
facility, and if they are, whether or not any of the repair costs are included
in the basic inspection fee. The ideal program scenario would permit appro-
priate repairs or adjustments to be made as part of the inspection process,
thereby eliminating the need for the motorist to spend additional time obtain-
ing repairs elsewhere and returning for a second inspection. If the program
involves the decentralized approach where inspections are performed in private
garages, the primary problem concerns protecting the public from "over-repair"
by the inspector where the inspection fee is based on the amount of time re-
quired to perform the inspection, and repairs or adjustments are performed at
extra cost. Further, if the inspection fee is set and certain repairs and
adjustments are included in the fee, then the problem becomes one of ensuring
that "under-repair" or "under-inspection" does not occur. For programs
utilizing the centralized approach, the problems mentioned above may of ensur-
ing that "under-repair" or "under-inspection" does not occur. For programs
utilizing the centralized approach, the problems mentioned above may not be as
significant if the program operator neither benefits nor incurs additional
costs as a result of vehicles passing the inspection with or without repairs
or adjustments.
Estimating Emissions Benefits
An important aspect in planning I/M programs is the development of estimates
of the reductions in vehicular emissions that can be expected as a result of the
program. For tailpipe measurement programs, EPA has developed emissions credits
for estimating the reduction in CO and HC as a function of program stringency,
the number of years that the program has been in effect, the calendar year being
considered, and whether a formal mechanics training program is utilized. These
credits cnn be applied directly to mobile source emissions inventories developed
using EPA's MOBILE1 emissions model. Of significance here is that the emission
52
-------
credits are not applicable to programs other than those utilizing tailpipe
measurements. There is a requirement, then, for developing an alternative
method for estimating emissions reductions from parameter inspection programs.
There appear to be two possibilities for satisfying the requirement for
estimating the emissions reductions achievable from a specific parameter inspec-
tion format. First, it may be possible to derive specific estimates based on
existing data regarding the impact of various maintenance procedures on emis-
sions levels. The discussion of the RM and Portland I/M studies certainly
indicates that there may be adequate data available on which preliminary
estimates of the effectiveness of a particular program could be based. The
second possibility, which is perhaps less desirable, is that the state could
conduct a demonstration program designed to evaluate the emissions reduction
potential of a particular program. It is noted that such a study is being
conducted in the State of Texas by the Texas Air Board. Also, the State of
Colorado has been operating a pilot study of a parameter inspection program,
which may serve to adequately demonstrate that program's effectiveness.
It is noted that EPA is providing support to the Texas study owing to the
interest in parameter inspections shown by Texas and other states. The format
of the Texas program is such that the evaluation of its effectiveness would
not provide a sufficient basis for assessing the emissions impacts of the param-
eter inspection proposals considered in this report. With regard to obtaining
similar support for other proposed program alternatives, EPA has indicated that:
"If another state proposed a parameter inspection approach, or some third
approach to I/M altogether, which was (1) so significantly different that
previously gathered field data could not be used to evaluate it, (2) on its
face potentially workable and effective, (3) seriously being considered as an
I/M alternative because it had substantial attractive features not shared by
other alternatives, and (4) implementable on schedule, EPA might support another
field evaluation. EPA's decision would be influenced in part by the availability
of funds and the number of states showing interest."x In the same letter, it
was indicated that a parameter inspection program proposed by the Motor Vehicle
Manufacturers Association, and which is almost identical to the low option con-
sidered in this report, "... does not, in EPA's opinion, satisfy the second of
these four conditions." If the State of Michigan decides to implement a param-
eter inspection program similar to low option, it is likely that it must accept
the entire burden of deriving and substantiating emissions reductions estimates.
SUMMARY
In terms of the emissions reduction potential of any I/M program alter-
native, two primary factors must be considered. The first factor is the
ability to detect deficiencies that contribute to high emissions. The param-
eter inspection approach to I/M is based on a premise that these types of
deficiencies can be detected directly by examining the particular components,
and parameters that affect emissions. There are many individual components,
systems, and parameters that offset emissions although several studies
Letter to Mr. Harry Weaver, Motor Vehicle Manufacturers Association, from
Charles L. Gray, Director Emissions Control Technology Division, U.S. Environ-
mental Protection Agency. 15 November 1979.
53
-------
indicate that only a few specific ones that have a significant impact can be
expected to require periodic maintenance. In terms of the four programs
considered here, the two involving the high options do not appear to be
viable. Notwithstanding the fact that the inspection and adjustment process
is estimated to require approximately two and one-half hours to complete, the
minimal reductions in emissions that can be achieved as a result of performing
many of the more complicated tasks, such as carburetor metering rod adjust-
ments, make this option extremely unattractive. In fact, based only on the
time requirements, it is expected that the high option as it is currently
defined can be eliminated from serious consideration as a viable approach to
I/M.
On the other hand, the low option concept appears to focus on the main-
tenance areas that have the greatest impact on emissions, and which are in
fact the areas that are genrally of primary concern in connection with main-
tenance performed as a result of failing a tailpipe measurement test. The
question, then, is what are the real differences in the tailpipe measurement
and parameter inspection approaches to I/M with regard to the types of main-
tenance expected to result?
The answer to this question lies in the second factor that must be con-
sidered in evaluating emissions reduction potential of an I/M program. This
factor concerns the ability of the repair industry to adequately correct emis-
sions-related problems once they have been identified. Experience gained in
California indicates that there are many problems associated with both the
identification and correction of emissions-related deficiencies, particularly
those involving the carburetor. While this does not guarantee that an equiv-
alent problem would occur in Michigan given the same I/M program, it does
provide a meausre of uncertainty concerning the quality of both inspection
and repair likely. This, in turn, indicates a need for ensuring that both
inspections and repairs are performed properly as part of the overall I/M
program. The most convenient and readily available method for ensuring this
quality is to require emissions measurement as part of the inspection and
reinspection procedures. Undoubtedly, if an emissions test is required, some
will argue that the results should be used to screen vehicles to determine
which ones really need maintenance. This will diminish one of the advantages
that a parameter program may have over a tailpipe measurement program since
not all vehicles would receive maintenance. Also, if an emissions test is
used (it will likely be an idle test) to either screen vehicles or determine
pass/fail, standards will have to be established that must be construed as
being representative of a vehicle's ability to pass the FTP emissions test.
Whether or not any short test correlates well enough to the FTP to adequately
portray the FTP emissions characteristics is a point that is hotly contested
by the automotive and regulatory sectors; in fact, the motivation for suggest-
ing alternative inspection and maintenance concepts, e.g., parameter inspection,
lies primarily in the controversy regarding the appropriateness of short tests,
especially the idle test. The use of a tailpipe measurement step as the pass/
fail determinant transforms the parameter inspection program to a tailpipe
measurement program that utilizes a fixed maintenance routine.
54
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SECTION 4
CONSUMER ISSUES
INTRODUCTION
Effective consumer protection is a critical element for the success of any
I/M program regardless of the specific inspection option selected. In order to
determine the specific consumer protection mechanisms that must be employed, it
is first necessary to examine the consumer issues associated with I/M, and to
determine if and how the selection of a particular inspection type will affect
the impact of the program on the motorists of Michigan.
PROGRAM COST
The first and perhaps most important issue involves program cost. How
much will Michigan motorists be required to pay for inspection? How many
motorists will be required to seek repairs? How much will they be obligated
to spend on repairs? An analysis of the likely fee requirements is presented
in Section 7. As is discussed in Section 7, the potential inspection fees are
quite variable depending on the actual inspection option selected. There is
also substantial variability within any given option. For example, a param-
eter inspection that does not include adjustment of parameters found to be out-
side of manufacturers' specifications will have a lower inspection fee than a
parameter inspection that includes these adjustments. However, a program in-
cluding minor adjustments may reduce some duplication of effort and yield a
lower average repair cost than a program that keeps the inspection and repair
sequences separate. This introduces a few additional issues. Should Michigan
implement an I/M program which results in the lowest inspection fee or the
lowest combined inspection and repair fee? By selecting a program that will
yield the lowest inspection fee, those who fail may be required to pay more
than they would under a program which minimizes the combined inspection and
repair cost. Yet, selection of a program that minimizes the repair cost (i.e.,
combined parameter inspection and adjustment) could mean a higher fee for those
whose vehicles did not need any repairs.
Cost of the inspection process is extremely variable between options. The
most influential variable on the cost of the parameter inspection options eval-
uated in Section 7 is the intensity of the inspection. The high option could
cost the consumer more than four times as much as the low option. This could
effectively eliminate the high option, as defined in this report, from
consideration.
55
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Where the inspections are conducted will also affect the impact of the
program on consumers. Although the inspection costs of program options differ-
ing only in the inspection location (centralized, decentralized) are roughly
equivalent, other consumer issues, discussed below, are quite dependent on this
variable.
CONSUMER CONVENIENCE
Convenience of the program to the public is in a very real sense a cost
issue. In addition to the inspection fee and program related repair bills,
T/M will also "cost" each motorist in terms of vehicle operating expenses (to
get to and from the inspection station), and in personal time, whatever value
each individual places on his or her time. The costs being somewhat unquanti-
fiable due to wide variations in expected travel distances, vehicle operating
costs, and the value of personal time, the issue of convenience of the program
is best handled in a more relative sense.
Decentralized programs can be more convenient than centralized programs
if sufficient facilities are licensed to adequately handle the inspection
demand. Since in a decentralized program there are considerably more inspec-
tion facilities, it is quite certain that the average travel distance to an
inspection facility will be less than in a centralized program. Once a motorist
reaches the Inspection facility, he or she may still have to wait for an inspec-
tion. The duration of this waiting time is dependent on:
• the inspection demand,
• the number of inspection facilities licensed,
• the duration of the inspection, and
• the manner in which the inspections are staggered.
Selection of a decentralized option does not necessarily ensure a more conven-
ient program than a centralized option. If an adequate number of facilities
are licensed, however, the decentralized approach can be more convenient to
more motorists than a similar program utilizing a centralized approach. It
should be noted that certain economic factors, discussed in detail in Section 7,
also influence the number of inspection facilities that can participate in the
program.
The duration of the inspection is also an important convenience issue.
The high option parameter inspection, for example, may take from l^j to 5 hours
to perform. For many motorists, this would mean having to leave the vehicle
at the inspection facility. Regardless of how much value each motorist places
on his or her personal time, an inspection of this length would certainly be
viewed as an inconvenience. A summary of the inspection times, excluding
waiting time is provided in Table 22.
56
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TABLE 22. INSPECTION TIME REQUIREMENTS3
Total
Test mode performance Locale
time (minutes)
Tailpipe measurement (idle centralized) 4-5 Oregon
Tailpipe measurement (loaded centralized) 6-8 Arizona, California
Safety and idle test (centralized) 4-6 Cincinnati, Ohio;
New Jersey
Idle test and parameter adjustments 20-25 Nevada
(decentralized)
Low option parameter inspection 30 Estimate
High option parameter inspection 90-300 Estimate
Does not include waiting time.
Source: Kincannon, B.F. et al. Viable Alternative Types of Inspection and
Maintenance Programs for St. Louis prepared for U.S. EPA, GCA-TR-77-03-G,
GCA Corporation, GCA/Technology Division, Bedford, Massachusetts. June 1977.
From Table 21, it appears that either the idle or loaded mode tailpipe tests
can be performed in less time than a parameter inspection. It should be noted,
however, that the parameter inspection process could also include minor adjust-
ments. The same concept applies to a decentralized tailpipe measurement pro-
gram as well. A centralized parameter inspection that includes adjustments
can also reduce the I/M process to one stop, however, allowing minor adjust-
ments to be performed by a single public or private entity may adversely
affect the repair Industry. This is discussed in greater detail in Section 5.
This brings to light an additional consumer convenience issue. For whom
should the convenience of I/M be maximized — those whose vehicles will need
repairs to meet the requirements or those whose vehicles have been properly
maintained? An I/M option that enables inspection and maintenance at one stop
can be much more convenient for the motorist whose vehicle requires repairs,
even if the inspection time is longer than in a two-stop approach. Alterna-
tively, the motorist whose vehicle will pass the inspection, will find as most
convenient the option which will have the shortest total inspection time
(including travel time, waiting time and inspection time). Permitting inspec-
tion and maintenance at the same stop may maximize convenience for many motor-
ists, particularly those who will fail the inspection. However, if the inspec-
tor stands to benefit from one particular inspection result, a conflict of
interest may occur.
57
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CONFLICT OF INTEREST
Any of the centralized options enable a one-stop approach to I/M. Simi-
larly, a centralized parameter inspection option is capable of providing the
same convenience if adjustments are included in the inspection. Regardless
of whether the price of adjustments/repairs is included in the inspection fee
or a separate charge is made, a conflict of interest will exist. In the case
of one price covering inspection and repair, the inspector will benefit (saved
time) from minimizing repair time or by determining that the vehicle "passes"
without adjustments or repairs. Conversely, spending a significant amount of
time on a vehicle will result in a financial loss if more effort was spent on
the vehicle than compensated for in the inspection fee. On the other hand, if
costs for inspection and repair are kept separate, the inspector could stand
to benefit from failing a vehicle and offering repairs the vehicle may not
need. In either of these two examples a potential conflict of interest exists -
the inspector (or his/her employer) stands to benefit more from one test result
than another. This can act to make the inspector biased and, if unchecked,
could lead to a consumer ripoff.
CONSUMER PROTECTION
Regardless of the I/M option selected, there will likely be some adverse
impact for certain motorists at least on consumer issues. Through an effective
consumer protection program, these impacts can be reduced and the potential for
consumer ripoffs diminished. One important consumer protection measure is a
sound quality assurance program. Since quality assurance is also a repair
industry impact, it is discussed in detail in Section 5.
Consumer protection measures can be divided into two general categories.
First, there are specific procedures that can be employed to deal with con-
sumer complaints as they occur. These include consumer "hotlines" and com-
plnints investigation. Neither the need for, nor the format of these types
of programs will vary significantly from a tailpipe emissions measurement pro-
gram to a parameter inspection.
The second type of consumer protection involves certain features built
Into the program that directly or indirectly protect consumers from potential
inequities or abuses. These include state motor vehicle repair regulations,
repair cost ceilings, waivers and exemptions, repair (or inspection) facility
and/or mechanic licensing or certification, and basic warranty protection
offered under the Clean Air Act. The applicability, nature, and scope of these
particular measures are more dependent on the type of I/M program implemented.
The discussion presented here focuses on the specific consumer protection
issues that can be expected to vary with the type of I/M program implemented.
This being the case, then, only the issues that fall into the second of the two
categories are considered.
Inspection/Repair Cost Limits
To prevent T/M from becoming an excessive financial burden, particularly
on vehicle owners in lower and fixed income brackets, a minimum cost ceiling
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Is often placed on the amount of money a vehicle owner Is obligated to spend
on the repair process. Although this concept applies to both tailpipe and
parameter inspection approaches, the specific provisions may vary depending on
the test type selected. In either case, however, it should be clearly stated
that vehicle owners should in no way be compelled or encouraged to limit their
maintenance expenditures. For those who can afford the extra costs, or who
simply desire to minimize their contribution to the pollution problem, there
should be strong encouragement to do so.
In either the case of a tailpipe test or a parameter inspection, a consumer-
conscious I/M program will incorporate one of two types of repair (or adjustment)
cost limits — an absolute dollar limit, or a sliding scale limit based on the
value of the vehicle, along with a preset, standard inspection cost. The first
approach involves setting a fixed upper limit that applies to all vehicles,
regardless of age, condition, or resale value. Programs with this type of
limit generally require maximum expenditures of from $50 to $100 depending on
local repair shop rates. The second type of limit, which in theory is more
equitable than the first, involves a maximum required expenditure based on the
vehicle's value as determined by a standard, accepted reference such as the
used car "Blue Book" of average retail prices. Parameter inspection programs
might also limit required repairs to only a specified set of parameters. Again,
however, the program should not discourage detection and correction of other
emission-related problems; rather, motorists should be informed of both the
required corrective actions as well as other optional measures that could im-
prove the overall vehicle operation.
Other related consumer protection measures for the parameter inspection
approach include the development of specific repair and adjustment procedures
that would represent the maximum requirement, and provide the motorist a list
of "reasonable rates" for various adjustments or repairs that may be required.
In a combined parameter inspection and adjustment program, a standard,
uniform fee may be developed for all inspection facilities to cover the inspec-
tion and adjustment costs. The advantage of this approach is that the motorists
will know exactly what the inspection/adjustment will cost. One disadvantage
of combined parameter inspection and adjustment is that motorists who have
properly maintained their vehicles such that they are within specifications,
would be required to pay the same amount for the inspection as the motorist
who has not maintained his vehicle. As an incentive, the State could offer
waivers to motorists who present proof of having recently had their vehicles
undergo a complete tuneup (e.g., itemized repair bill within so many days prior
to the test).
Licensing and Certification Programs
Licensing or certification of repair shops and mechanics are mechanisms
for ensuring that repairs are performed adequately and at a reasonable cost
to the consumer. As such, they are also important in the context of consumer
protection. The type and degree of regulation over private industry, such as
repair shops, by state government is a sensitive issue, but given the need to
ensure protection of the consumer and the adequacy of repair, some type of
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interaction or influence on the repair industry practices is crucial. A pre-
requisite for certification of a repair facility could be employing one or
more mechanics who have attended a training program in emission control. 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 possitive attitude toward emission control. The selec-
tion of a separated parameter inspection and repair approach necessitates that
inspectors are trained as mechanics; in a combined approach, of course, the
inspectors are mechanics. This issue is discussed in greater detail in Sec-
tion 5, Impacts on the Automobile Repair Industry.
Clean Air Act 207 (a) and (b) Warranty Provisions
The ability of in-use vehicles to maintain the emission levels for which
they were designed depends largely on the integrity of the emission control
components with which they are equipped. Federal requirements related to emis-
sions control from new motor vehicles also considers the issue of durability
and long-term effectiveness of emission control devices used. In fact, the
Clean Air Act Amendments of 1977 include provisions for warranty protection of
various emissions-related components; these provisions are discussed in the
following paragraphs.
The U.S. Environmental Protection Agency considers the emission performance
warranty, along with inspection/maintenance, as primary strategies for ensuring
the in-use motor vehicles continue to meet the emission standards for which they
were designed.13 The 207(a) warranty provision requires all vehicle manufac-
turers to warrant their vehicles to be free from defects in materials and work-
manship that will cause the vehicle to fail to meet applicable emission-related
regulations. The 207(b) warranty regulations require vehicle manufacturers to
warrant the emission control devices and systems for each new vehicle such that
if the vehicle, although maintained and used in accordance with manufacturer's
instructions, fails an approved short emission test, the cost of repairing the
emission control devices or systems would be borne by the vehicle manufacturer.
Section 207(a) is in two parts, as shown below.
"(1) Effective with respect to vehicles and engines manufactured.
In model years beginning more than 60 days after the date of enact-
ment of the Clean Air Amendments of 1970, the manufacturer of each
new vehicle and new motor vehicle engine shall warrant to the ulti-
mate purchaser and each subsequent purchaser that such vehicle or
engine is (a) designed, built, and equipped so as to conform at the
time of sale with applicable regulations under section 202, and (b)
free from defects in materials and workmanship which cause such
vehicle or engine to fail to conform with applicable regulations
for its useful life (as determined under section 202(d))."
"(2) In the case of a motor vehicle part or motor vehicle engine
part, the manufacturer or rebuilder of such part may certify that
use of such part will not result in a failure of the vehicle or
engine to comply with emission standards promulgated under section
202. Such certification shall be made only under such regulations
as may be promulgated by the administrator to carry out the purposes
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of subsection (b). The administrator shall promulgate such regula-
tions no later than two years following the date of the enactment
of this paragraph."
According to Section 207(a) (1), a vehicle owner may initiate a warranty
claim under which the motor vehicle manufacturer is obligated to replace any
defective part or component of a new motor vehicle or engine which causes it
to fall to conform with application regulations for its useful life. Its use-
ful life under Section 202(d) is 50,000 miles or 5 years, whichever comes first.
Unlike Section 207(b), there is no distinction, with regard to 207(a),
among the various emission control components. Of significant concern is use
of the term "defective." According to the U.S. EPA,14 the term "defective"
refers to any part or component, which affects emissions, that has failed
during the useful life of the vehicle, provided that (1) the vehicle has been
maintained according to the manufacturer's written instructions, and (2) the
vehicle has been used in a normal manner.
Section 207(a) (1) and Paramater Inspection—
The important question concerning Section 207(a) (1) is whether or not a
motor vehicle would have to fail an approved emissions test or participate in
an I/M program in order for the vehicle owner to establish a valid claim under
the warranty. EPA officials have indicated that there is no relationship be-
tween I/M or an emissions test and 207(a)(I).15 It is only necessary to estab-
lish that a part is defective, given of course that proper maintenance has been
performed and the vehicle received normal use. If the defective part is dis-
covered in the course of a parameter inspection, then the claim is valid.
The same situation holds if the defective part is discovered independently of
any emissions test. In other words, the vehicle owner may file a claim for
any defective emission related part, component, or system, whether or not the
vehicle fails an I/M test, or is even subject to I/M.
Emission Control System Components Covered by Section 207 (b) Warranty—
During the initial period of 24,000 miles or 24 months the 207(b) warranty
covers any system, assembly or device, or component thereof which affects emis-
sions. From this period until the warranty expires at 50,000 miles or 5 years,
the coverage is somewhat more limited. It includes "a catalytic converter,
thermal reactor or other component installed in or on a vehicle for the sole
or primary purpose of reducing emissions, which was not in general use prior
to the model year 1968." This more limited coverage does include modification
to parts (other than calibration changes) made for the sole or primary purpose
of reducing motor vehicle emissions. Many components have been on a vehicle
prior to 1968 or may have an additional purpose other than control of emissions
but to exclude these components would defeat the purpose of the warranty since
these components, as modified, may be an integral part of the emission system.
Examples of such dual purpose components covered for the entire 50,000 or 5-
year period would be a dual diaphragm vacuum advance unit on a distributor,
or a quick release electric assist choke on a carburetor. However, a general
failure of a distributor or a carburetor would not be covered after the 24,000
mile or 24-month period because these components were in general use prior to
1968 and are not devices used solely or primarily for the purposes of control-
ling emissions.
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Full implementation of 207(b) requires a number of determinations by the
EPA Administrator, with regard to 207(b) (1), and 207(b) (2). The Administrator
has made all of the determinations, including the existence of "identifiable
short tests, reasonably capable of being correlated with the Federal Test Pro-
cedure," as specified by 40 CFR Part 86, Subpart B. EPA anticipates final
promulgation of regulations establishing at least three of the short tests
listed below, as well as promulgation of the 207(b) warranty, prior to 1981.
• Idle test
• Federal three-mode test
• Clayton key-mode test
• Federal short cycle
• Now York/New Jersey short cycle
Vehicles Covered by 207(b)—
207(b) will be applicable only to vehicles manufactured in model years
subsequent to final EPA promulgation of the regulations establishing the war-
ranty .'ind .short test correlation. It is expected that 1981 and later light-
duty vehicles will be covered by these regulations. EPA also anticipates that
appropriate short tests will eventually be developed for other types of vehicles,
so that the warranty provisions will eventually extend to include all vehicle
types.7
207(b) and Parameter Testing—
Unlike the 207(a) warranty, 207(b) establishes a close relationship be-
tween the T/M program and the warranty claim itself. Specifically, 207(b)
requires as a prerequisite to a valid claim, that the vehicle must have failed
an approved short test, which would set into motion a procedure bringing about
a sanction or action, such as the withholding of vehicle registration.
Currently, parameter inspection is not being considered in the process of
identifying short tests that correlate with the FTP. However, future inclusion
of parameter test(s) has not been ruled out. As discussed in more detail else-
where Ln this study, EPA plans to investigate various parameter inspection
options in a demonstration project scheduled to begin January 1, 1980. Un-
fortunately, it is not expected that the Texas Program will generate sufficient
data to make an assessment of the degrees of correlation between parameter in-
spection and the FTP emissions, prior to the end of calendar year 1980. De-
pending on the outcome of the "Texas Study," an investigation of the applica-
bility of 207(b) will be made at that time.
In the low option, except for a functional check of the EGR valve, the
remaining portions of the inspection apply primarily to misadjusted, improperly
maintained, or tampered with components. If the inspection process is limited
to these types of checks, warantee claims under 207(b) could be restricted to
covering only KGR valves. However, if the process is such that, if while
setting air/fuel ratio, for example, a defective carburetor component was de-
tected and the motorist required to have it repaired, 207(b) would apply pro-
vided, of course, all of the other previously discussed criterion were met.
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The high option, being more rigorous and involving actually examining the
functionability of carburetor and ignition system components, would likely
result in a greater frequency of 207(b) claims; provided defects detected are
not tampering related.
Presumably, neither parameter test would enable warranty replacement of
catalytic converters, perhaps the single most important emission control device,
although valid claims for replacement of defective converters could be made
under 207(a). It is unlikely, however, that in the absence of a loaded-mode
emissions measurement test, or a parameter test that included a catalytic
converter "functional" test, a nonfunctioning converter would ever be detected.
Whether or not the parameter inspection concept would enable warranty
claims under 207(b) is not entirely clear at this time. Generally, in order
to be acceptable in terms of indicating the need for 207(b) related warranty
repairs, the method must prove to the satisfaction of EPA that it is able to
indicate that the emissions from the vehicle are outside the FTP standard and
that the actual estimate of emissions established by the method correlate well
with FTP emissions.
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SECTION 5
IMPACTS ON THE AUTOMOTIVE REPAIR INDUSTRY
INTRODUCTION
Regardless of the specific program format implemented, I/M will have a
significant impact on all facets of the automotive repair industry. Implementa-
tion of the I/M will result in an increased demand for replacement parts, re-
pairs, and qualified mechanics. Since the magnitude of the program in terms of
geographic coverage, vehicle types, and model years affected, etc., remain unde-
fined at this time, a quantitative assessment of the impact of I/M on the auto-
motive repair industry cannot be presented. Alternatively, the impacts of I/M
in general and the relative impacts of parameter inspections versus tailpipe
inspections can be addressed in a qualitative sense.
DEMAND FOR MECHANICS
Perhaps the most significant impact on the automotive repair industry
involves the necessary increase in the supply of qualified mechanics to meet
the I/M created demand. The national mechanic-to-vehicle ratio has been
declining significantly in the past few decades. In 1950 there was one mechanic
for every 73 vehicles, nationwide. By 1975 that ratio decreased to only one
mechanic for every 146 vehicles. In addition to increases in the number of
vehicles that will require repairs, increasingly complex emission control sys-
tems may extend repair times on vehicles as well.
Wlillo all of the I/M options will increase the demand for mechanics, the
extent of this Increase is dependent, to a certain extent, on the specific pro-
gram option selected and will affect not only the demand for mechanics but the
skill level of mechanics (or inspectors) as well. The discussion here will be
limited to the demand requirements. A discussion of the skill level and, thus,
training requirements is presented In a separate subsection.
Of the options under consideration, the centralized tailpipe measurement
approach will result in the lowest increase in demand for mechanics. The
inspection and repair sequences are separated in this option, and the inspectors
need not be mechanics. The repair industry will be involved only in the repair
process and only for those vehicles that fail (probably 20 to 30 percent). For
a hypothetical 1 million vehicle population, this equates to approximately
250,600 vehicles. Based on the average repair costs experienced in other states
an average repair time of 20 minutes can be assumed. This equates to approxi-
mately 83,000 mechanic hours.
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In a decentralized tailpipe approach, the demand for mechanics will be
greater than in the centralized approach. The inspection and repair sequences
will likely be combined in this approach, therefore the inspection requirements
will be filled by mechanics. Again using a hypothetical million vehicles the
requirement would be for the same 83,000 mechanic hours for repairs plus 1
million inspections at about 10 minutes per inspection (approximately 157,000
hours); a total of about 250,000 mechanic hours or about three times the demand
for the centralized option.
The inspection and repair components are assumed combined in a parameter
inspection approach. Since inspectors would essentially have to be mechanics
in a parameter approach, regardless of whether the program is conducted in
centralized or decentralized locations, the demand for mechanics will be approx-
imately equivalent. For the low option, a 30 minute inspection/adjustment time
is assumed. Again using the hypothetical 1 million vehicle population, this
equates to 500,000 mechanic hours or, in relative sense, about twice the
demand as for a decentralized tailpipe inspection.
For the high option, an average of 2% hours per vehicle must be expended.
For a 1 million vehicle population, this equates to 2,500,000 mechanic hours;
10 times the demand for the low option and 30 times the demand under a cen-
tralized tailpipe option.
DISTRIBUTION OF I/M CREATED WORKLOAD
While all of the I/M options evaluated will create business for the repair
industry, the distribution of this workload is dependent on the specific pro-
gram format implemented. A discussion of the relative impacts on the distribu-
tion of the I/M created workload associated with each potential program config-
uration is presented in the following paragraphs.
Tailpipe Inspections
In a centralized tailpipe measurement approach, the repair industry is
effectively kept separate from the inspection process and engages only in the
repair business generated by the program. Since no repair establishment is
connected with the inspection process, all entities will compete for repair
business. The experienced repair work distribution for the Portland, Oregon
program is presented in Table 23.
TABLE 23. DISTRIBUTION OF I/M-RELATED REPAIR WORK -
PORTLAND, OREGON
[)j s t r i but inn of re pa i r s
(pcrc ent of veh ic 1 eiii r,ir,ii-e til
'•'•tv I .11 inn 17
nwm-l ,i|
Ulh.T ]
Ni> nm [ nc .-n.im <• l
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Implementation of a decentralized tailpipe measurement program could mean
that selected repair industry entities would be performing both inspections as
well as most repairs. Despite allowing motorists whose vehicles fail the inspec-
tion to seek repairs anywhere, many such motorists will seek those repairs at
the same facility where the inspection was performed for convenience ("one-
stop") . Under this scenario, State-selected facilities will be realizing most
of the program created business. This introduces another issue. Will the State
allow all qualified facilities to perform the inspections or limit the number of
stations? Allowing all stations to participate will ensure a more equal dis-
tribution of the additional workload, however, as discussed in the cost analy-
sis in Section 7, increasing the participation rate beyond a certain point will
increase the fee to an unacceptable level. Additionally, a much more intensive
quality assurance and consumer protection effort would be required. By limit-
ing the participation in the program, the created workload will be dispropor-
tionately allotted to certain entities.
Parameter Inspections
The selection of a centralized parameter approach (State- or contractor-
run) could have a serious economic impact on the repair industry. Since some
repairs (adjustments) will likely be included in a parameter inspection sce-
nario, many motorists could actually substitute the inspection for annual minor
tuneups. This could seriously reduce tuneup business in the repair industry.
This also raises an important legal issue. In the case of a State-run central-
ized program, are there legal obstacles to allowing State inspectors to adjust
vehicles? The State would likely encounter serious adverse reaction from
repair industry groups regardless of the choice of a contract- or State-
operated program. A State-operated program could shift a lot of business from
the private to the public sector. A contractor-operated program would likely
be viewed by the industry as the State allowing a single entity to monopolize
the minor tuneup business. To allow a single entity, either private or public,
to control this entire market will not likely be viewed favorably by the private
garage industry in Michigan. Most likely the industry will view this as an
infringement on its business. Selecting this type of program could jeopardize
I/M in Michigan since it provides the most disproportionate allotment of I/M
created business of all of the options evaluated.
The problem of disproportionate allotment of business could be more acute
with a decentralized parameter inspection approach than with a decentralized
tailpipe approach since, logically, adjustments would be included with the
inspection. In essence, this would allot all of the inspections and nearly
all of the repairs to the selected repair shops. Since parameter adjustments
may be substituted for regular minor tuneups by some motorists, stations not
selected to participate in the program could actually lose existing work in
addition to not receiving any of the created business.
MECHANICS TRAINING REQUIREMENTS
The subject orientation of mechanic training programs and certification
tests should not vary considerably between a parameter inspection program and
one that incorporates tailpipe testing. Except, under a parameter inspection
approach, inspectors will essentially have to be trained as mechanics; whereas
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in a tailpipe approach, the inspectors only need to be proficient at measuring
emission levels properly since the inspection would not require determination
of the reason(s) why a vehicle is failing, rather a straightforward determina-
tion of pass/fail will be made based on emission levels alone. One advantage
of a parameter inspection, in this regard, is that to a certain degree the
problem diagnosis responsibility occurs at the inspection facility. This will
become more important as emission control technology advances since on future
vehicles diagnosing causes for problems will be more difficult than actually
solving the problem once it is identified.
By inspecting parameters and functionally testing emission control com-
ponents, the problems are attacked directly; tailpipe testing on the other hand
leaves detection of the problem up to the mechanic who may be separate from the
inspection phase of I/M.
In a relative sense that "high" option will demand more comprehensive
mechanics training. While mechanics should be proficient at repairing all of
the additional items in the high option anyway, investigations into such com-
ponents as interfaced carburetor system parts, for example, would occur in the
low option as repairs (i.e., if air/fuel ratio cannot be properly adjusted,
then the repair mechanic will investigate float levels, metering rod, etc.).
Since these components are not part of the routine "low" option investigations
the mechanic can generally take more time to check diagrams and specifications
in repairing these items; where in the "high" option, these investigations are
part of the inspection and the inspector should be very familiar with most con-
figurations and will not have much time to look up information.
There are 29 Community Colleges and an approximately equal number of Career
Centers in Michigan which currently offer some form of mechanic training.
Michigan also has the good fortune of being the home location of the major auto
producers. As a result, mechanics can benefit from expertise available through
these sources as well. One potential consumer protection benefit of any I/M
scenario is that it ensures increased interfacing of the manufacturers, the
repair industry, and the State by necessity; without this close cooperation,
serious problems may surface which could endanger the existence of the program.
The increased demand for mechanics may serve as a mechanism to drive up
wage rates for those who are qualified. The extent of this supply/demand prob-
lem will depend on the ability of the industry to fill positions created by the
increased demand. 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 shops for some initial lag period, particularly in the
case of a program that separates the inspection and repair components. The
tight supply situation, if unchecked, could lead to more frequent overcharging
until the increased demand is met with additional mechanics.
In addition to recruiting and training new mechanics, existing mechanics
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 it may act accordingly. The amount
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of mechanics' training that must be made available is directly dependent on
the increase in the demand for mechanics, which was discussed previously.
LICENSING OR CERTIFICATION OF REPAIR SHOPS AND MECHANICS
Licensing or certification of repair shops and mechanics are mechanisms
for ensuring that repairs are performed 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. The selection of a separated parameter in-
spection and adjustment approach necessitates that inspectors are trained as
mechanics. (in a combined approach, of course, the inspectors are mechanics.)
Most 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 closer
supervision is very important for both consumer protection and quality assurance
considerations.
Since January 1978, all repair facilities in Michigan have been required
to employ at least one mechanic who has received certification in each area
of automotive repair the facility deals in (brakes, tuneup, transmission, etc.).
Beginning January 1, 1981, all mechanics must be certified in the specific
area he performs repairs in. Mechanics who do not pass the State certification
test, may work as a mechanic trainee for a maximum of 2 years, but only under
supervision of a certified mechanic. Additionally, the mechanic's signature
and certification number must appear on every work order. These stringent
regulations are enforced through constant surveillance by State authorities,
who also investigate for overcharging, unnecessary repairs, etc.
The existence of this State Certification system will be a significant
asset for any I/M program Michigan implements. It can also serve as the basic
framework Cor other adjunctive programs such as quality assurance, mechanics
training, complaints investigation, etc.
Currently, there is no special classification for emission control systems,
however, there is a general "tuneup" category which covers much of this mate-
rial. As emission control technology development continues, the content of
the certification test for tuneups can, or course, be continuously updated.
The very rapid advancement of this technology may make frequent reexamination
a necessary requirement.
QUALITY ASSURANCE
One of the most important elements crucial to the success of any I/M pro-
gram is a sound, effective quality assurance program. Quality assurance is,
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in effect, a consumer protection measure. For any of the options evaluated
here, motorists will benefit if the inspections are conducted in a uniform
manner with properly calibrated and maintained equipment. Quality assurance
differs from consumer protection measures in that the latter refers to features
and rules built into the program for the purpose of protecting consumers from
potential abuses, while quality assurance refers to measures taken to ensure
that inspections are properly conducted, data collected is reliable, test
results are repeatable, etc. Accurate, reliable information must be generated
to correctly analyze the impact of the program, in terms of meeting the objec-
tives of I/M (reduced vehicular emissions, fuel usage, etc.) and maintaining
public interest in the program. Enforcement of the program will be more dif-
ficult, if not impossible, if the public perceives the program as haphazard or
arbitrary. The format Michigan selects for its program will, to a large extent,
determine what types of quality assurance practices will be required to ensure
the success of I/M. As discussed in the following paragraphs, the concept of
a parameter inspection introduces some difficult, though not insurmountable,
quality assurance problems. For comparison, a discussion of currently utilized
quality assurance measures is in order.
^Quality Assurance Techniques £or Tailpipe Measurement I/M Programs
Centralized Programs—
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. A program uti-
lizing a network of centralized inspection stations will facilitate the
standardization and repeatibility of tests. Such a system contains a relatively
small number of high quality exhaust gas emission analyzers that can be closely
monitored. It is technically feasible and desirable to automate the testing
sequence in this situation, tieing all operatings associated with the test into
a central computer system.
An automated test sequence interfaces control of the emission analyzer and
dynamometer (in the case of a loaded-mode test) with a computer routine, thus
removing perhaps the largest cause of test result variability, human error.
This approach enables the limitation of human involvement to: (1) identifying
the vehicle to the computer by means of entering the vehicle identification
number (VIN) and registration information into an input/output device (such as
a "CRT" or T.V. screen type computer terminal), (2) manually inserting the
analyzer probe(s) into the tailpipe(s) of the vehicle, and (3) operating the
vehicle on the dynamometer (in the case of a loaded-mode test). The computer
routine can monitor the "load" being applied by the dynamometer and automatically
lake and evaluate exhaust gas samples at the appropriate times. The sample
results can then be integrated by the computer and compared with previously
established test standards stored in the computer and pass/fail decisions can
be automatically determined.
Once such a system has been installed and its software has been found to
bf accurate and reliable, a series of relatively simple checks can be made to
ensure continued proper, reliable operation. For example, analyzers must be
calibrated periodically. This procedure is straightforward; by analyzing a
8ft of precisely-blended "calibration gases" and comparing the analyzers readings
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with the actual known concentrations, the analyzer's accuracy can be easily
determined and, if necessary, adjustments can automatically be made. With an
automated system, analyzers can be calibrated regularly as requently as desired
(usually hourly) to minimize the possibility of inaccuracies resulting from
equipment malfunction.
The data from each inspection station can be stored on computer tapes that
can subsequently be analyzed to determine if correct cut-off points are being
vised; also, failure rates can be analyzed to detect patterns indicative of in-
correct procedures at a particular lane, by a particular inspector or to uncover
unintentional biases or improperly determined cutpoints with respect to a par-
ticular year/class/make of vehicle.
One practice which falls into both the quality assurance and consumer
protection categories, involves the retesting of vehicles which failed inspec-
tion and received repairs. Data on repair costs, types of repairs performed,
and the name or identification number of the repair facility can be recorded.
From this data, facilities overcharging motorists or performing excessive,
inappropriate, or insufficient repairs can easily be identified. Also, the
reduction in emission levels can be quantified by comparing the results with
those of the previous test.
Periodic inspections can be made by the State to verify the accuracy of
data generated at the centralized facilities. This is particularly true in
the case of a contractor-operated program. In addition to regular checks on
equipment condition and accuracy, the State may perform unannounced checks to
verify that proper procedures are being followed.
Experience to date shows that the operation of automated centralized
systems is relatively trouble-free, and that downtime resulting from equipment
malfunction is minimal. The important point to note here, is that a computerized,
automated data handling system is most suited to a centralized, tailpipe measure-
ment program and allows for easy access of important information which is crucial
for quality assurance checks.
Not all centralized programs in operation today utilize automated comput-
erized data handling procedures, but do provide for quality assurance checking.
Notably, the State of New Jersey and the City of Cincinnati both have centralized
tailpipe measurement programs, but emission levels and pass/fail decisions are
recorded manually. Quality assurance studies can still be made, but involve
extra costs including keypunching time, etc. Also the quality of the data is
assumed somewhat lower than with an automated system as human errors can occur
when: (1) the inspector reads the emission levels, (2) determines the pass/
fail status, (3) records the information, and also, (4) when the keypuncher
codes the information.
Decentralized Tailpipe Programs—
Currently, decentralized I/M programs which employ tailpipe testing do
not easily lend themselves to computerized, automated data recording due to
prohibitively high costs of such equipment. Discussions with representatives
of garage-type emission analyzer manufacturers, however, indicate that in the
very near future, garage level analyzers will be capable of producing a hard
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copy record of the emission level readings in the form of a punched computer
(IBM) card. This will contribute a great deal to the minimization of human
error in a decentralized approach, but this option will likely add almost 50
percent to the cost of the analyzer.
By the nature of the decentralized approach, quality assurance practices
such as equipment calibration and inspection procedure checks will be more
costly. The reasons for this are two-fold. First, if a decentralized system
is selected, there will be considerably more facilities to keep track of than
in the case of a centralized program. Additionally, since the decentralized
approach utilizes repair shops as the inspection facilities, the State must
ensure against the possibility of intentional errors or biases in pass/fail
determinations and data recording due to the conflict of interests associated
with having the same facilities conducting both inspections and repairs. It
is also less likely that stations overcharging motorists or performing unneces-
sary repairs could be easily identified as the data will be supplied by these
stations, enabling those who abuse the system to "cover their own tracks." As
a result of this abuse potential, undercover visits will likely be a require-
ment if the State is to ensure that the desired emission reductions are being
achieved, and that consumers are protected from unscrupulous mechanics. In the
case of a contractor-operated centralized program, the conflict of interest
problem can be addressed in the I/M legislation through provision of a clause
that prohibits the contractor from engaging in any other type of business that
leads to a conflict of interest. This will ensure that the contractor will not
be in a position to profit from one test result but not another.
Quality Assurance Techniques for Parameter Inspections
As previously discussed, combining parameter inspections with adjustments
dictates, for all practical purposes, that the inspection process be conducted
in a network of private repair establishments. Since either the "high" or "low"
option parameter approaches involve checking engine parameter adjustments, it
is doubtful that "hard copy" data, in the form of a punched computer card, could
be provided, rather it is most likely that data would be manually recorded. The
same limitations and consequences that applied to the tailpipe measurement in-
spection in private garages apply here. The data processing will be more costly,
and the quality of the data will likely be less than in an automatic recording
approach. As in the previously discussed private garage tailpipe approach,
considerable surveillance by the State will be required to ensure a high quality
program.
Unlike a tailpipe measurement approach, a parameter inspection involves a
mechanic's determination of whether or not particular parameters are set to
specification. While tailpipe measurement involves an objective determination
of whether or not the concentrations of emissions are below a certain level,
the parameters inspection involves a subjective judgment on the part of the
mechanic. To assure quality, reliable, and most important, repeatable results
some uniformity must be assured. Perhaps the most effective method to assure
that proper inspection procedures are being carried out involves state surveil-
lance. Undercover inspectors with vehicles known to have or not have maladjust-
ments, defective components, etc., can seek inspections and monitor the
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inspection process and determine if a particular repair establishment (or
inspector) is doing an adequate job.
One problem that is common to all parameter inspection approaches is that
measuring program effectiveness in terms of emission reductions will be extremely
difficult if not altogether impossible. Without actually measuring emission
levels, there will be no assurance that the I/M program is actually meeting its
objective of reducing vehicular emissions. To ensure that the program is in
fact bringing about a significant emission reduction, either "before and after"
emission measurements would have to made on all vehicles, as in Nevada, or a
random sample of vehicles would have to be checked.
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SECTION 6
PROGRAM ADMINISTRATION REQUIREMENTS
INTRODUCTION
Program administration refers to the organizational and personnel struc-
ture necessary to implement, support, and maintain the I/M program. The ad-
ministrative requirements, in terms of the specific tasks and responsibilities
involved, will not vary significantly between an I/M program incorporating
tailpipe testing and one involving parameter inspections. However, there are
differences in the number of individuals required to perform specific tasks.
The choice of a decentralized rather than a centralized program, for example,
will necessitate more consumer protection/quality assurance investigators
since in decentralized approaches, the State will have far more inspection
facilities to monitor than in a centralized approach. Selection of the high
option parameter inspection instead of the low option will result in similar
increases in the administrative staff.
A suggested administrative structure is presented in the following para-
graphs. Since the nature of Michigan's I/M program, in terms of geographic
coverage and specific vehicles included in the program is still undefined, the
exact number of individuals required cannot be specified here. Alternatively,
the administrative positions required were identified and where option-specific
differences occur, they are discussed in a relative sense. While most of the
personnel described here would likely be employed directly by the State or con-
tractor (if applicable), it is not likely that all positions would require new
personnel; rather, it is quite probable that existing State personnel could
assume many of the responsibilities. The positions discussed here are divided
into State: and contractor personnel for centralized approaches; all positions
fit into the State category for decentralized or State-run programs. Those
positions not applicable for certain options are identified as such in the
position descriptions.
STATE PERSONNEL
The system administrative structure, shown in Figure 3, is assumed to be
organized under the Michigan Department of Transportation (MOOT). Reporting
directly to MDOT would be an Administrator, who would be responsible for opera-
ting the program in accordance with regulations established by MDOT. MDOT
staff would provide input to the Administrator regarding policy decisions and
would monitor the effectiveness of the program.
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Figure 3. Typical administrative structure,
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The Administrator would be supported by Legal Counsel, as necessary. The
function of Legal Counsel would be to advise the Administrator and MDOT on all
matters concerning the legal aspects of the program. In all likelihood, this
position would be filled as needed by existing staff lawyers within the State
government structure.
An EngineerC3), who would be required primarily during the startup phase
of the program, would be responsible for overseeing design and construction of
inspection facilities, the selection of test equipment, and the development of
data handling software.
The Mechanics Training Coordinator would be responsible for establishing
and implementing training programs for the repair industry. After startup, this
position would probably not require full-time effort; rather an occasional effort
would be required periodically during the actual operation of the program.
Responsibility for the program finances with respect to the State, would
be held by the Financial Coordinator. This would likely not be a full-time
position, and could perhaps be handled by existing State staff.
An Information Systems Analyst would be responsible for developing the
software to be used in the overall data collection system. A Data Analyst,
working in conjunction with his contractor counterpart (discussed later) would
be responsible for providing MDOT with periodic summaries concerning program
operation (e.g., percent failures, second failures, emission characteristics
of the inspectable fleet, etc.).
A Consumer Protection/Quality Assurance Supervisor would be required to
administer the quality control and consumer protection aspects of the program.
Subordinate to the coordinator would be the consumer protection and quality
assurance Investigators. The number of investigators would be dependent on the
format of the program. The fewest investigators would be associated with the
centralized-tailpipe or low-option parameter inspection approach. The central-
ized, high option would require about five times as many investigators as the
low option, since, as shown in the Section 7 Cost Analysis, approximately five
times as many facilities would be required under the high option. The high
option facilities are also likely to be almost twice as large, in terms of the
number of bays, as the low option facilities.
The decentralized approaches would involve a much greater effort. For the
high option, for instance, more than 2,600 private facilities would likely be
required to match the capacity of one hundred 38-bay facilities. Although a
single-bay repair shop inspection facility would require significantly less
investigation time than a large centralized facility, the large number of
decentralized facilities and additional travel time between facilities will
necessitate a substantial increase in the number of investigators required.
The low option, on the other hand, will require fewer decentralized facilities
and, thus, fewer investigators than the high option, but more than in a central-
ized low option approach.
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CONTRACTOR PERSONNEL
If a centralized, contractor-operated approach is used, several administra-
tive positions would be filled that are similar to State positions. The con-
tractor personnel would be headed by an Operations Administrator who would be
responsible for management of the operational aspects of the program and for
planning of future program operations. In a State-run or decentralized program,
the functions of this administrator would be handled by an Assistant Administra-
tor for Support Services.
The Operations Administrator would be supported by an Assistant Operations
Administrator who would oversee station managers and the Maintenance/Calibration
coordinators, as well as holding responsibility for day-to-day operation of the
program. This position would remain relatively unchanged in a State-run or
decentralized program.
Also subordinate to the Operations Administrator would be a Financial
Coordinator and Legal Counsel having duties similar to their respective State
counterparts.
In a State-run or in a decentralized program the functions of the two
positions would be absorbed by the State personnel of the same titles.
The Inspector Training Coordinator would be responsible for all the formula-
tion and establishment of a comprehensive training program for all inspection
station personnel employed by the contractor (or the State) .
Inspector training could, in any centralized approach, be conducted by the
individual facility managers and assistant managers. In a decentralized approach
incorporating tailpipe testing a number of instructors may be required on a one-
time basis and a smaller number continuously throughout the life of the program.
In any of the parameter inspection approaches, inspector training could be in-
corporated with mechanic's training.
The Personnel Administrator would handle all matters directly involving
any of the contractor's personnel. This administrator would also serve as
liaison between station personnel and contractor management personnel, and
would represent the employees in any labor disputes which might arise. This
position would be handled by existing State staff in a State-run program, and
would be unnecessary in a decentralized program.
The Data Analyst would work in conjunction with the State in preparation
of periodic reports on the program, and would be responsible for the daily data
processing effort.
The Maintenance/Calibration Coordinator would oversee maintenance/calibra-
tion persons and would hold ultimate responsibility for the repair and overall
condition of all contractor equipment.
In a State-run or decentralized approach, these positions would be filled
by MDOT personnel. The number of persons required would vary as a function of
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the specific option selected in a manner similar to that discussed for consumer
protection/quality assurance investigators.
The above described administrative structure is a suggested approach and
should be viewed as such. The actual structure established by the State should
reflect the particular option selected, existing personnel available within the
State government, and the available funding. The primary point in this Section,
however, is administrative requirements are fairly constant with regard to
whether parameter inspection or the tailpipe measurement approach is utilized.
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SECTION 7
COST ANALYSIS
INTRODUCTION
The primary Interest at this point is to consider parameter inspection
programs in terms of general concepts — more specifically, in terms of the
four concepts described in the previous paragraphs. In that specific program
scenarios arc> not being considered, detailed cost analyses have not been
developed, nor would it be possible to develop these at this time. Of more
concern are the relative costs associated with each parameter inspection con-
cept, and, again in a general sense, how these costs compare with tailpipe
measurement program costs. The analyses presented here consider the relative
costs associated with parameter inspection alternatives only. Reference 1
should be used in conjunction with the data presented in this document to
compare parameter inspection costs with tailpipe inspection costs. Since
these two analyses were developed independently, the costs derived should be
compared in general terms.
In analyzing costs, the methodology used for decentralized programs is
significantly different from that used for the centralized programs, regard-
less of whether the high or low option is being considered. For convenience
the analyses are presented separately for the decentralized approach — high
and low options — and the centralized approach — high and low options.
DECENTRALIZED APPROACH
General Methodology
There are a number of variables that will affect the cost of an inspection
nt a decentralized repair shop, several of which cannot be addressed quan-
titatively within the scope of this project. One such variable involves the
competitive nature of the service station industry. Since each station com-
petes with all others for customers, prices will be set at levels that attract
enough business to meet costs plus realize an acceptable margin of profit.
The basic premise underlying the behavior of a single station is that total
revenue must be at least equal to total station costs:
Total Station Revenues _> Total Station Costs
This applies generally to individual services performed by the station, as well.
One slight deviation, however, is that a particular service does not necessar-
ily have to provide a profit (or, for that matter, produce sufficient revenue
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to offset its cost) if it creates a demand for some other service that will
produce profit.
With regard to inspection and maintenance, the gross revenue produced is
equal to the sum of the inspection fees and repair work performed as a direct
result of the inspections. The costs associated with providing the inspection
service depend on several factors such as the equipment required, licensing
fees, salaries and overhead, etc. Gross revenue and costs are directly related
and are both affected by many common factors. One such factor is the expected
number of inspections performed annually by a facility; this factor can be
discussed in terms of market behavior.
Market Behavior—
Within a given geographic area, the average annual throughput per inspec-
tion station,, N, can be calculated from:
N - J
N --
where I = the total number of inspections and reinspections required in the
given geographic area.
S = the number of inspection stations within the given geographical
area.
Thus, the number of inspection stations and the annual throughput are inversely
related; as the number of such stations increases within a given geographical
area, the throughput for each will decline, and vice versa.
The market participation rate, R, is a useful term in discussing the mar-
ket behavior. It is calculated using the following formula:
R - 2-
R ~ G
where S = the number of inspection stations within a given geographic area
C = the total number of service stations within that area.
As Indicated above, service stations are motivated to provide inspection ser-
vices by the potential profits to be made. Unless otherwise constrained, ser-
vice stations will continue to enter the inspection business as long as these
profits can be realized. There is a point, however, beyond which increasing
the participation rate will mean throughputs so small that inspection revenues
will not equal costs. Figure 4, below, provides a generalized indication of
the functional relationship between the participation rate, R, and both the
costs incurred and revenue derived from the inspection program, for each in-
spection facility.
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to
K
o
o
k -
a b c
PARTICIPATION RATE (R)
FACILITY COSTS
INCURRED
FACILITY REVENUE
DERIVED
1.0
445-4
Figure 4. Generalized relationship between participation rate, R, and
costs and revenue associated with providing inspection
service.
If the participation rate in a network is close to "a" in Figure 4, all
stations will, on the average, be making a profit on the inspections, there-
fore, the program will tend to attract additional stations. As the par-
ticipation rate increases to around point c, some stations will begin to
experience a loss since costs will be higher than revenues. If the participa-
tion rnte is in the vicinity of point b, the average station will just break
even on its investment. Some stations will operate at this seemingly irra-
tional point because repair business on failed vehicles is likely to generate
some new revenue that would otherwise not occur.
From the standpoint of costs, then, it is desirable to keep the participa-
tion rnte low. On the other hand, if the rate is too low, the inspection
capacity will not be able to accommodate demand in a satisfactory manner. This
would be evidenced by long waiting lines at the inspection sites, and would
likely result in many consumer complaints. The actual participation rate in
a given area might be controlled to some extent through:
• establishing a certain "fixed number of station licenses
to be granted within a given geographic area in a given year;
• establishing uniform maximum or minimum fees to be charged
by inspection stations for performing inspections; and
• varying the licensing fee paid by inspection stations to the
state.
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For the purposes here, It is not essential that the number of inspection sta-
tions be derived. In fact, this number cannot be derived at this point since
the geographic coverage — hence, the size of the affected vehicle population —
has not been projected. Instead, the cost computations for the decentralized
option were based on three factors that can be dimensioned fairly accurately
at this point, and which will provide a realistic estimate of the actual fee
that would be charged for an inspection. The three factors include:
• time required to perform the inspection;
• current hourly shop rate (1979 dollars) for service facilities
in Michigan; and
• estimated costs for administering the program.
Very simply, the estimated inspection fee, f, is computed as:
f = (T)(H) + (Ca/I)
where T = time required to perform the inspection;
H = the 1979 average hourly shop rate for service facilities
in Michigan;
Ca = the annual administrative cost incurred by the State for
operating the program; and
I = the total number of inspections (excluding reinspections)
to be performed by the program.
The Inspection fee reflects two separate components — the actual inspec-
tion represented by the product of T and H, and an administrative fee, which
is a function of several factors but essentially reflects the total adminis-
trative costs divided by the annual number of paid inspections.
Several assumptions are implicit in this approach. The most crucial of
these, however, is that the existing shop rate, H, provides a relative indica-
tion of the true costs of operating a service facility, (including the costs
associated with purchasing, maintaining, and replacing common tools and equip-
ment, and general administrative, labor, and overhead costs), and that an
inspection service justifies the same hourly rate as other work performed at
the facility. Also, since the administrative cost element cannot be estimated
specifically for the Michigan I/M program, it is assumed that the average
administrative cost associated with programs in other states will provide a
reasonable estimate of the administrative costs that will be incurred in the
State of Michigan.
Cost Analysis
A close Inspection of the high and low options reveals that the primary
difference between the two is the level of intensity involved; actually very
little difference occurs In the equipment and shop space required. An important
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conclusion, then, is that the relative cost of the two options will be primarily
a direct function of the amount of time spent performing the inspection. The
derivation of a fee estimate is discussed separately for the high and low op-
tions in the following paragraphs.
High Options—
Section 2 of this document provided an outline of the individual inspec-
tion tasks proposed for the high option. Included were estimates of the time
requirements to perform each task, and a subjective assessment of the level of
skill and special equipment (in this context, special equipment includes items
that would not ordinarily be found in a general repair facility and their use
would be more or less limited to performing the inspections) required.
The individual time requirements for performing each task are summarized
below in Table 24. As can be seen from this table, the individual time require-
ments are generally specified as ranges owing to the variability in the effort
as a function of vehicle manufacturer and model. The total time range is
approximately 1-1/2 to 5 hours. Based on discussions with representatives of
the automobile service industry, an estimated "average" inspection time of
2-1/2 hours is reasonable.
TABLE 24. SUMMARY OF INSPECTION TASK TIME - HIGH OPTION
Inspection element
Estimated time required
Carburetor-all items
Ignition system
Thermal air Inlet
Heat Riser
PCV
EGR system
AIR system
Spark delay valve
Catalytic converter
1 to 2-1/2 hours per carburetor
30 minutes to 2 hours
10 to 20 minutes
Approximately 1 minute
2 to 5 minutes
2 minutes
1 to 2 minutes
(included in ignition system check)
1 minute
The shop rates for automotive repairs are also variable, primarily as a
function of geographic location. Rates are generally higher in the more urban
areas. The actual rate may vary by the type of work performed, as well. A
sample of repair facilities in and around the metropolitan Detroit area indi-
cated that the rates range from around $16 per hour to over $30 per hour for
tune-up work; again, the range within the Detroit metropolitan area is higher -
generally $25 to $35 per hour. For purposes here, an hourly rate of $30 per
hour is assumed. The result, then, is an estimated cost range of $45 to $150,
and an average cost of $75 to perform the inspection.
Also, the administration costs will be absorbed by the consumer. This
covers the cost of support programs concerned with public information, quality
assurance, mechanics training, and for the overall administrative effort
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required. Based on programs planned for other states, cost estimates for the
overall administrative function range from $0.20 to $2.00 per inspection, de-
pending largely on the scope of the support programs involved. For the high
option of a parameter inspection program, it can be assumed that a significant
effort will be required in areas such as consumer protection, public informa-
tion, and quality assurance. It appears reasonable, then, to expect that the
attendant coats will reflect the higher end of the previously-stated range;
the assumed administrative cost is $2.00 per inspection.
Some motorists will also Incur additional costs in spite of the fact that
their vehicle may pass the inspection. As indicated in Section 2, some car-
buretors must be partially disassembled in order to perform the required ad-
justments or inspections. In order to reassemble the carburetors, new gaskets
are required, which cost approximately $5.00 to $8.00 per set.
The total Inspection cost for the high option performed in a private
garage or repair facility, then, can be expected to range from about $47.00
to around $160.00; an average cost of approximately $80.00 appears likely.
This cost is exclusive of any repairs or adjustments that cannot be performed
as part of the inspection. Also, new parts that may be required, even though
they may be Installed as part of the inspection, are not included, either.
At this point the likely costs of repair parts and repairs or adjustments
required that are not made as part of the inspection process have not been
investigated; it is acknowledged here that these costs constitute an extremely
significant aspect of the proposed program and, therefore, must be considered
In subsequent phases of the planning effort. In fact, reinspections under
this option must also be considered from the standpoint of cost impact since
reinspections could certainly be significant.
Low Option—
Estimating the costs associated with the low option essentially involves
the same considerations as were applicable to the high option. Again, the
primary difference is that the low option inspection process is much less
demanding Ln terms of both time and expertise. The inspection routine along
with the individual time requirements for each task are summarized in Table 25.
TABLE 25. SUMMARY OF INSPECTION TASK TIME - LOW OPTION
Inspection element Estimated time requirement
Visual Inspection 1 to 2 minutes
Fuel filler 30 seconds to 1 minute
Catalytic converter 1 minute
EGR system 2 minutes
Idle air-to-fuel ratio 15 to 20 minutes (if adjustment is required)
The total time requirement, including processing paper xrork and counselling, it
estimated to be approximately 30 minutes.
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To derive an estimate of the inspection cost, the previously-defined hourly
rate of $30.00 per hour was applied to the inspection time estimate resulting
in a cost of $15.00. It is likely that the overall administration costs would
be less for the low option since the scope of certain of the support programs,
primarily the quality assurance program and the consumer protection program,
would not be as great for this option. It is estimated that a reasonable ad-
ministration cost would be on the order of $1.50 per inspection. The total
inspection cost, exclusive of repairs or adjustments performed separately, is
estimated to be approximately $16.50.
CENTRALIZED APPROACH
General Methodology
For the centralized approach, an assessment was made of the various costs
associated with implementing and operating an inspection station, from which
the per Inspection cost was calculated as a function of the annualized costs
and the expected throughput. The general cost categories and subcategories
considered in this analysis are presented in Table 26. Cost data were derived
from several sources including equipment manufacturers, land assessors, building
contractors, various reports concerning I/M programs in other states, and ori-
ginal estimates derived by GCA staff members. All cost data presented here
are in constant 1979 dollars unless otherwise noted.
TABLE 26. COST CATEGORIES CONSIDERED IN THE ANALYSIS OF
CENTRALIZED PARAMETER INSPECTION PROGRAM
Primary category
I. Initial capital costs
II. One-time start-up costs
Subcategories
in. Annual operating costs
IV.
Annual administrative costs
1. Building investment
2. Land investment
3. Equipment costs
1. Land acquisition
2. Facilities planning
3. Program design
4. Develop data handling systems
software
5. Personnel training
6. Personnel salaries and overhead
prior to start-up
7. Initial public information program
1. Facility personnel
2. Maintenance
3. Utilities/services/supplies
1. Program administrative personnel
2. Enforcement
3. Consumer protection/quality
assurance
it. Public information
5. Training, licensing, certification
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The basic comparisons made in this section consider centralized parameter
inspection programs utilizing either the high option or the low option; one
additional possibility exists, however, which is not treated here. This addi-
tional possibility concerns whether the program is operated by the State or by
a private contractor, either of which is a realistic approach. Generally, dif-
ferences can be expected depending on which approach is selected because cer-
tain cost savings can be realized by a contractor since he generally has more
flexibility in selecting contractors, purchasing equipment, hiring personnel,
and in his overall administrative process. Previous studies of tailpipe in-
spection programs indicate that the cost differential may be as much as 10
percent.
The following paragraphs provide a detailed description of the cost ele-
ments analyzed and also indicates data sources and assumptions used.
Initial Capital Costs
These costs reflect the initial expenditures required for tangible items
such as purchasing and improving land, constructing the test facility, and pur-
chasing and installing all items of equipment, land, buildings, and equipment
are the three major elements considered under the category of capital costs.
Building Investments—
Building costs are dependent on specific designs and features utilized;
unit costs, therefore, vary substantially as a function of the particular design
selected. For I/M applications, the primary concerns are functional adequacy
of the building, and cost economy. A type of structure that ostensibly satis-
fies these criteria is a standard clear span, metal structure. These are
essentially pre-engineered, modular structures that can be adapted to a wide
variety of applications.
At this point, some basic specifications for a "standard" structure must
be developed. The primary specification concerns the number of bays that the
facility should have. Consider, for the moment, the metropolitan Detroit area.
The total light-duty vehicle population to be served in this area, projected
to 1987, is estimated to be 3.1 million. Assuming a conservative retest rate
of 10 percent, then, means that about 3.4 million vehicles must be serviced
during 1987. Based on the technical discussion in Section 2, it is seen that
the inspection time for the high option is estimated at 2-1/2 hours. If the
Inspection facilities are open say 280 days per year, on an average of 10 hours
per day, and operate with an efficiency factor of 0.80, then annually there
arc essentially 2,240 inspection-hours available per bay, per year. Since each
Inspection requires 2-1/2 hours, each bay has an annual capacity of approxim-
ately 900 inspections. The total number of inspection bays required to accom-
modate the 3.4 million vehicles is:
3.4X 106/900 = 3,800 bays
With this factor defined, one could suggest that the size criteria be estab-
lished so that no more than 100 facilities would be required; this would mean
that each facility would require approximately 38 bays. Although this con-
stitutes a rather large facility, it certainly is within the practical range;
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the discussion will assume, then, that the standard facility for the high option
contains 38 inspection bays.
The space requirements for this type of facility were analyzed resulting
in a design concept that provides an overall size of 26,000 square feet
(150' x 174'). This is comprised of approximately 14,000 square feet of in-
spection bays, 5,000 square feet of isle space, 5,000 square feet of adminis-
trative area, and 2,000 square feet of waiting area. A conceptual floor plan
is provided in Figure 5.
For the low option these same 3.4 million vehicles would require only
about 760 bays owing to the much faster inspection time (30 minutes as
opposed to 2-1/2 hours). Rather than utilizing 20 38-bay facilities, it
might be more reasonable to use 38 20-bay facilities; it is assumed, then,
that the standard low option centralized facility will include 20 bays.
Again, the basic space requirements were analyzed and a design concept
derived. This design provides 16,800 square feet in total (140* x 120'). For
this facility, the individual bay sizes and waiting areas were held constant
(with respect to the 38-bay facility) while the administrative areas and isle
space were scaled down. A conceptual floor plan is shown in Figure 6.
The cost for constructing the facility described above was derived from
conversations with manufacturers' representatives; the unit cose was estimated
to be approximately $30.00 per square foot for a total cost of $780,000 for the
38-bay facility and $504,000 for the 20-bay facility.
Land Investment—
The costs associated with land investment consists of two elements — the
basic cost of the land, and necessary improvements such as landscaping and
paving. The cost of a particular parcel of land depends on the size of the
parcel and the unit price. Unit costs for land are extremely lot-specific;
the unit cost for parcels within a given block may vary by a factor of 3,
while, within a given municipality, the unit cost could easily vary by a factor
of 10 or more. Available parcels may be somewhat larger than the size actually
required necessitating the purchase of land that exceeds the general require-
ments. Obviously, then, it is not possible at this point to develop a precise
cost estimate for the land required for an inspection facility. In a recent
study performed for the Michigan Department of Transportation, estimates rang-
ing from $0.50 to almost $6.00 per square foot were presented for land in the
larger metropolitan areas of the State; an assumed unit cost of $4.00 per
square foot appears to be reasonable.
The total area required is primarily a function of the building size. For
both types of facilities, the land requirement is estimated to be four times
the floor area of the building. This would provide parking areas for both
customers and employees, and room to maneuver through the area. The estimated
land area required, then, is 104,000 square feet (2.4 acres) for the 38-bay
facility, and 67,200 square feet (1.6 acres) for the 20-bay facility. Costs
of $400,000 and $270,000 are indicated for the two facilities.
86
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I BO'
cc
x <
a
Q
<
CO
o
H
O
V)
2
<
m
O
LJ
Q.
Z
ADMINISTRATIVE
AREA
REST ROOMS
WAITING ROOM
MACH
ROOM
Figure 5. Conceptual floor plan — centralized facility for
high option parameter inspection program.
87
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140'
in
>-
<
00
O
a
v>
V)
GO
O
UJ
a
in
z
ADMINISTRATIVE
AREA
REST ROOMS
WAITING ROOM
MACH.
ROOM
443-3
Figure 6. Conceptual floor plan — centralized facility for the
low option parameter inspection program.
88
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Added to this cost is the cost of paving and landscaping. The unit cost
for this element is $1.30 per square foot, $135,000 and $87,000. The total
land investment is equal to the sum of the purchase price and the improvements,
or $535,000 for the 38-bay facility, and $357,000 for the 20-bay facility.
Equipment Requirements—
In concept, the parameter inspection technique can be applied without a
large array of specialized equipment. In a more practical sense, however,
the use of certain specialized items should be considered primarily as a method
for assuring that quality control is maintained and to assist in the process
of routine records keeping and program assessment.
As was previously indicated, there is some uncertainty regarding the types
of tests and test equipment that will be required for vehicles that will be
produced beyond the next few years. It is fairly certain that vehicles pro-
duced by ?"ord Motor Company will require a "black box" diagnostic device for
Its EEC-1 computerized engine control system. Also, for some current vehicles,
emissions analyzers are required to perform certain adjustments on the car-
buretor (primarily, A/F adjustment). It can be concluded, then, that there
Is a requirement for equipment other than basic hand tools and commonly used
devices such as timing lights, dwell meters, etc.
With regard to equipment available, there is a wide variety of equipment
representing a wide range in sophistication, capability, utility, and cost.
The extremes in this range are, at the low end, various hand held devices, such
as tachometers, that perform one specific function; at the high end are com-
puter controlled engine analyzers that are capable of performing a wide variety
of specialized tasks. Figure 7 illustrates the range in equipment available,
while the costs associated with these types of equipment are shown In
Figure 8.
Although the cost differential among the various types of equipment men-
tioned above might appear to be significant, the actual impact on the inspection
cost of choosing the least expensive over the most expensive (or vice versa is
quite small; this will be illustrated at the end of this Section. Further,
the incremental cost would likely be offset directly by the gain in efficiency
and quality of the inspection process using a computer controlled system. For
tlu-se reasons, the analysis presented here assumes that a highly advanced en-
gine analyzer system will be provided in each inspection bay. It is also as-
sumed that an online computer file will be maintained and that each bay will be
equipped with a cathode ray tube (CRT) display unit so that all relevant spec-
ification for any vehicle under inspection can be obtained quickly and accu-
rately by the inspector. The analyzer and CRT unit is assumed to be appropriate
for both the high and low options since the types of adjustments that the sys-
tems would be useful for are common to both options. Further, it is assumed
that the overall administrative recordkeepin- functions will utilize a comput-
erized system.
In addition to the equipment required to perform the inspections and pro-
cess records, general office equipment, furnishings for the waiting area, and
special exhaust fume handling systems are required. The entire equipment
requirement along with an Itemized cost estimate is provided in Table 27.
89
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HAND-HELD
EQUIPME NT
SCOPE LESS
ANALYZER
SCOPE
ANALYZER
COMPUTER
TACHOMETER
VOLTMETER
AMPMETER
DWELL METER
VACUUM GAUGE
TIMING LIGHT
TIMING RETARD
OSCILLOSCOPE
EMISSIONS ANALYZER
SEQUENTIAL TESTING-
PRINTOUT
=p
ANrE
'[
^[
M
»-[
*1
HIGH VOLUME
MICRO-PROCESSING
STORED SPECIFICATIONS
LIMITED ADD-ON CAPABILITY
OTHER
Figure 7. Functional comparison of engine testing equipment.
-------
A /\
COMPUTER
OSCILLOSCOPE WITHOUT
FUNCTIONS
OSCILLOSCOPE WITH
FUNCTIONS
SCOPELESS ANALYZER
TACH DWELL METER
TIMING LIGHT
VOLT -AMMETER
"
|
0
(
' , , J
1
i 0.5
J
1
1
V
— -»*. — .
_A
.13
V I
tfU' 1
A
.0 1.5 2.0 v 5.0 6-0 7.0 8.0 v 15.0 20
COST RANGE ($000)
.0
445-4
Figure 8. Cost comparison of engine/electrical test equipment.
TABLE 27.
Facility type
38-Bay
Total
20-Bay
EQUIPMENT REQUIREMENTS FOR TWO TYPES OF CENTRALIZED
PARAMETER INSPECTION FACILITIES
Total
! Item
Engine analyzer
CRT units
Mini computer
Tool sets
Facility furnishings
Engine analyzer
CRT units
Mini computer
Tool sets
Facility furnishings
No.
required
38
38
1
38
—
20
20
1
20
—
Estimated
unit cost
($)
20,000
2,500
50,000
2,000
—
20,000
2,500
50,000
2,000
—
Total cost
($)
760,000
95,000
50,000
76,000
50,000
$1,031,000
400,000
50,000
50,000
40,000
40,000
$ 580,000
91
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Summary—
The capital costs associated with a 38-bay and a 20-bay facility are
summarized In Table 28.
TABLE 28. SUMMARY OF CAPITAL COSTS FOR AN INSPECTION FACILITY
Estimated cost ($)
Cost element
38-bay facility 20-bay facility
Building investment
Land investment
Equipment
Total
$ 780,000
535,000
1,031,000
$2,346,000
$ 504,000
357,000
580,000
$1,441,000
It is noted here that some equipment items are not included at this point;
these are primarily associated with the administration of the program and will
be included as part of the administrative costs.
One-Time Start-Up Costs
Implementation of any I/M program will require the expenditure of monies
for noncapital 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 (pro-
gram planning, design, development, etc.), which are inherently much more
variable in cost than, for instance, equipment or building costs. Considera-
tions used in developing cost estimates for each element are discussed with
the presentation of the individual estimates as follows.
Land Acquisition—
Included in this element are the costs for identifying and locating can-
didate sites, negotiating purchase price, and completing title transfers. Site
location and price negotiation would involve approximately 200 man-hours of
professional 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 pre-
paration, and miscellaneous support functions required to execute the purchase.
The cost associated with this component is estimated to be approximately 10 per-
cent of the unimproved land value.
For the two facilities being considered here, this cost is:
$6,000 + (0.10)($400,000) = $46,000; and
$6,000 + (0.10)($272,000) = $33,000.
92
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Facilities Planning—
This element reflects the costs associated with engineering and design for
the test facilities, bid review and construction monitoring. This element will
be defined as 10 percent of the construction cost, or:
(0.10)($780,000) = $78,000 for the 38-bay facility, and
(0.10)($504,000) = $50,000 for the 20-bay facility.
Computer Software Design—
The costs associated with the development of computer software must be
allocated over the entire program rather than to each facility. Based on the
experience of other states, the cost of developing the required computer soft-
ware for I/M programs has been estimated at around $200,000 regardless of the
program size. This figure will be assumed to apply to the Michigan program as
well. The problem of allocating the cost can be handled by, again, assuming
that the entire program will consist of about 100 inspection stations for the
high option and 38 stations for the low option; the cost per station, then, can
be assumed to be 1 percent and 3 percent of the total cost for this element,
or $2,000 for the high option and $6,000 for the low option. Obviously, this
IB a rather imprecise method, however, it does not affect the final inspection
cost estimate significantly yet the fact that there is a cost associated with
this element is accounted for.
Personnel Training—
Owing to the nature of the parameter inspection process, it is assumed
that most inspectors would be required to have significant experience as me-
chanics prior to being hired. The additional training requirement would,
therefore, be minimal. Given the assumptions used previously regarding the
operating hours for the facility, it will be necessary to hire two inspectors
per bay; one would be full-time while the other would work part-time. This
requires training 76 individuals for the 38-bay facility and 40 for the 20-bay;
the likely turnover rate for personnel must be considered also. This is
assumed to be 10 percent annually. The requirement is to train a total of
85 and 45 individuals for the 38-bay and 20-bay facility, respectively, during
the initial stages of operation.
The cost of providing training was estimated based on the experiences of
other states in developing I/M programs. It is estimated that the cost per
individual is $50. The inspector training would cost a total of $4,300, and
$2,200 for the two options. It is noted that training is an ongoing activity
and, therefore, training costs are reflected both here and as recurring.
In addition to training the inspectors, the facility manager and assistant
manager must be trained in both the inspection techniques and in the adminis-
tration of the facility. The cost associated with providing this training is
estimated at $100 for each person, or a total of $200, which applies to both
options. The total training costs for the 38-bay facility is $4,500, while the
cost for the 20-bay facility is $2,400.
Personnel Salaries—
Prior to beginning actual inspections, most of the facility personnel
would be hired and would participate in training and preparing the inspection
station for operation. It is assumed that the manager and assistant manager
93
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would be hired and begin working 2 months prior to start-up, while the inspectors
would be hired 2 weeks prior to start-up, on the average.
The pay scale for the managers, assistant managers, and inspectors is:
• managers - $2,000 per month
• assistant managers - $1,670 per month
• inspectors - $1,500 per month
The start-up costs associated with the operational personnel are summarized in
Table 29.
TABLE 29. OPERATIONAL PERSONNEL SALARIES DURING PROGRAM START-UP
Position
Monthly
sal arv
Time
required
No. of
positions
Salary
during
start-up
start-up High
Low
High
Low
option option
option option
($)
($)
Manager
Assistant
Manager
Inspectors
2,000
1,670
1,500
<"Ufi/T.7ooM
2 months
2 months
2 weeks
1
1
85
1
1
45
4,000
3,340
58,820
4,000
3,340
31,140
Total
$66,160 $38,480
Added to the total shown in Table 28 would be the overhead costs, assumed here
to be 25 percent of the wage rate. The total costs, then, are $82,700 and
$48,000 for the high and low options, respectively.
Also during the start-up phase a number of administrative personnel will
he employed. The costs associated with the administrative effort must be
allocated over the entire program. Since the basic administrative structure
is likely to be very similar to the administrative structure used in other
states for tailpipe inspection programs, the total start-up costs associated
with administrative activities can be estimated from these other programs.
Several programs indicate that the administrative effort during start-up costs
approximately $250,000. Assuming that the allocated administrative cost per
facility is approximately 1 percent and 3 percent respectively for the high
option and low option, the administrative personnel costs for the two facil-
ities under consideration here are about $2,500 and $7,500; the total operat-
ing and administrative personnel salaries are $82,700 + $2,500 = $85,200 for
the high option, and $48,000 + $7,500 = $55,000 for the low option.
94
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Support Programs—
During the- start-up phnae the public information program and a mechanics
training program will likely be initiated. Generally, the costs associated
with public Information programs are based directly on the size of the vehicle
population affected by the program. For purposes here, it can be assumed that
this cost will be approximately $0.15 per vehicle, which is slightly higher
than the cost used for tailpipe inspection programs. This would mean that the
costs allocated to the 38-bay facility and 20-bay facility under consideration
are approximately $5,000 and $25,000, respectively.
At this point it is nearly impossible to estimate the requirement for
mechanics training. It is not likely that the total amount spent would exceed
$100,000 based on the mechanics training programs proposed for other states.
Again, the allocated cost will not significantly affect the final inspection
cost, although for completeness, it will be assumed that the allocated cost
will be $1,000 for the 38-bay facility and $5,000 for the 20-bay facility.
Summary—
A summary of the estimated start-up costs associated with implementing
operations at a 38-bay centralized inspection station for the high option and
a 20-bay facility for the low option are provided in Table 30.
TABLE 30. SUMMARY OF INITIAL START-UP COSTS FOR A 38-BAY
INSPECTION FACILITY, AND A 20-BAY INSPECTION FACILITY
Estimated cost
Item
High option ($) Low option ($)
Land acquisition
Facility planning
Computer software
Personnel training
Personnel salaries
Support programs
Total
46,000
78,000
2,000
4,500
85,200
6,000
$221,700
33,000
50,000
6,000
2,400
55,000
30,000
$176,400
Annual Operating Costs
Annual operating costs include all costs associated with the actual opera-
tion of tlie program. For the purposes here, the costs of adjunctive programs
(e.g., public information, inspection/mechanic training, etc.) are included
under "Annual Administrative Costs," which are discussed later.
Facility Personnel—
The annual costs associated with this category are a function of the num-
ber of personnel involved in the operation of the facility and their relative
level of responsibility, and the prevailing wage scale for the employment
categories involved.
95
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TABLE 31. ANNUAL PERSONNEL COSTS - OPERATIONAL PERSONNEL
VO
Job title
Manager
Assistant Manager
Inspectors — Full Time
Inspectors — Part Time
Subtotal
Overhead at 25% of Wages
Total
Annual Pay rate
participation ($)
Full-time $24,000/yr
Full-time 20,000/yr
Full-time 18,000/yr
700 hr/yr 8.57/hr
Number of positions Annual salary ($)
High option Low option High option
1 1 24,000
1 1 20,000
38 20 684,000
38 20 228,000
956,000
239,000
$1,195,000
Low option
24,000
20,000
360,000
120,000
524,000
131,000
$655,000
-------
Both the operating personnel requirements and corresponding wage rates were
specified in the previous paragraphs. Applying these to the annual operation
of the two types of facilities results in the costs shown in Table 31.
Maintenance—
Included in this category are repair and preventive maintenance costs for
facility equipment, estimated at 20 percent of the original equipment cost per
year. This equals to:
(0.20)($1,031,000) = $206,200, and
(0.20)($580,000) = $115,000.
Utilities/Services/Supplies—
Items in this category include electricity, heat, water, insurance, inspec-
tion forms, building services, office supplies, etc. Based on the size of the
facilities, the type of equipment required, hours of operation, and general
location, estimates of $200,000 and $150,000 per year were derived.
Summary—
A summary of the annual operating costs associated with the 38-bay and
20-bay inspection facilities are provided in Table 32.
TABLE 32. SUMMARY OF ANNUAL OPERATING COSTS FOR A 38-BAY
INSPECTION FACILITY AND A 20-BAY INSPECTION FACILITY
Estimated costs ($)
Cost element
High option Low option
Personnel $1,195,000 $655,000
Maintenance 206,200 116,000
Utilities/services/supplies 200,000 150,000
Total $1,601,200 $921,000
Ann ua1 Adm I nistra11on Costs
Costs Involved in this category reflect the overall program administrative
effort. Specifically, the salaries of personnel involved in areas such as
enforcement, consumer protection, public information, training, and certifi-
cation are included. Also, the operating costs for quality assurance and
consumer protection vehicles fall into this category.
Administrative Personnel Costs—
The suggested administrative structure discussed in Section 6 was used to
develop an estimate of the total cost for personnel salaries and overhead.
Table 33 provides a summary of the personnel cost estimate. Again, these costs
have to be allocated over the entire program; as before, it is assumed that
97
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TABLE 33. ANNUAL ADMINISTRATIVE PERSONNEL COSTS -
HIGH AND LOW OPTIONS
Salary
Position
State Personnel
Administrator
I.egal Counsel
Clerical Support (2)
Mechanics Training Coordinator
Financial Coordinator
Consumer Protection/Quality
ANKurance Supervisor
Data Analyst
Consumer Protection Investigator
Quality Assurance Investigator
Total State Personnel Salaries
Overhead « 25%
Total State Cost
Cons tractor Personnel
Operations Administration
Assistant Operations Administrator
1 egal Counsel
( U-rlcal Support (2)
financial Coordinator
Personnel Administrator
Data Analyst
Maintenance /Calibration
Coordinator
Total Contractor Personnel
Salaries
Overhead P 251
Total Contractor Cost
Total Cost
Annual
($)
30,000
20,000
12,000
20,000
24,000
18,000
18,000
18,000
15,000
30,000
20,000
30,000
12,000
20,000
24,000
18,000
15,000
Monthly
($)
2,500
1,670
1,000
1,670
2,000
1,500
1,500
1 , 500
1,250
2,500
1,670
2,500
1,000
1,670
2,000
1,500
1,250
Participation
annually
(months)
12
3
12 (each)
6
12
12
12
12
12
12
12
3
12 (each)
12
12
12
12
Total salary
for participation
annually
($)
30,000
5,000
24,000
10,000
24,000
18,000
18,000
18,000
15,000
162,000
41,000
203,000
30,000
20,000
7,500
24,000
20,000
24,000
18,000
15,000
158,500
39,500
$198,000
$401,000
98
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1 percent of the cost can be allocated to the 38-bay facility and 3 percent to
the 20-bay facility. The resulting cost allocations for the two types of
facilities are $4,000 and $12,000, respectively.
Support Programs—
The public information programs and the training programs for inspectors
and mechanics will be conducted on an ongoing basis. Again, the cost of the
public information program is assumed to be based on a fixed rate per inspected
vehicle. The assumed rate is $0.15 per vehicle; since the 38-bay facility can
accommodate approximately 34,000 vehicles annually, the allocated public infor-
mation cost is approximately $5,000; the 20-bay facility can accomodate approx-
imately 83,500 vehicles therefore an allocated cost of $12,500 is indicated.
It is assumed that the training activity will continue at the same level
as during the start-up phase, therefore the allocated costs are approximately
$4,500 and $2,400 annually.
Cost Summary
The individual cost categories are summarized in Table 34.
Fee Computation
In order to derive a "break-even fee," all costs found in Table 34 are
converted into annual figures. The steps involved in calculating these annual
costs are summarized below.
Initial Capital Costs—
The capital investment in equipment is assumed to yield equal benefits
for each of 5 years and be fully depreciated thereafter. The interest rate, i,
is the marginal return on capital in the absence of inflation. For the pro-
gram being assessed here, i is assigned a value of 0.06.
In annualizing equipment costs, the following formulae are employed.
The net present value (NPV) of an investment that yields $1 of services for
each of n years at a capital growth rate of i is:
n
NPV = X) -^T = 1 -
k=i
Therefore, an investment of $1 will yield annual benefits of:
__ „ -- —^ for each of n years. Therefore, the amortized costs in
constant dollars, is represented by ^-. The amortization factor for equipment,
then, is: --- - 0>2374.
l-Cl+0.06)
99
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TABLE 34. COST SUMMARY FOR A 38-BAY AND A 20-BAY INSPECTION FACILITY
o
o
Cost category
Initial Capital Costs
Startup Costs
Annual Operating Costs
Annual Administrative Costs
Cost element
Buildings
Land
Equipment
Subtotal
Land Acquisition
Facility Planning
Computer Software
Personnel Training
Personnel Salaries
Support Programs
Subtotal
Personnel Salaries
Maintenance
Utilities /services/
supplies
Subtotal
Personnel Salaries
Training Programs
Public Information Program
Subtotal
Estimated
High option
780,000
535,000
1,031,000
2,346,000
46,000
78,000
2,000
4,500
85,200
6,000
221,700
1,195,000
206,200
200,000
1,601,200
4,000
4,500
5,000
13,500
cost ($)
Low option
504,000
357,000
580,000
1,441,000
33,000
50,000
6,000
2,400
55,000
30,000
176,400
655,000
116,000
150,000
921,000
12,000
2,400
12,500
16,900
-------
For buildings, the initial investment is assumed to yield a constant flow
of capital services for 20 years and be fully depreciated thereafter.
Applying n = 20 to the above formula:
0.06
1-C1+0.06)-20
= 0.87
If structures are liquidated before 20 years, the sale price is assumed
to be the capitalized flow of the remaining services. Therefore, a structure
sold after j years will sell for:
20-j
for each dollar of initial investment. This assumption enables the use of the
above amortization factor, -r=rr, without making further adjustments.
Land is assumed to yield a constant level of services in perpetuity (n = °°
in the above formulae). Therefore, $1 of investment yields i dollars of service
per year. That is to say, without inflation, the resale value of land is un-
changed from year to year, and the annual benefit (cost of capital services) is
i times the original value of the land regardless of when liquidation occurs.
One-Time Startup Costs—
One-time startup costs, like capital costs, occur at the beginning of the
project. However, these expenditures do not yield a flow of services or have a
resale value, as do capital investments. Startup costs can, however, be re-
covered over time. Since the ideal contract length for the program being
assessed here Is 5 years, a 5-year period of equal annual payments in constant
dollars is assumed. Therefore, the annual cost of each dollar of startup cost
is:
°'06 = 0.2374
-5
Annual Operating and Administrative Costs—
These costs are presented as annual figures. To obtain total annual cost
in constant 1979 dollars, the operating and administrative costs are added
directly to the annualized startup and capital costs.
Fee Calculation, fc—
A break-even fee, reflecting constant 1979 dollars, is calculated by dividing
the total annualized costs by the number of paid inspections per year. This
fee is designed to recoup all of the costs presented in Table 34. The annual-
ized costs are provided in Tables 35 and 36, for the high and low options,
respectively.
101
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TABLE 35.
ANNUALIZED COSTS IN CONSTANT 1979 DOLLARS FOR A 38-BAY
CENTRALIZED PARAMETER INSPECTION STATION FOR THE HIGH
OPTION
Cost category
„ .
Cost
Amortization Annualized
factor cost
(1=0.06) ($)
I.
II.
III.
IV.
Capital Costs
1 . Land
2. Buildings
3. Equipment
Start-up Costs
Operating Costs
Administrative Costs
Total Annualized Costs
535,000
780,000
1,031,000
221,700
1,601,200
13,500
0.06
0.087
0.2374
0.2374
1.0
1.0
32,100
67,860
244,760
52,630
1,601,200
13,500
2,012,050
TABLE 36. ANNUALIZED COSTS IN CONSTANT 1979 DOLLARS FOR A 20-BAY
CENTRALIZED PARAMETER INSPECTION STATION FOR THE LOW
OPTION
Cost category
„
Cost
Amortization Annualized
factor cost
(1=0.06) ($)
I.
II.
III.
IV.
Capital Costs
1 . Land
2. Buildings
1. Equipment
Start-up Costs
Operating Costs
Administrative Costs
Total Annualized Costs
357,000
504,000
580,000
176,400
921,000
16,900
0.06
0.087
0.2374
0.2379
1.0
1.0
21,420
43,850
137,690
42,336
921,000
16,900
1,183,196
102
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The actual inspection fee in constant 1979 dollars can be computed at this
point by dividing the annualized cost shown in Tables 35 and 36 by the average
number of vehicles inspected annually during the program life cycle (assumed
to be from 1982 through 1987).
High Option--
Figures presented earlier indicated that the 1987 inspection demand would
be approximately 34,000 vehicles for a single 38-bay facility; assuming that
the average demand during the life cycle is 90 percent of the 1987 demand re-
sults in an estimated average annual demand of 30,600 vehicles. The breakeven
fee, then, is computed to be approximately $65.60 per inspection.
Low Option—
As previously calculated, the 1987 inspection demand will be approximately
83,500 for a 20-bay facility. Assuming that the average demand during the
life cycle would be approximately 90 percent of the 1987 demand, a 75,150
vehicle average demand would be expected. The breakeven fee, then, is computed
to be approximately $15.75 per inspection.
COST SENSITIVITY ANALYSIS
One of the most crucial cost variables is the time required to perform the
Inspection. The more time efficient the inspection procedure, the larger the
per-bay volume and thus the lower the per motorist cost. An analysis of the
cost sensitivity was performed for several test time variations to determine
the resultant effect on the inspection fee.
Decentralized Programs
The inspection fee for decentralized programs was previously defined as a
function of the time required to perform the test plus an administrative fee
to cover the annual administrative and adjunctive program costs. It was pre-
viously reported that a decentralized approach to the high option would cost,
on average, about $80 per inspection. This fee was derived based on a
$10/hour shop rate and 2.5 hours per inspection. If the high option was
modified such that only 1.5 hours were required per test, the cost of an
Inspection would be reduced to about $47 per test. Say further modifications
to the procedure enabled inspections to be performed in only 1 hour. This would
reduce the inspection cost to about $32 per test.
Similar effects would occur on the inspection fee for the low option
with test time reductions. A previous estimate of $16.50 was derived for the
low option inspection fee, based on a test time of 30 minutes and a $1.50
administrative charge. Were it possible to conduct the inspection in 15 minutes,
the cost to the motorist would be $9.00, again assuming a $1.50 administrative
fee.
Centralized Programs
If the high option inspection time were reduced to 1.5 hours, a 38-bay
facility annual throughput could increase to 57,000 inspections per year.
Calculation of the change in inspection fees for the centralized programs is
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not quite as straightforward as for the decentralized options, as some of the
administrative and startup costs were previously calculated based on the
percent of the vehicle population covered at a single facility (1 percent for a
38-bay facility under the high option and 5 percent for a 20-bay facility under
the low option). Using the same assumptions as before, a 38-bay facility in-
specting 57,000 vehicles annually would be responsible for 1.6 percent of the
total administrative related annual and startup costs. These changes are
itemized in Table 37. Elements not reported in Table 37 are unchanged.
TABLE 37. COST CHANGES FOR A 38-BAY CENTRALIZED
INSPECTION FACILITY ASSOCIATED WITH
A 1-HOUR REDUCTION IN THE TEST TIME
FOR THE HIGH OPTION
Cost category
Startup Costs
Annual Administrative Costs
Cost element
Software
Salaries
Support Programs
Salaries
Mechanic ' s Training
Public Information
Previous
cost
($)
2,000
85,200
6,000
4,000
1,000
5,000
New cost
($)
3,200
86,700
10,000
6,400
1,600
8,000
The increases in cost were amortized in the same manner as done previously.
The total annualized cost for this approach would be $2,016,150. The inspection
fee can be calculated by dividing the total annualized cost by the average in-
spection demand (90 percent of the 1987 demand) or (57,000)(0.9) = 51,300.
This translates to an inspection fee of approximately $40.00.
A similar analysis was performed for the low option, assuming a reduction
in test time to 15 minutes. With these reduced time requirements, only 20
20-bay facilities would bo needed. Each facility would be required to per-
form approximately 261,000 inspections per year by 1987. Each facility would
then be responsible for 5 percent of the total acfministrative related startup
and annual costs, as opposed to 3 percent in the original assessment. These
changes are itemized in Table 38.
Again, the increases in cost were amortized in the same manner as done
previously. The total annualized cost for the approach would be $1,218,000.
The inspection fee can be calculated by dividing the total annualized cost by
the average inspection demand (90 percent of the 1987 demand) or (167,000)(0.9) =
150,300. This translates to an inspection fee of approximately $8.10.
Additional related sensitivity analyses were performed for these options.
The previous analyses were performed on the impact of time saving modifications
to the inspection procedures. The following sensitivity analyses assume that
the same time savings are achieved, except instead of modifications to the
inspection procedures the savings are assumed due to increased automation
achieved by doubling the equipment costs. The equipment maintenance costs will
also increase proportionately.
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TABLE 38. COST CHANGES FOR A 20-BAY CENTRALIZED
INSPECTION FACILITY ASSOCIATED WITH
A 15-MINUTE REDUCTION IN THE TEST
TIME FOR THE LOW OPTION
Cost category
Startup costs
Annual administrative
costs
Cost element
Software
Salaries
Support Programs
Salaries
Mechanic's Training
Public Information
Previous
cost
($)
6,000
55,000
30,000
12,000
2,400
12,500
New cost
($)
10,000
61,000
30,000
20,000
5,000
25,000
For the high option, the cost changes are as follows:
Equipment $1,031,000 x 2 = $2,062,000
Maintenance 206,200 x 2 = $412,400
The equipment costs must be amortized as before. The total annualized
cost would be $2,016,150 + $901,900 = $2,918,050. This translates to an in-
spection fee of approximately $56.90 for the high option.
For the low option, the cost changes would be:
Equipment $580,000 x 2 = $1,160,000
Maintenance $116,000 x 2 = $232,000
Again, amortizing the equipment costs as before, the total annualized
cost would he: $1,296,800 + $507,400 = $1,804,200 this translates to an in-
spection fee of about $12.00.
A summary of all of the fees calculated is presented in Table 39.
From Table 39, it should be noted that in all instances, the centralized
approaches are cheaper than comparable decentralized approaches. The centralized
inspection fees, however, were calculated on a "breakeven" basis. That is,
no contractor fee was added. A contractor would, of course, receive some return
for its investment and risk. Generally, these fees are on the order of
10 to 15 percent, reducing considerably the differences in fees between these
two approaches.
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TABLE 39. SUMMARY OF INSPECTION FEE ESTIMATES
Inspection fee ($)
Assumptions used
Centralized
Decentralized
High option Low option High option Low option
Base Case $65.60
Test time reduced to 1^ hours 40.00
for high option, and to 15
minutes for low option.
Test time reduced to 1 hour
for high option.
Test time reduced to 1% hours 56.90
for high option, and to 10
minutes for low option; all
equipment costs doubled.
$15.75
8.10
$80.00
47.00
32.00
$16.50
9.00
7.70
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SECTION 8
RESPONDING TO FUTURE EMISSIONS CONTROL TECHNOLOGY
INTRODUCTION
Alternative I/M approaches must be considered in terms of being able to
accommodate new technological developments in emissions control and, for that
matter, in power plant design in general. Also, any program considered should
be sufficiently flexible to accommodate testing of other pollutants such as
NO . In this connection a review of the evolving emissions control technology
and possible new requirements for pollutants considered and what these mean in
terms of inspection and maintenance is in order.
IMPLICATIONS OF FUTURE TECHNOLOGY
In January 1979, EPA promulgated regulations that will require all light-
duty cars and trucks manufactured subsequent to model-year 1980 to meet emis-
sions standards ..."with their engines adjusted to any combination of settings
within the physically adjustable ranges of their adjustable parameters..."
For model-year 1981 vehicles, these requirements will apply to the air/fuel
mixture and the choke parameters only; for model-years subsequent to 1981,
these requirements will be extended to include idle speed and initial ignition
timing, as well. As another example of future emissions control, vehicles
manufactured beginning in model-year 1981 will be equipped with three-way
catalysts as a primary method of controlling CO, HC and NOX emissions. The
use of these devices requires very precise control of the air/fuel ratio as
a function of engine speed and output. This level of control will be achieved
through the use of on-board microprocessors that will provide real-time con-
trol over the. air/fuel ratio and possibly other parameters as well, such as
idle speed, EGR flow rate, AIR system, ignition timing, and others.
The new technological approaches to emissions control will impose new
requirements on all emissions inspections programs. It might be argued that
a tailpipe measurement program will be less affected since the basic inspec-
tion procedure will not change, while a parameter inspection program will
require new, individual inspection tasks and criteria. Such an argument
ignores the fact that, while the Inspection requirements may not change, the
repair requirements do regardless of which type of I/M program is utilized.
In essence, the burden of responding appropriately to new technological
requirements may be placed more directly on the repair industry at large
with tailpipe measurement approach since the program focus is primarily to
assure compliance with established standards as determined by measuring ex-
haust pollutant concentrations, and notwithstanding the particular maintenance
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practices used to bring the vehicles into compliance. From a totally prag-
matic point of view, the burden of maintaining up-to-date knowledge of repair
requirements belongs entirely with the repair industry. Unfortunately,
however, it has been demonstrated that the repair industry does not always
respond adequately to this requirement (particularly with regard to maintain-
ing current awareness of emissions control systems), therefore many I/M pro-
grams have established (or will establish) special mechanics training courses
to prepare the repair industry for its rather critical role in the overall I/M
effort. It can be concluded, then, that within the I/M program administration
there must be concern for ensuring that the repair industry maintains a current
awareness of emissions systems and emissions systems maintenance, regardless
of whether the tailpipe measurement or parameter inspection approach to the
program is utilized.
It is likely that there will be some differences between centralized
parameter and decentralized parameter inspection programs in terms of the
level of effort required from within the I/M program to ensure that inspectors
and mechanics received adequate, periodic training. These differences are
attributed to the requirement for many more inspectors for the decentralized
program compared to the centralized program. It must be assumed that inspec-
tor training is a program function. The actual impact of this expanded train-
ing requirement will not add significantly to the cost of the I/M program.
New vehicles will be less susceptible to tampering and maladjustment
since parameters such as air/fuel mixture and timing will be adjustable only
within a very limited range. Further, the use of electronics in parameter
control will also incorporate diagnostics capabilities to warn of system or
component failures. It could be argued that these changes will result in
vehicles that do not need I/M. In spite of these improvements, I/M will
still be warranted since components are still subject to deterioration and
wear, which means that periodic maintenance will be required.
CONTROL REQUIREMENTS FOR ADDITIONAL POLLUTANTS
Currently, the only pollutants of interest in I/M programs are CO and HC.
There is a rather high probability that for certain regions NOX emissions from
automobiles will require the same type of control as CO and HC. In this con-
nection, then, it is of interest to consider the ability of various I/M program
types to accommodate NOX testing or inspection.
The primary NOX control system used on current generation vehicles is the
EGR system. In terms of parameter inspection programs, the EGR system can be
inspected fairly easily as described previously. For tailpile measurement
programs, however, NOX emissions must be measured when the vehicle is operat-
ing in various modes on a chassis dynamometer since the actual formation of
these compounds occurs primarily during conditions of relatively high engine
speed and load. As indicated previously, future control technology for NOX
will involve the use of reduction catalysts. The only method available for
ensuring that these devices are functioning properly is to actually measure
the exhaust concentrations, which, again, requires the use of a loaded-mode
test. It has been suggested that a visual inspection of the exterior of a
catalytic converter may provide an adequate indication of whether the device
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is functioning; this is based on the premise that a converter that has no
signs of physical damage is likely to be functional. Given the rather precise
control necessary of the air/fuel ratio to ensure proper functioning of the
reduction catalyst, and the fact that poisoning of the catalytic bed can occur
without any external indication of it having happened, it is more likely that
the only reliable indication that either type of catalytic converter (oxida-
tion or reduction) is functioning is to measure the exhaust CO, HC, and NOX
concentrations while the vehicle is operated on a dynamometer.
Another possibility that exists for future emissions control requirements
concerns smoke and particulates from diesel-powered vehicles. Where there are
currently no in-use standards for either smoke or particulates, it is conceiv-
able that such standards could be promulgated, and that testing would be re-
quired as part of an I/M program. The basic tests include measuring opacity
and particulate emissions in the exhaust stream while the vehicle is operating
under a load (again, using a dynamometer). For these particular tests, there
are no relevant parameter inspection procedures.
The central issue in the two possibilities for future test requirements
discussed above is the requirement for a dynamometer; otherwise from either a
technical or administrative standpoint both types of tests could quite easily
be integrated into any of the parameter inspection program concepts under
consideration here. Specifically, .the requirement for loaded-mode emissions
testing generally eliminates the decentralized inspection option from further
consideration because it is very likely that small, independent garages could
neither afford the cost of a dynamometer and still provide the inspection
service for an acceptable cost, nor devote the shop space required for the
dynamometer.
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SECTION 9
SUMMARY
INTRODUCTION
The previous sections have considered several issues related to param-
eter inspection in a general sense, and with specific emphasis on the four
programs defined in Section 1. Presented here is a summary of the key aspects
of the four types of programs considered, and an indication as to how these
aspects differ from those for a tailpipe inspection approach. Separate dis-
cussions are provided for each primary area considered, and for each program
in its entirety.
In an overall sense, motor vehicle emissions inspection and maintenance
(I/M) involves a process whereby motorists are required to have their vehicles
undergo an annual inspection to ensure that the emissions performance of the
vehicle is acceptable; acceptable implies that the emissions characteristics
are within some range that is specified by an emission standard, which con-
siders the vehicle model year, type and size of the engine, and other related
factors. Two general I/M concepts are under consideration for implementation
in the State of Michigan. These include parameter inspection, and tailpipe
measurement.
The intent here is to consider four parameter inspection concepts from
the standpoint of their relative effectiveness, advantages, and disadvantages.*
Also, the relative advantages and disadvantages of selecting parameter inspec-
tion over the tailpipe measurement approach are considered. The parameter
inspection concepts that are of interest at this point do not reflect specific
program choices that may be considered for implementation in the State of
Michigan; rather, they merely reflect concepts on which specific program
definitions may be developed later.
OVERVIEW OF PROGRAM CONCEPTS CONSIDERED
The parameter inspection program concpets considered in this report
include:
• Centralized, high option;
• Centralized, low option;
*The reader should refer to Reference 1 for a detailed review of tailpipe mea-
surement programs, and a more complete discussion of the appplication of I/M
in the State of Michigan.
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• Decentralized, high option; and
• Decentralized, low option.
Obviously, the primary variables among programs are where the inspections
are performed, and what items are considered. The choices regarding where in-
spections are performed were mentioned previously — existing private garages
and repair facilities for the decentralized approach, and special network of
inspection facilities where only inspection-related activity occurs. The com-
ponents that require inspection under the high and low options are discussed
in Section 2.
A complete definition of any I/M program also includes identifying the
affected vehicle types, the geographic area coverage, stringency, repair cost
limits, and provisions for waivers and exemptions. Of these, the specific
vehicle types, geographic coverage, and provisions for exemptions or waivers
are generally not affected by the type of inspection approach selected. Strin-
gency refers to the expected number of vehicles that will require maintenance
because of failing the inspection. In the case of parameter inspection, there
will be no predetermined failure rate; rather, any vehicle that is found to
have malfunctioning emissions-related components will require appropriate main-
tenance. Repair cost limits for parameter inspection programs may be specified
separately for individual components subject to inspection. Further, repair
rates for various common maintenance items, such as adjusting the air-to-fuel
ratio, may be controlled to some degree.
Several support programs are required for I/M regardless of the particular
inspection approach selected. These include public information, mechanics
training, inspector training, quality assurance, and enforcement. These support
programs are not particularly sensitive to the inspection approach in an overall
sense, although the specific focus of any of these may be influenced greatly by
the inspection type. This also applies to the administrative structure used for
overall program control. The general composition of the administration structure
depends more on the particular wishes and desires of those responsible for im-
plementing and operating the program than on any overriding factor related to
the inspection approach.
The four parameter inspection concepts can be compared with the tailpipe
measurement approach in terms of general format. Like the parameter inspection
concept, the tailpipe measurement approach can operate as a centralized or
decentralized program using essentially a high or low option. The facility
considerations are identical for the parameter and tailpipe measurement
approaches. Generally, if the decentralized approach is used, the inspection
stations are required to be certified or licensed by and responsible to the
state agency administering the program. With regard to the inspection technique,
the high option can be considered as the use of a loaded mode test, while the
low option can be considered an idle test. In either case, however, the only
inspection item is the exhaust emissions levels measured by an exhaust analyzer.
Whereas with the parameter inspection concept any combination of high or
low option and test facility type is appropriate, the possibilities are somewhat
limited for the tailpipe measurement approach. Essentially, the decentralized
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approach to tailpipe measurement must use an idle test rather than loaded mode
Owing to the rather expensive and space consuming equipment required to perform
loaded mode testing.
As with parameter inspection, the vehicle types affected, geographic coverage,
and exemptions and waivers all involve policy considerations and are not specifi-
cally influenced by the type of inspection used. Generally, tailpipe measure-
ment programs establish emissions standards that reflect a point somewhere between
the 70th and 90th percentile emissions rate for various categories of vehicles,
so that the expected failure rate is between 10 and 30 percent.
Resource requirements describe the equipment, time, and expertise required
to perform the inspections. For the parameter inspection approach these require-
ments vary only as a function of the inspection items included; large differences
can be expected, therefore, in the requirements for the high and low options.
The high option requires a significant amount of time to perform. It is
estimated that the time range is between 1-1/2 and 5 hours, with an average that
is close to 2-1/2 hours. Although equipment requirements are not significant,
essentially only common hand tools with a few speciality items are required,
the level of expertise required is quite high. It is envisioned that only an
experienced, highly trained mechanic or technician could properly perform many
of the inspections and adjustments related to the carburetor. On the other
hand, the low option requires a modest amount of time — estimated to be approxi-
mately 30 minutes — and only common tools and equipment. The level of expertise
required is not nearly as demanding as that for the high option, yet it is
assumed that the inspection would be performed by an experienced tune-up
mechanic.
The tailpipe measurement approach requires an emissions analyzer as a
minimum, which Is a fairly expensive item. For centralized operations, the
emissions analyzer must be designed to accomodate high throughput efficiently
and accurately. Usually, this means adding the capability of interfacing with
a computer for both data recording and standards determination. For the loaded
mode inspection process, a chassis dynamometer is required, which is also expen-
sive. Again, if the loaded mode is used, it is usually desirable to interface
a data handling system as well as the emissions measurement function so that
the entire operation becomes highly systematized. The level of expertise re-
required to perform the inspections is not as high as that for either of the
parameter inspection concepts. The inspection procedures are relatively
straightforward, although there is generally a requirement for the inspector
to be able to interpret the results for those vehicles that fail the test.
Tailpipe measurement in centralized facilities using automated data handling
systems requires approximately 2 to 5 minutes. For the decentralized approach,
it can be expected that inspections will require approximately 10 to 15 minutes
to perform.
Although it would appear that both approaches are actually based on achieving
the same end — assuring that infuse vehicles are properly maintained in order to
minimize omissions — arguments against each approach have been voiced by those
apparently in favor of the opposite approach. Those favoring the tailpipe
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measurement approach generally consider parameter inspection as being akin to
mandatory maintenance, which is politically undesirable. On the other hand,
those favoring parameter inspection tend to disagree with the premise that a
short emissions test can provide an acceptable indication of a vehicle's emis-
sions characteristics during actual use.
To discuss the relative merits of various approaches to I/M, a number of
questions regarding the potential effectiveness in reducing emissions, costs,
and other impacts of each program type must be answered. Also, questions must
be asked regarding whether the approaches under consideration are likely to
meet special requirements that might exist, and whether adverse public, institu-
tional, or political reactions might occur that would effectively block
implementation.
RELATIVE EFFECTIVENESS IN REDUCING EMISSIONS
The underlying premise in the parameter inspection approach to I/M is that
if all emissions-critical components and systems are functioning in accordance
with manufacturer's specifications, then the optimum level of emissions control
will be achieved. The high option represents an attempt to ensure that all
possible systems and individual parameters are within specifications, regardless
of the probability that they are out of adjustment or not functioning, and with-
out concern as to the magnitude of the actual impact that each component has on
emissions. Limited studies have indicated that there are a relatively few
specific components that can be expected to require routine, periodic main-
tenance of the type that would be appropriate for an I/M program. Primarily,
these components include the idle speed setting, the idle mixture, initial
timing, and the EGR system. An extremely important objective in selecting
parameters to be included in the program is to select those that are most likely
to result in a direct emissions benefit, and at the same time, are appropriate
in terms of the resources required to perform the inspection. That this objec-
tive is not achieved in the proposed high option is evident upon considering
the time requirement and procedures that are used to perform some of the inspec-
tion tasks.
At present there are no specific data that provide a clear definition of
the actual impact that a parameter inspection program would have on emissions.
Based on the Restorative Maintenance (RM) study referred to in Section 3, it is
possible to assume that a parameter inspection program designed around the low
option concept would have a positive impact on emissions. Many questions re-
main, however, regarding the actual level of reduction that could be expected.
The RM program was limited in scope to model-year 1975 and 1976 vehicles that
had accrued fewer than 15,000 miles of use; a basic question at this point is
whether the test results from this limited sample can be extrapolated to older
vehicles, or to the same model-year vehicles after several additional years of
use. A major requirement for any state contemplating the implementation of an
alternative I/M program, such as parameter inspection, is to develop and sub-
stantiate estimates of emissions reductions achievable.
The effectiveness of any I/M program will be affected by the choice of
the centralized or the decentralized approach. The primary difference in the
two approaches is the level of control that can be exercised over both the
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inspection and maintenance phases. By their nature, decentralized programs
involve many more inspectors and inspection facilities serving a wider range
of interests compared to a centralized program. Quality control and surveillance
are much more difficult with the decentralized approach, therefore, the potential
reduction in emissions with this approach is likely to be lower than that of a
centralized program. Issues concerning consumer skepticism and consumer pro-
tection are more crucial with a decentralized program, as well. In terms of
reducing consumer costs and inconvenience, it would be highly desirable to
incorporate some repairs into the inspection phase with parameter inspection
programs. If the centralized approach is used, a serious problem may be
encountered concerning whether or not the state (or whatever governmental entity
is responsible for the program) or an agent of the state can, in fact, become
involved directly in the repair of motor vehicles. It would appear that a
contractor-operated inspection program would present fewer problems in terms
of state involvement in a sector of private industry; this would be particularly
true if there were more than just one or two contractors involved in the program.
The impact of tailpipe measurement programs on emissions from in-use vehicles
has received, and is continuing to receive, substantial study by EPA. The basic
conclusion that these programs are effective in reducing emissions has been
documented. In essence, this implies that the various short tests, including
the basic idle test, adequately reflects a vehicle's emissions characteristics
in actual use. Whether or not the short test adequately portrays this ability
is a point that has been debated between the auto industry and EPA. Data con-
cerning the types of repairs most frequently required to bring vehicles into
compliance with short test standards, and data from the RM study as well as
the focus of the inspection items in the parameter inspection concept (low
option) suggested by the manufacturers, indicate that the various opinions as
to which approach is more effective may not be as diverse as they might appear
to be on the surface.
An additional issue regarding the effectiveness concerns the ability for
the programs to accomodate vehicles using future technology emissions control
systems. Many of the control concepts for the future will involve electronic
control of parameter settings, as well as advanced exhaust treatment concepts
such as reduction catalysts in conjunction with strict parameter control. Based
on current information, there does not appear to be a large difference between
the abilities of a parameter inspection program and a tailpipe measurement pro-
gram using the idle mode test to accomodate new technology vehicles. On the
other hand, if control of NOX emissions becomes a requirement, then both of
these test types may prove to be inadequate. Currently, the primary NOx control
system is the EGR system, which can be inspected visually. Future control will
require a reduction catalyst, the effectiveness of which cannot be determined
visually. Further, NOx emissions can only be characterized by a measurement
procedure when the vehicle is operating in a loaded mode (e.g., accelerating,
high cruise, etc.), therefore, the idle mode emissions measurement technique
is not applicable. The only acceptable test for NOx will likely be loaded
mode tailpipe measurement.
Several conclusions can be presented at this point regarding the potential
effectiveness of the parameter inspection concept in reducing emissions. First,
the rationale for parameter inspections — that is, if all emissions-sensitive
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systems and parameters are properly adjusted and repaired, emissions will be
minimized — is sound. In fact, this is essentially the same premise on which
any I/M program is based. However, given the rather poor performance record
of the repair industry, it is doubtful that a parameter inspection program
would guaranty that all deficiencies would be identified and corrected.
While the same argument applies to the tailpipe measurement approach, emissions
testing does provide a reasonable indication of whether or not various emissions-
sensitive systems, components, and parameters are functioning properly. Further,
the parameter approach requires that all vehicles undergo a rigorous inspection
without regard to the actual emissions performance. Numerous studies have in-
dicated that relatively few (certainly less than 20 percent) vehicles are gross
emitters, which are really the focus of I/M. The reasonableness of requiring
all vehicles to be subjected to this relatively rigorous inspection must be
considered carefully in terms of cost effectiveness. On the other hand, tail-
pipe measurement has been demonstrated to be a relatively simple and reasonably
accurate method for identifying gross emitters, although errors of commission
and omission do occur with this method (and with the parameter approach as well).
The second conclusion concerns the ability to adapt to new inspection
requirements imposed by future emissions control technology. Generally, there
will be differences between the ability of a parameter program and a tailpipe
measurement program, but these will not be extremely significant. If NOX
testing is required in the future, neither parameter inspection or idle-mode
emissions testing may be adequate since some form of loaded-mode emissions
testing may be essential.
Third, regardless of which inspection approach is selected, the choice of
using centralized or decentralized facilities may have a significant impact on
the actual emissions reductions achieved. In general, it can be expected that
quality control will be much more difficult with a decentralized program for
several reasons, not the least of which is the much larger number of inspectors
involved, and the fact that there may be significant motivation to either over
inspect or under inspect, depending on the inspection fee rate structure. These
factors can seriously jeopardize the effectiveness as well as the credibility
of the program.
Finally, the last major conclusion regarding the effectiveness of the
parameter inspection concepts considered here is that the high option does not
reflect a viable approach to I/M owing primarily to both the excessive time
required to perform the inspections and the lack of any evidence that many of
the more time consuming inspection tasks would provide a measurable increase
in the emissions benefits received.
PROGRAM COSTS
The relative costs of the four parameter inspection concepts vary directly
with the intensity of the inspection process. The cost calculated for the four
programs range from about $16.00 for a low option inspection performed in a cen-
tralized facility, to approximately $80.00 for a high option inspection per-
formed at a private garage. Within this range is the low option decentralized
inspection, estimated to cost about $16.50, and the high option centralized in-
spection costing approximately $65.00.
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These costs can be compared directly with those associated with tailpipe
inspection programs. Generally, tailpipe inspection programs have been shown
to have break-even fees of approximately $5.00 to $8.00; for any given program,
the cost of the loaded mode test is generally about the same as that for the
idle mode.
The relative costs of T/M program alternatives must consider repair costs
and coats for traveling; and personel time associated with obtaining repairs and
reinspections, in addition to the basic inspection cost. If the assumptions
are made that (1) parameter inspection eliminates the need to travel elsewhere
for repair, (2) repairs, adjustments, and parts replacement is significantly
less costly if performed as part of the inspection process, and (3) the quality
of diagnosis and repair if performed as part of the inspection is the same as
that expected elsewhere, then the overall cost differential between tailpipe
inspection and parameter inspection becomes much less significant. On the
other hand, without the capability of consolidating the inspection and repair/
adjustment routines, the parameter inspection approach may prove to be totally
impractical from the cost standpoint.
OTHER RELATED IMPACTS
Consumer Issues
Many of the essential consumer protection elements that apply to tailpipe
testing will apply to an I/M program involving parameter testing as well. The
applicability, nature, and scope of some measures are dependent on the type of
I/M program implemented. For example, although the concept of repair cost
limits applies to both tailpipe and parameter inspection approaches, the specific
provisions may vary depending on the test type selected. For parameter inspec-
tions, one related consumer protection measure would be the development of
specific repair and adjustment procedures that would represent the maximum
requirement, and provide motorists with a list of reasonable rates for typically
required repairs.
Another important consumer protection consideration involves the applica-
bility of the 207(b) warranty provisions under a parameter inspection approach
to I/M. 207(b) establishes a close relationship between the I/M program and
the warranty claim itself. Specifically, 207(b) requires as a prerequisite to
a valid claim, that the vehicle must have failed an approved short test, which
would set into motion a procedure bringing about a sanction or action, such as
the withholding of vehicle registration.
Parameter inspections are not currently being considered in this regard.
However, future inclusion has not been ruled out.
Assuming the parameter approach will gain approval, the applicability of
207(b) will still depend on the nature of the parameter inspection. If the
inspection process is limited to misadjusted, improperly maintained, or tampered
with components warranty claims would be severely limited. If the process is
such that repair of any defective components uncovered while setting parameters
is required, then 207(b) would apply (provided all other criteria were met).
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Repair Industry Impacts
One other consumer protection measure that has serious impacts on the
repair industry is the question of combining or separating the repair and
inspection process. Combining parameter inspection with adjustment and repair
could create a conflict of interest, particularly if additional charges are made
for adjustments or repairs. This would, for all practical purposes, eliminate
a centralized, contractor- or state-operated parameter inspection approach. If
repairs and adjustments are included in the parameter inspection scenario, many
motorists could actually substitute the inspections for annual minor tuneups.
Therefore, a state-operated program could shift a lot of business from the
private to the public sector. A contractor-operated program would likely be
viewed by the industry as the state allowing a single entity to monopolize the
minor tuneup business. To allow a single entity, either private or public, to
control this entire market will not likely be viewed favorably by the private
garage industry in Michigan.
Alternatively, separating parameter inspection and adjustment would involve
considerable duplication of effort. These issues make a decentralized parameter
inspection approach much more feasible. This introduces the problem of alloca-
tion of inspection and repair work. Allowing all stations to participate will
ensure a more equal distribution of the additional workload. Additionally,
a much more intensive quality assurance and consumer protection effort would
be required. By limiting the participation in the program, the created work-
load will be disproportionately alloted to certain entities.
Demand for Trained Mechanics—
Any of the I/M options evaluated here will increase the demand for mechanics
and mechanics training. The increased demand for mechanics may serve as a mecha-
nism to drive up wage rates for those who are qualified. The extent of this
supply/demand problem will depend on the ability of the industry to fill posi-
tions created by the increased demand, some lag is inevitable. Because of this,
windfall profits may accrue to existing shops for some initial lag period,
particularly in the case of a program that separates the inspection and repair
components. The tight supply situation, if unchecked, could lead to more fre-
quent overcharging until the increased demand is met with additional mechanics.
The subject content of mechanic training programs and certification tests
should not vary considerably between a parameter inspection program and one
that incorporates tailpipe testing. Under a parameter inspection approach,
inspectors will essentially be trained as mechanics, whereas in a tailpipe
approach, the inspectors only need to be proficient at measuring emission
levels properly.
Quality Assurance—
One problem that is common to all parameter inspection approaches is that
measuring program effectiveness will be extremely difficult if not altogether
impossible. Without actually measuring emission levels, there will be no
assurance that the I/M program is actually meeting its objective of reducing
vehicular emissions. To ensure that the program is in fact bringing about a
significant emission reduction, either a "before or after" emission measurement
would have to be made on all vehicles, as in Nevada, or a random sample of
vehicles would have to be checked.
117
-------
Administrative Requirements
The administrative requirements, in terms of the specific tasks and respon-
sibilities involved, will not vary significantly between an I/M program incor-
porating tailpipe testing and one involving parameter inspections. There are
differences in the number of individuals required to perform specific tasks.
The choice of a decentralized rather than a centralized program, for example,
will necessitate more consumer protection/quality assurance investigators since
the state will have far more inspection facilities to monitor. Selection of
the high option parameter inspection instead of the low option will result in
similar increases in the administrative staff. The overall administrative
requirements are fairly constant regardless of whether a parameter inspection
or tailpipe measurement approach is utilized.
Issues Requiring Special Consideration
Throughout the discussion it has been mentioned that the parameter inspec-
tion approach should include both inspection and repair or adjustment as part
of the inspection process. An important issue in this connection is the legal
implications of the state becoming involved in the repair of motor vehicles.
This potential problem surfaces only with the centralized approach. The use of
contractor-operated, centralized facilities may deminish the problem particularly
if several different contractors are involved.
Another issue concerns the expected duration of the program. A basic
question here concerns whether or not the program would continue if it were
demonstrated that it wasn't required to maintain air quality objectives. If
there is a possibility that the program would not be operated past, say, 1987,
then this fact should be considered in selecting a particular option since a
heavy capital expenditure for equipment and buildings may not be desirable for
a relatively short-term program.
Ability to Satisfy Minimum EPA Policy
Consideration must be given to the ability of the program to meet various
statutory requirements imposed by EPA. The primary requirements concern the
minimum reduction in emissions achievable, and basic program elements used.
Regarding the issue of minimum emissions reductions, EPA requires that exhaust
emissions from light-duty vehicles be reduced by 25 percent by 1987, compared
to what they would have been without I/M. The problem here is that there is
currently no available method or data base that can be used to easily develop
an estimate of the emissions reductions expected over time with a parameter
inspection program. Further, EPA requires that the State proposing an alter-
native approach to tailpipe measurement (e.g., parameter inspection) demon-
strate adequately that the reauired emissions reductions will be achieved.
In this connection, if the State of Michigan proposes to adopt the parameter
Inspection approach, It may be faced with a rather significant task of devel-
oping nnd substantiating estimates of the programs effectiveness in reducing
pm 1 s s i on s .
118
-------
A second issue that must be considered is the requirement (although one
that must be considered tentative at this point) that all decentralized I/M
programs include measurement of exhaust emissions. The parameter inspection
routines considered here do not include such a provision, although it could
be easily incorporated. The more critical issue concerns how the tailpipe
measurement is to be used in the parameter inspection approach. It is not
clear that there is any specific requirement that the measurements be used for
anything more than emissions data collection (obviously, where NOX is of concern,
a tailpipe measurement procedure is required). Including emissions measurement,
however, raises questions as to whether or not the measurements should provide
a screening function to determine which vehicles actually require the parameter
inspection. This means that the pass/fail criteria would be based on a short
emissions test, which is perhaps not acceptable to those who favor the parameter
inspection concept.
119
-------
REFERENCES
1. Bhatia, V., et al. Pacific Environmental Services. Santa Monica, California.
Evaluation of Motor Vehicle Emissions Inspection and Maintenance Programs for
the State of Michigan. Volume II. Prepared for U.S. Environmental Protec-
tion Agency, Region V Office. Chicago, Illinois. EPA Report No. EPA-905/
2-79-003b. October 1979.
2. Ibid.
3. Lucas, Albert G., and Robert L. VanCura. A Parameter Inspection and
Adjustment Approach to Vehicle Emissions Inspection and Maintenance.
General Motors Corporation. Environmental Activities Staff. June 1979.
4. Bernard, Jefferey C., and Jane F. Pratt. An Evaluation of Restorative
Maintenance on Exhaust Emissions of 1975 Through 1976 Model Year In-Use
Vehicles. Calspan Corporation, Buffalo, New York. Prepared for U.S.
Environmental Protection Agency, Office of Mobile Source Air Pollution
Control. Ann Arbor, Michigan. EPA-460/3-77-021. December 1977.
5. U.S. Environmental Protection Agency. Office of Air and Water Programs.
Memorandum from David G. Hawkins. Inspection/Maintenance Policy.
17 July 1978.
6. 40 CFR 51.328. Appendix N. Emissions Reductions Achievable Through Inspec-
tion, Maintenance and Retrofit of Light-Duty Vehicles. Environment Reporter.
Bureau of National Affairs, Inc. Washington, D.C, 24 August 1979.
pp. 125:0143 through 125:0146.
7. User's Guide to MOBILE1: MOBILE SOURCE EMISSIONS MODEL. U.S. Environ-
mental Protection Agency. Office of Air, Noise, and Radiation. Washington,
D.C. 20460. August 1978.
8. Bhatia, V., et al., op. cit.
9. Rochester Products Division, General Motors Corporation. Rochester
Carburetor Diagnosis, Adjustments, and 1978 Specifications. November 1977.
10. 1977 General Motors Emission Control Systems Maintenance Manual. Service
Section, General Motors Corporation. Detroit, Michigan. 1977.
11. An Evaluation of Restorative Maintenance on Exhaust Emissions of 1975
Through 1976 Model Year In-Use Automobiles. U.S. Environmental Protection
Agency. Office of Air and Waste Management. Mobile Source Air Pollution
Control, Emission Control Technology Division. Ann Arbor, Michigan 48105.
EPA-460/3-77-021. December 1977.
120
-------
12, Austin, T.C., and G. Roberstein. A Comparison of Private Garage and
Centralized I/M Programs. Society of Automotive Engineers. Paper No.
790785. August 1979.
13. Federal Register. Wednesday, August 9, 1979. Voluntary Aftertnarket Part
Self Certification Regulations; Proposed Rule EPA.
14. Feldman, David. U.S. EPA Attorney. Mobile Source Enforcement Division,
Washington, D.C. Conversations August 21 and September 11, 1979.
15. Nash, R.W. Letter to GCA/Technology Division. Dated 17 September 1979.
U.S. EPA, Ann Arbor.
121
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APPENDIX A
DIAGRAMS SHOWING VARIOUS CARBURETOR INSPECTION AND
ADJUSTMENT PROCEDURES FOR THE HIGH OPTION
122
-------
MODEL 1M & 1ME CARBURETOR
ADJUSTMENTS
1
©:
GAUGE FROM TOP OF
CASTING TO TO* OF
INDEX POINT AT TOE
OF R.OAT
(a^BEND HERETO
^ ADJUST FLOAT
UP OR DOWN
FLOAT LEVEL ADJUSTMENT - ALL
^\©:
HOLD FLOAT RETAINING
PIN FIRMLY IN PLACE -
PUSH DOWN ON END OF
FLOAT ARM. AGAINST
TOP OF FLOAT NEEDLE
jHOLD POWER
PISTON DOWN AND SWING
METERING ROD HOLDER
OVER FLAT SURFACE
(GASKET REMOVED!
OF BOWL CASTING NEXT
TO CARBURETOR BORE
^REMOVE METERING ROD
BY HOLDING THROTTLE
VALVE WIDE OPEN. PUSH
DOWNWARD ON METERING
ROD AGAINST SPRING
TENSION, THEN SLIDE
METERING ROD OUT OF
SLOT IN HOLDER AND
REMOVE FROM MAIN
METERING JET.
i 4JSPECIFIED PLUG
GAUGE - SLIDE FIT
BACK OUT IDLE
STOP SOLENOID-
HOLD THROTTLE
VALVE COMPLETELY
CLOSED
METERING ROD ADJUSTMENT - 6 CYL. - ALL
©
BACK OUT IDLE
STOP SOLENOID MOLD
THROTTLE VA.VE
COMPLETELY CLOSED
SPECIF'ED GAUGE
SHOULD HAVE A SLIDE
FIT BETWEEN TOP Of
BOWL GASKET REMOVED
4ND LO.VEB EDGE Of
METEB,\G BOO HOLDER
NOTE
DO NOT PUSH DOWV
ON POWER PISTON
METERING ROD ADJUSTMENT - 4 CYL. -1ME
SUPPORT LEVEP, WTH
PLIERS-BEND TANG IN
OB OUT TO OBTAIN SPECIFIED
FASTIDLERPM iSEE INSET,
PLACE CAM FOLLOWER
TANG ON HIGH STEP
OF CAM (SEE NOTE!
NOTE MANUALCHOKE
MODELS WITH SMOOTH
CONTOUR CAM SURFACE
ROTATE FAST IDLE CAM
CLOCKWISE TO ITS
FARTHEST UP POSITION
PREPARE VEHICLE FOR
ADJUSTMENTS -
SEE EMISSION LABEL
ON VEHICLE IGNITION
TIMING SET PER LABEL
FAST IDLE CAM
STEPS
7*-
©ADJUST CURBKX.E
SPEED WITH IDLE STOP
FAST IDLE ADJUSTMENT - 6 CYL. - ALL
-------
NOTE. DO NOT PERFORM THIS
~ ADJUSTMENT OH MODELS
' MTH AM IDLE-OAStVOT
0:
3 )TVIH« FAST
SCREW IN
OR OUT TO OBTAIN
SPECIFIED FAST IDLE
RfM. - SEE DtCAL.
(2JPLACE FAST
'IDLE SCREW ON
HIGHEST STEP OF
FAST IDLE CAM
FAST IDLE ADJUSTMENT - 4 CYL. - 1 ME
( 2JHOLD CHOKE VALVE
^-^COMPLETELY CLOSED
12CT PLUG
GAUGE MUST
PASS THROUGH
HOLE IN LEVER
AND ENTER HOLE
IN CASTING
0BEND LINK
Tf\ AO H tcr
(T)PLACE FAST OH
^-^LOW IDLE SCREW
OH CAM FOLLOWER
ON HIGHEST STEP
OF FAST IDLE
CAM
CHOKE COIL LEVER ADJUSTMENT 4 & 6 CYL. - 1 ME
INDEX
0
1 JLOOSEN THREE
RET AIMING SCREWS
mTH CHOKE COM. LEVER LOCATED
IDe OWL TAHG (SEE INSETI-
SET MARK ON ELECTRIC CHOKE
TO SPECIFIED POINT ON CHOKE
HOUSING
PLACE FAST IDLE SCREW
OR CAM FOLLOWER ON
HIGH STEP OF CAM
AUTOMATIC CHOKE ADJUSTMENT - 1 ME
8
©
HOLD DOWN
ON CHOKE VALVE-
ROD IN END OF SLOT
©BEND ROD AT
POINT SHOWN
TO ADJUST
GAUGE BETWEEN LOWER
EDGE OF CHOKE VALVE (AT
CENTER) AND INSIDE »»
HOfWWALl
WITH FAST IDLE
ADJUSTMENT MADE
FAST IDLE SCREW OR
CAM FOLLOWER MUST
BE HELD FIRMLY ON
SECOND STEP OF FAST
IDLE CAM AGAINST
HIGHEST STEP
FAST IDLE CAM (CHOKE ROD) ADJUSTMENT
-------
NJ
©
©
POCE GAUGE
BETWEEN LOWSR EDGE
OF CHOKE VALVE AND
INSIDE AIR HORN WALL
USE OUTSIDE
VACUUM SOURCE
TO SEAT
DIAPHRAGM
NOTE ON DELAY FEATURE"
MODELS. COVER PLUG AND
PURGE BLEED HOLE WITH 1
SQUARE PIECE OF MASKING
TAPE. REMOVE AFTER
ADJUSTMENT —
PUSH OOVH* 01
CHOKE VAV.VE
.COMPRESS PLUNGER
BUCKING SPRING AND
SEAT PLUNGER STEM
ON MODELS SO
EQUIPPED"
0
PLACE FAST
IDLE CAM
FOLLOWER ON
HIGHEST STEP
OF CAM
VACUUM BREAK ADJUSTMENT - 1ME {BOWL SIDE)
10
CD INSTALL CHOKE COIL IN
CHOKE HOUSING AND INDEX
PROPERLY ISEE NOTE,
NOTE IF CHOKE COIL IS
WARM COOL DOWN TO
POINTWHERE CHOKE _'
VALVE WILL CLOSE
FULLY
GAUGE BETWEEN LOWER
EDGE OF CHOKE VALVE
AND INSIDE AIR HORN
WALL ISEE NOTE)
I HOLD THROTTLE
VALVE WIDE OPEN
\
BEND TANG TO
ADJUST ISEE INSET)
UNLOADER ADJUSTMENT - 1ME
11
) ENGINE MUST Br
WARM-CHOKE WIDE OPEN
FAST IDLE SCREW OR CAM
FOLLOWER OFF STEPS OF
CAM ISEE EMISSION LABEL I
TO ADJUST LOW
!«.£ TURN \IT
HEX SCREW
(SOLENOID NOT
ENERGIZED!
CURB IDLE
TO SPECIFICATIONS TURN
ASSEMBLY IN OR OUT
TO ADJUST RPX.
(SOLENOID ENERGIZED)
IDLE STOP SOLENOID ADJUSTMENT - ALL
12
SOLENOID ENERGIZED -
A C COMPRESSOR LEAD
DISCONNECTED »T A C
COMPRESSOR A C ON AT
IN DRIVE
©
ENGINE MUST BE
WARM - CHOKE WIDE OPEN -
FAST IDLE SCREW OFF STEPS
OF CAM - AUTO TRANS
IN DRIVE (SEE
EMISSION LABEL)
UBN SOLENOID
ASSEMBLY TO ADJUST <
TO SPECIFIED RPM
(RECONNECT AC
COMPRESSOR LEAD AFTER
ADJUSTMENT)
© OPEN THROTTLE SLIGHTLY
TO ALLOW SOLENOID *;-. ,
PLUNGER TO FULLY •' C) J f7\
^^ — W TURN 1 8 HEX SCREW OUT TO SET CURB
IDLE SPEED TO SPECIFICATIONS -AC
Off (SEE EMISSION LABEL)
EXTEND
IDLE SPEED ADJUSTMENT
-------
No
13
o
)WITH LOW IDLE SPEED
SCREW ON LOW STEP OF
CAW TURN SCREW TO
ADJUST CURB IDLE SPEED
TO SPECIFICATIONS
1 'lEMGINE MUST BE WARM -
CHOKE WIDE OP6N - OASHPOT
PLUNGER NOT OONTACTING
TANG ON THROTTLE LEVER
ISEE EMISSION LABEL)
^X
LOW IDLE SPEED
ADJUSTED AND SCREW
ON LOW STEP OF CAM
TURN DASHPOT ASSEMBLY
IN UNTIL PLUNGER END
JUST TOUCHES TANG ON
THROTTLE LEVER - THEN
TURN ASSEMBLY IN
SPECIFIED NUMBER
OF TURNS
IDLE-DASHPOT ADJUSTMENT - 4 CYL. M/T
ALTITUDE & CALIF. (CHEVETTE)
14
. USING OUTSIDE VACUUM
SOURCE APPLY SL/FFICIEM
VACUUM TO THE ACTUATOR
TOEXTE\0 THE PLUNGER FULLY
NOTE ENGINE MUST BE
WARM - CHOKE iVIOE OPEN -
CAM FOLLOWER OFF OF STEPS
FAST IDLE CAM
TURN PLUNGER SCREW
IN OR OUT TO OBTAIN
SPECIFIED RPM !»•'
1600 RPM "
IN NEUTRAL
' MANUALLY OPEN
THROTTLE SLIGHTLY
AND ALLOW TO CLOSE
AGAINST EXTENDED
PLUNGER
ADJUST CURB IDLE SPEED
WITH IDLE SPEED SOLE-
NOID ISEE LABELI
THROTTLE LEVER ACTUATOR ADJUSTMENT
-------
N3
—I
FLOAT GAUGE - EXTERNAL CHECKING PROCEDURE
On 1S78 and past model Oualfet and
Quadrajet carburetors 'except those using a
screen over the vent slot §n the air horni. it is
now possible to externally check the foat tevel
using a new float gauge J-9789-130' or
BT-7720" This gauge is des.gned for fielc
use in auicklv and accurately measunng exter-
nally the float level on Dualjet and Quadrajet
cartxjretors to eliminate the need to remove the
carburetor air horn to check float levels Using
the gauge, the float level may be checked
"on-the-car' with the engine running
•Currently available from Kent-Moore Tool Division
''Currently available from Burroughs Tool & Equipment Corp
©
WITH EMGIME mamma AT DUE.
.
•mill GAUGE m V€KT SLOT
Cm KBIT MOVE (NEXT TO AM
CLEANER •OUNTMG STUD) «
SE GAUGE I
©WWNG AT EYILEWL. OBSERVE ALLO» .T TO FLOAT F«gLT
MAJK ON GAUGE THAT LWES UP
wmi TOP OF CASTING AT THE
VEKT SLOT 0« VENT HOLE-
SCTTMG SHOULD K VTTHHI
-.1 w FAOM spconeo FLOAT -
LEVEL srrnwc
REMOVE FLOAT GAUGE
FROM AIR HORN.
CAUTION: 00 HOT PKESS OOVM
ON GAUGE TO CAUSE FLOOOMG
OH DAMAGE TO FLOAT
©
'JIF THE MECHANICAL SETTING
(STEP 2) VARIES OVER :1 *" FROM
SPECIFICATIONS. REMOVE AIR
HORN AND ADJUST FLOAT
LEVEL TO SPECIFICATIONS
FOLLOWING NORMAL ADJUST-
MENT PROCEDURES.
FLOAT GAUGE — EXTERNAL
CHECKING PROCEDURE
(DUALJFT AND OUADflAJCT - TTPICAL)
FLOAT GAUGE - EXTERNAL CHECKING PROCEDURE
1 With the engine running at idle, choke wide-open, carefully insert gauge in vent slot or vent
hole (next to air cleaner mounting stud) in air horn. Release gauge and allow it to float freely.
2 Reading at eye level, observe mark on gauge that lines up with top of casting at the vent slot
or vent hole. Setting should be withm ± 1,16" from specified float level setting
3 If the mechanical setting (Step 2) varies over z 1 < 16" from specifications, remove air horn
and adjust float level to specifications following normal adjustment procedures
CAUTION: Do not press down on gauge to cause flooding or damage to float.
-------
M2MC-M2ME DUAUET CARS. 210 ADJUSTMENTS
vl/ GAUGE FROM TO" Q* CASTING TO TO»
O* CL.GAT - GAUGISC »Ct«tT 3 ig BACK
FROM EHC Of CLOA" AT TCc SEE .^S6T
VL' PUSH FLOAT DO1
ro
oo
s AFTER ADJ JS
FLOAT ADJUSTMENT
2
1GAUGE FROM TOP OF CHOKE
VALVE WALL N£Xr TQ vE\'
STACK TO TOP
OF PUMP STEM
AS SPECIFIED
ROD pS SPECIFIED MOLE
P'JMP L
©
/SUPPORT LEVER WITH
SCREWDRIVER WHILE
BENDING LEVEP
THROTTLE VALVES
COMPLETELY CLOSED
NOTE MAKE SURE FAST !OlE
CAM FOLLOWER LEVER IS OFF
STEPS ON FAST IDLE CAM
PUMP ADJUSTMENT
'eeMD CHOKE ROD
ATTHISPOdfr
TO ADJUST
(SEE INSET).
QtOKEJMLVE
CLOSED
2) PUSH UP OH THEflHOSTATJC
COIL TAMG (COUNTERCLOCKWISE)
UNTIL CHOKE VALVE IS CLOSED
LOWER EDGE OF LEVEH SHOULD
JUST CONTACT SIDE OF PLUG
GAUGE
INSERT SPECIFIED
PLUG GAUGE
0 LOOSEN THREE RETAINING SCREWS AND
REMOVE THE THERMOSTATIC COVER AND
COIL ASSEMBLY FROM CHOKE HOUSING
PLACE FAST IDLE CAM
FOLLOWER ON HIGH STEP
OF FAST IDLE CAM
CHOKE COIL LEVER ADJUSTMENT
PIACE CAM FOLLOWED
ON PSOPER STEP Of
FAST IOl£ CAM PER
UNO€RHOOO HJNE UP LABEL
r1
1 TURK FAST itXE SCREW
' TO MOPW flPM S - l»tfl
SPEC OM UNDERHOOO
TU«*f UP LABEi
FAST IDLE ADJUSTMENT (ON CAR)
-------
N)
FK3UHE1
1 MAKE f AST IDLE ADJUSTMENT (BENCH OR ON THE-CAB SETTING)
i USE CHOKE VALVE MEASURING GAUGE J-STCI OR 8T-7704 TOOt MAY
BE USED WTTH CARBURETOR ON OR OFF ENGINE IF OfF ENGINE. PLACE
CARBURETOR ON HOLDING FIXTURE SO THAT IT WILL REMAIN IN
SAME POSITION WHEN GAUGE IS IN PLACE
1 ROTATE DEGREE SCALE UNTIL ZERO 101 IS OPPOSITE POINTER
4 WITH CHOKE VALVE COMPLETELY CLOSED. PLACE MAGNET SQUARELY
ON TOP Of CHOKE VALVE
S. ROTATE BUBBLE UNTIL IT IS CENTERED
FIGURE 2
6 ROTATE SCALE SO THAT DEGREE SPECIFIED FOR ADJUSTMENT IS
OPPOSITE POINTER
7 PLACE CAM FOLLOWER ON SECOND STEP OF CAM NEXT TO HIGH STEP
8 CLOSE CHOKE BY PUSHING UPWARD ON CHOKE COIL LEVER
9 TO ADJUST BEND TANG ON FAST IDLE CAM UNTIL BUBBLE IS CENTERED
1C REMOVE GAUGE
')MAKE FAST IDLE ADJUSTMENT
(BENCH OR ON-THE-CAR SETTING)
*) SPECIFIED
ANGLE (SEE SPECS I
TO ADJUST. BEND TANG
ON FAST IDLE CAM
UNTIL BUBBLE IS
CENTERED
AST IDLE CAM
(£)CLOSE CHOKE BY
PUSHING UPWARD ON
CHOKE COIL LEVER.
''REMOVE GAUGE FIGURE 2
WPLACECAM FOLLOWER
ON SECOND STEP OF CAM
NEXT TO HIGH STEP
CHOKE ROD (FAST IDLE CAM) ADJUSTMENT -
ANGLE GAUGE METHOD
1 USE CHOKE VALVE MEASURING GAUGE JUBOI Oft ST 7JO« TOOt MAT
K USED WITH CAmURCTOM O* OR Of* EMGtNE. IF OFF ENGINE. PLACE
CAMUftCTOM OH HOUMNG FIXTURE SO THAT IT WILL REMAN* IN
SAME POSITION WHEN GAUGE IS IN PLACE.
i ROTATE DEGREE SCALE UNTIL ZERO UN IS OPPOSITE POINTER
1 WITH CHOICE VALVE COMPLETELY CLOSED PLACE MAGNET SQUARELY
ON TOP OF CHOKE VALVE
4 ROT ATE BUBBLE UNTIL IT IS CENTERED
FtpURt_2
1 ROTATE SCALE SO THAT DEGREE SPECIFIED FOR ADJUSTMENT IS
OPPOSITE POINTER
6 SEAT CHOKE VACUUM DIAPHRAGM USING VACUUM SOURCE
7 HOLD CHOKE VALVE TOWARDS CLOSED POSITION. PUSHING COUNTER-
CLOCKWISE ON INSIDE COIL LEVER
8 TO ADJUST. TURN SCREW IN OR OUT UNTIL BUBBLE IS CENTERED
9 REMOVE GAUGE
© ;
WTTH CHOKE \
COIL REMOVED,
ROTATE INSIDE
COIL LEVER
COUNTER
CLOCKWISE
TURN SCREW
TO ADJUST
UNTIL BUBBLE
.SCENTERED
FIGURE 2
'SEAT DIAPHRAGM
' USING VACUUM SOURCE
~~^ NOTE ON DELAY MODELS WfTH
AIR BLEED. REMOVE RUBBER
COVER OVER FILTER ELEMENT
AND PLUG SMALL BLEED HOLE
IN VACUUM TUBE WITH TAPE.
ON MODELS WITH AIR BLEED
IN END COVER. PLUG COVER
WITH 1" MASKING TAPE RE
MOVE TAPE AFTER ADJUST
MENT
FRONT VACUUM BREAKADJUSTMENT-
ANGLE GAUGE METHOD
-------
FIGURE 1
1 USE CHOKE VALVE MEASURING GAUGE J-2STO1 OR BTT7W TOOL MAY
8E USED WTTH CAflSUHETOR ON OH OfF ENGINE IF Off ENGINE PLACE
CARBURETOR ON HOLDING RXTURE SO THAT IT WILL REMAJN IN
SAME POSITION WHEN GAUGE iS IN PLACE
2. ROTATE DEGREE SCALE UNTIL ZERO iOI IS OPPOSITE POINTER
1 WITH CHOKE VALVE COMPLETELY CLOSED PLACE MAGNET SQUARELY
ON TOP OF CHOKE VALVE
4 ROTATE BUBBLE UVTIL IT IS CENTEREC
FIGURE 2
5. ROTATE SCALE SO THAT DEGREE SPECIFIED FOR ADJUSTMENT IS
OPPOSITE POINTER
6 SEAT CHOKE VACUUM DIAPHRAGM USING V ACUUM SOURCE
7 HOLD CHOKE VALVE TOWARDS CLOSED POSITION PUSHING COUNTER
CLOCKWISE ON INSIDE COIL LEVER
8 TO ADJUST BEND LINK UNTIL BUBBLE IS CENTERED
9 REMOVE GAUGE
•^ SEAT DIAPHRAGM
USING VACUUM SOURCE
NOTE ON DELAY MODELS W'TH
AIR BLEED REMOVE RUBBER
COVER OVER FILTER ELEMENT
AND PLUG SMALL BLEED HOLE IN
VACUUM TUBE WITH TAPE ON
MODELS WITH AIR BLEED IN
END COVER PLUG COVER
WITH 1 SQUARE MASKING
TAPE REMOVE
TAPE AFTER
ADJUSTMENT
©SPECIFIED
ANGLE iSEESPECS
\
®,
TO ADJUST BEND
CHOKE LINK UNTIL
BUBBLE IS CENTERED
^ WITH CHOKE COIL REMOVED
HOLD CHOKE VALVE
TOWARDS CLOSED CHOKE
BY PUSHING COUNTER
CLOCKWISE ON INSIDE COIL
LEVER MAKE SURE
PLUNGER BUCKING SPRING
UFUSEOI IS COMPRESSED
AND SEATED
REAR VACUUM BREAKADJUSTMENT-ANGLEGAUGE METHOD
8
© ALIGN MARK ON COVER WITH SPECIFIED POINT ON
HOUSING
NOTE MAKE SURE COIL PICK UP LEVER ENGAGES COIL
TANG - SEE TYPICAL VIEW - INSET «2
LOOSEN THREE
RETAINING SCREWS
{NOTE TIGHTEN
SCREWS AFTER
AOJUSTMENT)
©ROTATE COVER AND
COIL ASSEMBLY
COUNTERCLOCKWISE
UNTIL CHOKE VALVE
JUST CLOSES
PLACE CAW
FOLLOWER ON
HIGHEST STEP
OF CAM
INSET « 2
AUTOMATIC CHOKE COIL ADJUSTMENT - (M2MC-M2ME)
-------
FIGURE1
1 USE CHOKE VALVE MEASURING GAUGE J-26701 OR 8T.77D4 TOOL MAY
BE USED WITH CARBURETOR ON OR OFF ENGINE IF OFF ENGINE PLACE
CARBURETOR ON HOLDING RXTURE SO THAT IT WILL REMAIN IN
SAME POSITION WHEN GAUGE IS IN PLACE
2. ROTATE DEGREE SCALE UNTIL ZERO iDI IS OPPOSITE POINTER
1 WTTH CHOKE VALVE COMPLETELY CLOSED PLACE MAGNET SQUARELY
ON TOP Of CHOKE VALVE
4 ROTATE BUBBLE UNTIL IT IS CENTERED
FIGURE 2
5 ROT ATE SCALE SO THAT DEGREE SPECIFIED FOR ADJUSTMENT IS
OPPOSITE POINTER
6 INSTALL CHOKE THERMOSTAT1C COVER AND COIL ASSEMBLY IN
HOUSING ALIGN INDEX MARK WITH SPECIRED POINT ON HOUSING
7 HOLD THROTTLE VALVES WIDE OPEN
8 ON WARM ENGINE CLOSE CHOKE VALVE BY PUSHING UP ON TANG
ON VACUUM BREAK LEVER (HOLD IN POSITION WITH RUBBER BAND'
BEND TANG ON FAST IDLE LEVER UNTIL BUBBLE IS
HOLD THROTTLE
VALVES WIDE
OPEN
'INSTALL CHOKE THEHMOSTAT1C-
COVER AND COIL ASSEMBLY IN '^'BEND TANG TO-
HOUSING ALIGN INDEX MARK ADJUST UNTIL
WITH SPECIFIED POINT ON HOUSING BUBBLE IS CENTERED
® ON WARM ENGINE. CLOSE CHOKE VALVE BY PUSHING UP ON TANG
ON VACUUM BREAK LEVER (HOLD IN POSITION WITH RUBBER BAND)
UNLOADER ADJUSTMENT - ANGLE GAUGE METHOD
(TYPICAL)
10
/SOLENOID ENERGIZED -
A C COMPRESSOR LEAD
DISCONNECTED AT A C
COMPRESSOR A C ON
A T TRANSMISSION IN
DRIVE M TIN NEUTRAL
0
E"'CL£ FOB ADJUSTMENTS -
see EMISSION LABEL ON VI-OCLE
NOT? IGNITION TIMING SETPtfl LABEL
TURN SOLENOID SCREW TO
ADJUST TO SPECIFIED RPM
RECONNECT A C COMPRESSOR
LEAOA
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MODEL 2GC.2GE CARB.
ADJUSTMENTS
'. MEASURE FROM LIP
^-^ AT TOE Of FLOAT TO
AIR HORN GASKET
i 3)VISUALLY CHECK
FOR FLOAT ALIGNMENT
ADJUST
FLOAT LEVEL ADJUSTMENT
2
^AIR HORN RIGHT SIDE
" UP TO ALLOW FLOAT
TO HANG FREE
IGASKET IN PLACEl
BEND FLOAT TANG TO
ADJUST FOR PSOPER
SETTING
2 MEASURE SPECIFIED
— DISTANCE FROM
GASKET SURFACE TO
NOTCH AT TOE OF FLOAT
NEEDLE MUST NOT
^WEDGE AT MAXIMUM
DROP
FLOAT DROP ADJUSTMENT
GAUGE F*OM TO* Of
At* HO** ««tG TO TOP
C* PUMP ROC \^
EV
HOtO THROTTLE
VALVES COMPLETELY
CLOSED
PUMP ROD ADJUSTMENT
I 1 j REMOVE THERMOSTATIC
S—^COVER COIL ASSEMBLY
AND INSIDE BAFFLE PLATE
(IF USED!
,-—-.
!,3:) CLOSE CHOKE VALVE
^"^ BY PUSHING UP ON LEVER
ROD
HERE TO
ADJUST
(SEE INSETI
CHOKE COIL LEVER ADJUSTMENT
( 4 , EDGE OF COIL
LEVER MUST LINE
UP WITH EDGE OF
12O PLUG GAUGE
IN HOLE INSIDE
CHOKE HOUSING
IDLE SPEED SCREW
ON HIGHEST STEP OF FAST IDLE
CAM
-------
U>
U)
(j) WITH CHOKE VALVE l«0£ OPE>. ENGINE COt_D
v ROTATE COVER AGAIHSTCOIL T£«*O«t 'JNTiL CHOICE
VALVE CLOSES- Si! MARK ON COVER TO SPECIF.EO
POivro»CHO*E HOUSING <*JTE <* VOOELSWTH
SLOTTED COIL PICKUP LEvER MAKE SoRE COIL TA*G
IS INSTALLED IX SLOT m LEVER SEE INSET
®
LOOSES THREE RETAINING
SCREWS NOTE Tp-SHTEN
SCREWS AFTER ADJUSTMENT
3LE SPEED SCatf,
OS HIGHEST STE? Of CAW
THERMOSTATIC
ChOKECOIL LEVER
AUTOMATIC CHOKE COIL ADJUSTMENT
®
BEND TANG TO ADJUST
(SEE INSET = 2 Of - 3i
L LOW STEP © GAUGE BETVVEEM
2 2ND STEP UPPER EDGE OF CHOKE VALVE
H HIGH STEP AND«ALL OF AIR HORN
IDLE SPEED
SCREW ON 2ND " -
STEP OF FAST IDLE CAM
INSET = 1 AGAINST HIGH STEP ~
CHOKE ROD (FAST IDLE CAM) ADJUSTMENT
2)HOtO CHOKE VALVE
^-^ CLOSED WITH ROO
IN BOTTOM Of SLOT
3jTLACe GAUGE SETNCEM
^^UPPSH EDGE Or CHOKE
VALVE AMD AlB HOflN WALL
0SEAT DIAPHRAGM
^ PLUNGER USING
OUTSIDE VACUUM
SOURCE
VACUUM BREAK ADJUSTMENT (THROTTLE LEVER SIDE)
8
3JST6M
"-^PULLED OUT
UNTIL SEATED
(SPRING
COMPRESSED
ON BUCKING
SPRING
MODELS!
(V)GAUGE BETWEEN UPPER
^""EOGE OF CHOKE VALVE
AND WALL OF AIR HORN
VACUUM
DIAPHRAGM
SEATED
NOTE- PLUG END COVER
WITH A PIECE OF MASKING
TAPE MAKING SURE TO
COVER PURGE BLEED HOLE
REMOVE TAPE AFTER
ADJUSTMENT
i 1JPLACE IDLE SPEED SCREW
^-^ON HIGHEST STEP DF FAST
V IDLE CAM
"^
S*J
-~^_T'- s~~\
' 5JBEND ROD
( 2 )USE OUTSIDE VACUUM SOURCE
VACUUM BREAK ADJUSTMENT (CHOKE SIDE)
-------
©
GAUGE B€TWEES UFP1P
EDGE OfCHO*E VALVE
AND WALL Of AJP HORN
©
HOLD THROTTLE
VALVE rtlDEOP£S
CHOKE UNLOADER ADJUSTMENT
u>
10
©PREPARE VEHICLE FOR ADJUSTMENTS - SEE
EMISSION LABEL OS VEHICLE \O"E IGNITION
TIViNG SET PER LABEL
-s- ©TURN IDLE SPEED SCREW TO
SET CURB IDLE SPEED TO
~x SPECIFICATIONS -'SEE
•-' X^ EMISSION LABEL
©,
THROTTLE
LEVER
OLE SPEED SCREW ON
LOW STEP OF FAST IDLE
CAW
IDLE SPEED ADJUSTMENT
11
THROTTLE SLIGHTLY TO A
SOLENOID »'_U«G£R TO FULL* EXTEND
®T
TUW« IOCE S«ED SCHEW TO
SET CUSB IM.E SPSEO TO
SPECIFICATIONS- AC OFF
iSEE EMISSION LABEL
(D SOLENOID ENERGIZED -
A C COMPRESSOR LtAO
CXSCOIWiECTEO AT 4.C
COMPRESSOR A C ON
AT TRAf«SWtSSlO*f IN
DRIVE ^--^
ELECTRICAL
CONNECTION
©
TURN SOLENOID SCREW TO
ADJUST TO SPECIFIED RPM
'RECONNECT A.C COMPRESSOR
LEAD AFTER ADJUSTMENT!
©PREPARE VEHICLE FOR ADJUSTMENTS -
SEE EMISSION LABEL ON VEHICLE
NOTE IGNITION TIMING SET PER LABEL
A/C IDLE SPEED ADJUSTMENT
12
(3) WITH PLUNGER HELD INWARD
TURN PLUNGER SCREW IN OR
OUT TO OBTAIN SPECIFIED
DECEL R P-M j .'-_——
TO FULL
VACUUM SOURCE
3O6 ENGINE (EXCEPT CALIFORNIAI
1600 R P-M IN NEUTRAL
0
ADJUST IDLE SPEED
—^ SCREW TO OBTAIN
SPECIFIED RfM
®
WITH ENGINE AT
SPECIFIED IDLE SPEED
PUSH IN ON END OF
PLUNGER UNTIL SEATED
VACUUM OPERATED DECELERATION CONTROL
THROTTLE LEVER ACTUATOR ADJUSTMENT
-------
13
f T' KITH IDtE SPEED SET TO P»OP€» ft P U
VWT VAJ.VE SHOULD JUST U CLOSED
TUttm VEKT VALVE SCMCW TO ADJUST
WITH IDLE SPEED SET
TO PROPER R P M PLACE
IDLE SPEED SCREW ON
2ND STEP OF FAST 'OLE CAM
NEXT TO HIGHEST STEP
CLEARANCE
BOWL VENT VALVE ADJUSTMENT
©
REMOVE UPPER END OF
ROD FROM CHOKE LEVER
^2) HOLD CHOKE
WIDE OPEN
ROO SHOULD FIT
IN BOTTOM OF
SLOT IN LEVER
©TO ADJUST BEND ~
i LEVER WITH SCREW-
DRIVER IN SLOT
PUSH DOWNWARD
ON ROD TO END
OF TRAVEL __— ^ .
©CONNECT ROD
TO LEVER
®
CHOKE COIL ROD ADJUSTMENT
-------
GLOSSARY
accuracy: The degree by which an Instrument is able to determine the true
concentration of a pollutant Ln the exhaust gas sampled.
air contaminants: Any fume.'j, :ir>ok^, particuidte matter, vapor gas, or any
combination, but excluding water vapor or stream condensate.
riir-fuel ratio: The expression o{ the proportional mixture of air and gaso-
line created by the carbtirt-tor. Usually expressed as a numerical rela-
tionship such as 14:1, 13:1, etc.
ambient air: The surrounding or .-mtside air.
calibration gases: A blend ol HC and CO gases ur
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Crankcase emissions: The products of combustion emitted into the ambient air
from portions of the engine crankcase ventilation or lubrication system.
degradation: The decreased effect of I/M on emission reduction due to normal
wear of engine system.
deterioration: A synonym for degradation indicating an increase in emission
levels due to wear.
drift: The amount of meter reading change over a period of time. Zero drift
refers to change of zero reading. Span drift refers to a change in
reading of a calibration poinc on the upper half of the scale. The
calibration point ir> established by reading a calibration gas of known
concentration.
emission inepectiori program: An inspection and maintenance program in which
each vehicle ia subjected at specified intervals to a test of its emis-
olonn under specified conditions. The emission levels are compared with
;\ standard established for the vehicle class. If the emissions are higher
than the standard, the vehicle is failed and must be adjusted or repaired
to bring its emissions into compliance with the standards.
exhaust gas analyzer: An I is» • -unent for sensing the amount of air contaminants
In the exhaust emisuious 01 a motor vehicle.
exhaust emissions: The products ot combustion emitted into the ambient air
from any opening downstream of the exhaust ports of a motor vehicle engine.
fleet owner authorized stations: A permit issued to a qualified fleet owner
to perform vehicle emissions inspection limited to his fleet only.
fleet operator: The owner of a fleet of a designated number of vehicles.
hang-up: HC which clings to the burtace of the sampling and analyzer system
In contact with the gas sample stream which causes an erroneous indica-
I Ion of IIC in the measured value.
heavy -duty vehicle Any motor vohj.de designed for highway use which has a
vehicle weight of more tnan 8,500 pounds.
hydrocarbons: A compound whose molecular composition consists of atoms of
hydrogen and carbon only.
Idle test. An emission inspection program which measures the exhaust emission
from n motor vehicle operating at idle. (No motion of the rear wheels.)
A vehicle with an automatic transmission may be in drive gear with brakes
applied or in neutral gear,
independent contractor: Any person, business firm, partnership or corporation
with whom the state may enter into an agreement providing for the con-
struction, equipment, maintenance, personnel, management and operation of
official inspection station*.
137
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inspection and maintenance program: A program to reduce emissions from in-use
vehicles through identifying vehicles that need emissions control related
maintenance and requiring that maintenance be performed.
Inspection station: A centralized facility for inspecting motor vehicles and
pollution control devices for compliance with applicable regulations.
inspector: An individual who inspects motor vehicles and pollution control
devices for compliance with applicable regulations.
instrument: The system which samples and determines the concentration of the
pollutant gas.
key mode test: A loaded mode test in which exhaust emissions are measured at
high and low cruise speeds and at idle. The cruise speeds and dynamometer
power absorption settings vary with the weight class of the vehicle. The
dynamometer loading in the high cruise range is higher than normal load
in order to more effectively expose malfunctions leading to high emissions.
light-duty vehicle: A motor vehicle designed for highway use of less than
8,501 pounds gross vehicle weight. Further distinctions are sometimes mad
made between light-duty automobiles and light-duty trucks such as pickup
trucks.
loaded mode test: An emission inspection program which measures the exhaust
emissions from a motor vehicle operating under simulated road load on a
chassis dynamometer.
model year of vehicle: The production period of new vehicle or new vehicle
engines designated by the calendar year in which such period ends.
motorryrle: A motor vehicle having a seat or saddle for use of the rider and
designed to travel on not more than three wheels in contact with the
ground, but excluding a tractor.
motor vehicle: Any self-propelled vehicle which is designed primarily for
travel on public right of ways and which is used to transport persons
and property.
positive crankcase ventilation: A system designed to return blowby gases from
the crankcase of the engine to the intake manifold so that the gases are
burned in the engine. Blowby gas is unburned fuel/air mixture which leaks
past the piston rings into the crankcase during the compression and ig-
nition cycles of the engine. Without positive crankcase ventilation these
gases, which are rich in hydrocarbons, escape to the atmosphere.
prescribed inspection procedure: Approved procedure for identifying vehicles
that need emissions control related maintenance.
138
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registered owner: An individual, firm, corporation or association whose name
appears in the files of the motor vehicle registration division of the
department of motor vehicles as the person to whom the vehicle is
registered.
repeatability: The instrument's capability to provide the same value for
successive measures of the same sample.
response time: The period of time required by an instrument to provide
meaningful results after a step change in gas concentration level
initiated at the tailpipe sample probe.
smoke: small gasborne and airborne particles, exclusive of water vapor,
arising from a process of combustion in sufficient number to be
observable.
stringency factor: The percentage of total vehicles tested in an inspection/
maintenance program in a given time period that fail inspection and are
required to have maintenance performed.
tampering: The illegal alteration, modification, or disconnection of emis-
sion control device or adjustments or manufacturer tuning specifications
on motor vehicles for (;he purpose of controlling vehicle emissions.
vehicle dealer: An individual, firm, corporation or association who is
licensed to sell motor vehicles.
vehicle emissions standard: A specific emission limit allowed for a class
of vehicles. The standard is normally expressed in terms of maximum
allowable concentrations of pollutants (e.g., parts per million).
However, a standard could also be expressed in terms of mass emissions
per unit of time or distance traveled (e.g., grams per mile).
139
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TECHNICAL REPORT DATA
' read /uiUfiiclioHS on the reverse before coini>letinx)
I HI I'llHT NO
EPA-905/2-79-005
•i. r i n i ANU sum i TLI
Comparison of Parameter and Exhaust Testing Approaches
for a Vehicle Emissions Inspection and Maintenance
Program in Michigan
6. PERFORMING ORGANIZATION CODE
7 AlUHOHIS)
Midurski, Theodore P., and Sellars, Frederick
•I PI RTOFIMINO OFUiANI^A flON NAMt ANDADOFlbSS ~
GCA Corporation
GCA/Technology Division
Burlington KoacI
Bedford, Massachusetts 01730
1,' SI'UNSOHINK. ACil NCY NAMt AND ADDRLSS
U.S. Environmental Protection Agency
Region V Office1
Chicago, Illinois
8. PERFORMING ORGANIZATION REPORT NO
GCA-TR-79-70-G
3. RECIPIENT'S ACCESSION-NO.
5. REPORT DATE
December 1979
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-02-2887, WO// 7
13. TYPE OF REPORT AND PERIOD COVERED
14. SPONSORING AGENCY CODE
1D. SUPI'L f Mh N ! AMY NOTbS
10. ABSTRACT • ~~~~~~
The Michigan Department of State Highways and Transportation is in the process of
leveloping a motor vehicle emissions inspection and maintenance (l/M) program for
implementation in various nonattainment areas of the State. To date, the effort has
ocusod on identifying and assessing the various program alternatives available that
satisfy the objectives of I/M. A primary issue at this point concerns whether the
program should use the emissions measurement concept, or a concept involving parameter
inspection.
Assessments of the specific requirements related to implementing I/M in Michigan,
including a first level assessment of alternative program approaches, have been devel-
oped as part of this initial planning. Based on these initial assessments, the need
or a more detailed assessment of the parameter inspection concept was identified.
These det.iilc-d analyses of issues related to the parameter inspection concept were
>rrformed by CCA/Technology Division, under a contract with the U.S. Environmental
'rotection Agency. These analyses considered the emissions reduction potential, costs,
jonsumor and repair industry impacts, and administration requirements of four parameter
.nspection concepts. The results of these analyses are reported here.
KF Y WORDS AND DOCUMENT ANALYSIS
LHSCtWfORS
Autoinobi le eng ines
Exhaust detectipi,!
Kxhnust emissions.
h.IDENTIFIERS/OPEN ENDED TERMS
Automobile emissions
Inspection and main-
tenance
Mobile source emissions
control
c. COSATI Held/Group
19. SECURITY CLASS (Thin Report)
21. NO. OF PAGES
152
20 SECURITY CLASS (This page)
22. PRICE
FPA Form 2220-1 (9-73)
141
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