Do not WEED. This document
should be retained in the EPA
Region 5 Library Collection.
Evaluation Of Motor Vehicle Emissions Inspection And Maintenance
Programs In Minnesota
Final Report
Contract No. 68-02-2887
Work Assignment No. 6
EPA-905/2-79-001
February 1979
GCA/TECHNOLOGY DIVISION
BEDFORD, MASSACHUSETTS 01730
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GCA-TR-79-03-G
Prepared for
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION V
Chicago, Illinois
Contract No. 68-02-2887
Work Assignment No. 6
EPA Project Officer
Carlton Nash
EVALUATION OF MOTOR VEHICLE
EMISSIONS INSPECTION AND
MAINTENANCE PROGRAMS
IN MINNESOTA
Final Report
February 1979
by
Theodore P. Midurski
Frederick M. Sellars
Nancy K. Roy
Donna L. Vlasak
U.S. Environmental Protection Agency
Region 5, Library (PL-12J)
77 West Jackson Boulevard, 12th Floor
Chicago, II 60604.3590
GCA CORPORATION
GCA/TECHNOLOGY DIVISION
Bedford, Massachusetts
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DISCLAIMER
This Final Report was furnished to the U.S. Environmental Protection
Agency by GCA Corporation, GCA/Technology Division, Bedford, Massachusetts
01730, in fulfillment of Contract No. 68-02-2887, Work Assignment No. 6. The
opinions, findings, and conclusions expressed are those of the authors and not
necessarily those of the Environmental Protection Agency or of cooperating
agencies. Mention of company or product names is not to be considered as an
endorsement by the Environmental Protection Agency.
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ABSTRACT
Recent data for the State of Minnesota indicate that the National Ambient
Air Quality Standards for CO and Ox will not be attained in all areas of the
State by 1982, even if all reasonable available control technologies are
applied. In view of this, it is likely that the State will request from
U.S. EPA an extension of the compliance date beyond 1982. In order for this
request to be considered, the State must, among other things, have adopted
a firm schedule for implementing a motor vehicle inspection and maintenance
(l/M) program in the highly urbanized nonattainment areas. In this connection,
the State of Minnesota is currently planning for the implementation of an I/M
program. As a part of this effort, detailed analyses have been performed of
the costs, personnel requirements, rationale for selecting the particular op-
tion, scheduling requirements, and effects that the cold climate in Minnesota
might have on emission testing associated with the particular program option
being considered. This document reports these analyses.
111
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CONTENTS
Abstract ill
List of Figures vl
List of Tables vii
Acknowledgments x
1. Introduction ..... 1
Background 1
Objectives 2
Report Organization 2
2. Motor Vehicle Inspection and Maintenance 4
Introduction 4
Need for and Objectives of I/M 4
General Program Formats 5
Detailed Examination of I/M Program Elements 9
Selection of Test Mode 9
Organizational Approaches 17
Exemptions and Waivers 20
Frequency of Inspections 28
Enforcement Mechanics 32
Supporting Programs Required 34
Phasing Considerations 44
Integrating Safety, Noise, and Emissions Testing 47
References 53
3. Program Option 55
Option Definition 55
Inspection Scenario 56
4. Network and Personnel Requirements 61
Inspection Network . 61
Personnel Requirements 68
5. Cost Analysis 75
Methodology 75
Fee Computation 102
References 109
6. Implementation Planning Ill
Introduction Ill
Immediate Issues 112
7 Cold Climate Considerations . 124
Introduction 124
Effects of Cold Operation on Individual Vehicles 124
Seasonal Variations in Fuel Composition 136
Cold Temperature Effects on Analyzers 136
Cold Climate Impacts on Facility Operation 137
Summary 138
References 139
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LIST OF FIGURES
No.
1 Theoretical emissions deterioration curve 29
2 Motor vehicle inspection and registration flow chart 60
3 Suggested administrative structure 71
4 Conceptual floor plan for a combined safety and loaded-mode emission
inspection facility 78
5 Representation of choke-on time as a function of ambient
temperature 125
6 Cumulative HC and CO emissions during FTP driving cycle - Car A ... 127
7 Cumulative HC and CO emissions during FTP driving cycle - Car B . . .127
8 Cumulative HC and CO emissions during FTP driving cycle - Car C . . . 128
9 Cumulative CO emissions during FTP driving cycle - Car G 128
10 Cumulative CO emissions during FTP driving cycle - Car I 129
11 Cumulative CO emissions during FTP driving cycle - Car J 129
12 Average vehicle CO percent deviation versus start-up temperature . . 131
13 Temperature dependency of carbon monoxide emissions - varied
categories of vehicles 132
14 Cold-start emissions and total emissions produced during FTP driving
cycle as a function of ambient temperature ..... 135
VI
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LIST OF TABLES
No.
1 Estimated Test Time Requirements for Four I/M Test Modes 15
2 Advantages and Disadvantages of Various Test Modes 16
3 Organizational Structure: Advantages and Disadvantages 21
4 Sample Emissions Profile for an Urban County - 1985 Emissions
(kg/day) 25
5 Impact of Varying Vehicle-Age Exemptions and Stringency Factor
on Emissions Reductions Achievable From LDV's and LDT's 27
6 I/M Inspection Frequency 31
7 Advantages and Disadvantages of Two Enforcement Mechanisms 34
8 Elements of Safety, Emission, and Noise Inspection Program
Options 49
9 Average Annual Growth Factors, Human Population, 1970-1978 62
10 Projected Population by County for 1987 62
11 Derivation of Vehicle Ownership Rates During 1977 by County .... 63
12 Projected 1987 County Vehicle Populations Based on an Overall
Ownership Rate of 0.53 64
13 Projected 1987 County Vehicle Populations Based on an Overall
Ownership Rate of 0.60 65
14 Total Number of Annual Inspections During 1987 by County 66
15 Inspection Lane Requirements by County 67
16 Inspection Network Requirements . • 69
17 Operating Personnel Requirements 70
18 Administrative Personnel Requirements 74
vii
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LIST OF TABLES (continued)
No.
19 Outline of Program Cost Categories and Elements 76
20 Building Floor Area Requirements for Various Facility
Configurations 79
21 Inspection Network Requirements 80
22 Building Cost Estimates 81
23 Unit Costs for Land in the Seven-County Metropolitan Area 82
24 Estimated Land Investment Requirements, By County 84
25 General Specifications of a Typical I/M Centralized Facility
Emission Analyzer 85
26 Major Equipment Items Required for Loaded-Mode Emissions Testing. . . 86
27 Equipment Costs as a Function of Facility Configuration 87
28 Equipment Costs for the Inspection Network . 89
29 Capital Cost Summary 90
30 Estimated Instruction Cost for Instructor, Investigator, and
Inspector/Mechanic Training ..... 92
31 Administrative Salaries and Overhead Associated With Program
Startup 95
32 Summary of Initial Startup Costs 96
33 Annual Personnel Costs for Facility Personnel 97
34 Annual Calibration Costs 98
35 Annual Taxes 100
36 Annual Costs for Utilities, Services, and Supplies 99
37 Annual Administrative Personnel Costs 101
38 Cost Summary 103 X
39 Annualized Costs in Constant (1978) Dollars 107
40 Annualized Costs in Actual (Inflated) Dollars 107
viii
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LIST OF TABLES (continued)
No.
41 Break-Even Fees, Constant (1978) and Actual (Inflated)
Dollars 108
42 Breakeven Fees for Second (and Subsequent) Reinspectlons in
Constant (1978) and Actual (Inflated) Dollars 110
43 Implementation Schedule 121
44 Comparison of Cold-Mode Cycle Length in Minutes as a Function of
Soak Duration for Ambient Temperatures of 75°F and 20°F 134
ix
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ACKNOWLEDGEMENTS
The authors would like to acknowledge the individuals and organizations
who provided the necessary inputs for this study. Specifically, we would like
to express our appreciation to the Minnesota Pollution Control Agency, the
Department of Public Safety, Division of Motor Vehicles, and the Metropolitan
Council of the Twin Cities Area. We would especially like to thank Mr. Richard
Sandberg of the Minnesota Pollution Control Agency, and the EPA Task Officer,
Mr. Carlton Nash for their assistance throughout the study effort.
x
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SECTION 1
INTRODUCTION
BACKGROUND
Amendments to the Clean Air Act that were adopted during 1977 have es-
tablished that the National Ambient Air Quality Standards (NAAQS) for pollu-
tants such as carbon monoxide (CO) and photochemical oxidants (Ox) must be
attained in all areas of the U.S. no later than 31 December 1982. The U.S.
Environmental Protection Agency (EPA), the federal agency charged with the
responsibility of administering and enforcing the Clean Air Act and amendments
thereto, has set the requirement that each state containing an area (or areas)
currently in violation of the NAAQS must submit a revision to its State Imple-
mentation Plan (SIP) during January 1979 demonstrating compliance in all areas
by 31 December 1982. That all states will not be able to demonstrate total
compliance by the end of 1982 is recognized in the Amendments and provisions
are made for extending the compliance date to 31 December 1987. In order to
obtain the extension, however, the revised SIP to be submitted in January 1979
must include (among other things) a specific schedule for the implementation
of a motor vehicle emissions inspection and maintenance (l/M) program in those
nonattainment areas that have an urbanized population greater than 200,000.
Failure to submit an acceptable I/M schedule (or if a reasonable effort toward
submitting an acceptable schedule is not being made) will result in rather
severe sanctions being imposed on the state.
Preliminary reviews of the status of air quality control regions in the
State of Minnesota have indicated that the NAAQS for Ox and/or CO will not be
achieved by 31 December 1982 in all instances. Given the requirements of the
Clean Air Act Amendments mentioned above, a decision was made to initiate a
preliminary planning effort for the eventual implementation of an I/M program
in the State. This planning effort is being forwarded by the Minnesota Pollu-
tion Control Agency (MPCA).
To date, several decisions have been made concerning the format of the
I/M program that will be implemented in Minnesota. These decisions concern
the technical aspects of the test, the basic operational and administrative
structures that will be utilized, and the specific areas within the State that
will be affected; for the most part, these decisions have been made by the
,HPCA.
Several additional parameters have been defined as well, but these are
based on requirements specified either in the Clean Air Act Amendments or by
policy established by EPA. For example, program start dates are either defined
or limited by EPA regulation.
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OBJECTIVES
In order to understand the full range of implications associated with
the proposed I/M program, several additional parameters have to be defined.
Of prime concern is the cost of the program, particularly as it relates to
the individual motorist. In this connection, a detailed analysis was per-
formed to identify the approximate fee that would have to be charged for an
inspection in order for the program to be self-supporting. A primary objec-
tive of this report is to describe the assumptions, methods, and data used
in developing this estimate, and to discuss the actual fee thus calculated.
Further, it is considered important to delineate the specific rationale
that was used in defining the proposed program scenario. Specifically, the
options that were available should be presented and discussed on a relative
basis, and in doing so, the rationale for selecting a particular option
should become clear. Documenting the rationale is also a prime objective of
this report.
From the standpoint of State planners and decisionmakers, an important
consideration concerns the timetable with which they must work in developing
and implementing the program. The third objective of this report is to dis-
cuss both the statutory and practical factors that will undoubtedly affect
the overall implementation process, and to provide a suggested schedule for
implementation.
Finally, there has been concern expressed regarding the effects that the
cold climate in Minnesota might have on emission testing. It is noted that
most of the existing I/M programs are located in states that have much warmer
climates - Arizona, California, Nevada - although similar programs are being
operated in Chicago and Cincinnati, which certainly experience prolonged pe-
riods of very cold weather. The final objective, then, is to provide dis-
cussion concerning possible impacts of the cold Minnesota climate on emission
testing.
REPORT ORGANIZATION
This report is organized into seven principal sections including this intro-
ductory section. Section 2 provides a detailed discussion of the technical
aspects of I/M programs. Included are comparisons among various options that
are available for testing automotive emissions, administering the program,
enforcing the test requirements, etc. This section provides the rationale for
the particular I/M program scenario proposed by the MPCA. The actual scenario
for the proposed program is discussed in detail in Section 3. Although the
discussion focuses on the basic inspection program, some specific recommendations
are included regarding support program elements. A key element in this study\
is the derivation of the test facility requirements and the number of individual^
to both run the test facilities and provide admistrative support. The de-
velopment of these requirements is reported in Section 4. Based on the I/M
program scenario, supporting program elements, network and personnel require-
ments developed in the first few sections, costs associated with the program
S
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are discussed in detail in Section 5. The actual costs are discussed by ca-
tegory and a break-even fee is developed. Section 6 presents a discussion of
several aspects of implementation scheduling. Current scheduling requirements
established by EPA regulation are discussed, as are other elements such as
construction phasing, startup time, etc. Finally, a technical discussion of
the potential impacts of a cold climate on an emissions inspection program
are discussed in Section 7.
The reader is cautioned at this point that several elements of this report
must be considered tentative and, therefore, subject to change. Cost esti-
mates were developed in terms of 1978 dollars, therefore the actual, in place
cost of the program will be somewhat different from the costs developed here;
this difference, however, should primarily reflect the rate of inflation from
1978 through 1987.
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SECTION 2
MOTOR VEHICLE INSPECTION AND MAINTENANCE
INTRODUCTION
The required implementation of motor vehicle emissions inspection and
maintenance (I/M) programs in certain areas of the U.S. under provisions
of the 1977 Amendments to the Clean Air Act was discussed in Section 1. At
this point, then, a detailed discussion is in order regarding the technical
concepts and objectives of I/M.
The first questions that will be considered here are: what is an I/M
program, and how does I/M fit into the overall effort of reducing pollution
from automobiles? Following this is a discussion of the general I/M program
configurations that have been or will be used in various states. Finally, a
detailed discussion is provided of the specific options available in develop-
ing an I/M program, and what the impacts and benefits are of various options.
NEED FOR AND OBJECTIVES OF I/M
Beginning with 1968 model-year vehicles, automobiles manufactured in or
imported into the U.S. have had to comply with emission standards specified
in the Federal Motor Vehicle Emission Control Program (FMVECP). Under this
program, maximum emission rates are established for new vehicles, and manu-
facturers must demonstrate through an auditing program that their vehicles
are in compliance with these emission limits. The emission standards spec-
ified by the FMVECP require progressively more stringent control of emissions
with each subsequent model year.
To comply with the emission standards, manufacturers have retained their
existing engine design concepts, but developed emission control devices (crank-
case ventilation control, catalytic converters, etc.) and revised certain
system parameter specifications (air-to-fuel ratio, ignition timing, etc.).
This approach to emission control ostensibly satisfied the requirements of the
FMVECP for new vehicles. However, surveillance studies conducted by EPA dis-
closed that the emission rate for these "controlled" vehicle generally in-
creased with time at a much greater rate than was expected, therefore reducing
greatly the overall effectiveness of the FMVECP. Further analyses determined
that the root causes of the rapid deterioration of these emission control
systems could be traced to either improper or inadequate maintenance, or
tampering with the devices or system settings.
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In light of these findings, effort has been expended on developing tech-
niques for reducing the air quality impact of poor maintenance practices and
tampering. One result of this effort is the evolution of the inspection and
maintenance concept.
In its most basic sense, inspection and maintenance refers to a program
where vehicle exhaust emission levels are measured during specified operating
conditions and compared with a specified standard for that particular vehicle
configuration. If the measured rate exceeds the standard, the need for some
form of maintenance, 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. A more precise discussion of various technical aspects of I/M may
be found in the EPA report entitled "Summary Report on Vehicle Emissions
Inspection and Maintenance Programs."
GENERAL PROGRAM FORMATS
As indicated previously, several individual parameters must be defined
in the development of an I/M program. For the purposes here, these parameters
can be considered to deal with either the technical or administrative aspects
of the program. Almost any combination of individual parameters can be used
in developing a particular I/M program, therefore, it is perhaps of more value
at this point to discuss these parameters on an individual basis rather than
attempting to discuss them in the context of a particular program; the follow-
ing discussion is intended to be somewhat superficial, merely acquainting the
reader with the basic concepts; a detailed treatment of these parameters
appears later in this section.
Test Mode
Currently, there are two primary test modes used in emissions inspections.
The first type - idle mode - involves the quantitative analysis of pollutants,
namely, hydrocarbons (HC) and carbon monoxide (CO), present in the exhaust
gas while the vehicle is at idle. The second type - loaded mode - involves
the quantitative analysis of pollutants (CO and HC) during simulated driving
and idle modes. The primary differences between the two test types, aside from
test equipment required, is that (1) the loaded mode test may provide more
diagnostic information regarding engine malfunctions over a wider range of
operation, and (2) loaded mode must be used if NOX emissions are to be tested;*
the relative validity of the two modes (that is, which one of the two test
modes more accurately defines the vehicle's emissions characteristics) can be
argued. It is generally agreed that both modes provide an adequate assessment
of the effectiveness of a vehicle's emissions control components and systems.
Both idle and loaded-mode testing are utilized in current programs.
New Jersey, Nevada, Oregon, and Rhode Island utilize idle-mode testing, while
loaded-mode testing is conducted in California. It is noted that Arizona
It is noted that there currently are no requirements for inspecting NOX emis-
sions although this may become a requirement at some future point in time.
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utilizes both types - the loaded test provides diagnostic information and
serves to precondition the test vehicle, while the actual passs-fail criterion
is based on the idle-mode emissions.
Types and Management of Inspection Facilities
I/M programs can be formatted such that inspections are performed in
either centralized test facilities or privately operated service stations.
A public authority can be delegated the responsibility of establishing the
network of centralized inspection lanes, or a contractor may be commissioned
to design, finance, construct and operate the facilities. The contractor is
selected through a competitive bid process and is monitored by and accountable
to the responsible state agency. A third alternative is to license and cer-
tify private service stations and garages to operate the program using their
existing facilities. These facilities would also be monitored by and account-
able to the public authority responsible for overall program administration.
A fourth alternative is to have a system with some combination of testing at
both central lanes and private garages. In New Jersey, for example, the
initial testing is performed at the state-operated lane while the retesting
of vehicles is done either at central lanes or certified garages. Rhode
Island's program utilizes private garages for testing with a central station
run by the State serving as a referee lane.
Failure Rate
The failure rate refers to the portion of the tested vehicle population
that is expected to fail the test, and therefore require maintenance. The
rate is a function of the emission characteristics of the affected vehicle
population and the emissions standards established for the program. For ex-
ample, if the 70th percentile rate in the frequency distribution of emission
rates for the vehicle population is selected as the standard, then the failure
rate can be expected to be 30 percent. The failure rate is also referred to
as the stringency factor.
In the relationship between the stringency factor and emission standard,
the stringency factor is the independent variable. This parameter is defined
on the basis of effecting a specific level of emission reduction from the I/M
program. Selection of a particular stringency factor must consider the demin-
ishing rate of return (i.e., rate of emission reduction) as the stringency
factor increased; this is discussed more fully in a subsequent section. The
emission standard, then, is set entirely as a function of the stringency factor.
Vehicles Affected
Another important consideration is the portion of the vehicle population
that will be required to undergo testing. Theoretically, it would be possible
to require all vehicles registered in the state (or a subarea) to be inspected
and repaired as required, but this approach would not be practical, or even
desirable. Certain vehicles, such as antique autos, and older vehicles (say, ^
12 to 15 years or older), diesel or gaseous-fueled vehicles, should not neces-
sarily be required to undergo testing. Also, consideration is usually given
to exempting heavy-duty, commercial vehicles (gross vehicle weight greater
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than 8500 pounds) from inspection requirements because of special problems that
arise in areas such as defining appropriate emission standards, or providing
facilities that will accommodate large, heavy vehicles, Generally, I/M programs
are most efficient if their focus is limited to the light-duty vehicle population.
Inspection Frequency
Since the efficiency of emission control systems generally decreases with
time, inspection and maintenance must be performed periodically. Since the
deterioration in control effectiveness is a more or less continuous process,
the frequency of vehicle inspection and maintenance significantly affects the
overall benefits derived from an I/M program. It is generally agreed that the
most practical approach is to require either annual or semi-annual testing.
Area Coverage
The general requirement established by EPA regarding the area to be in-
cluded in an I/M program is that, as a minimum, all nonattainment counties
with populations of 200,00 or more, and surrounding urbanized areas must be
included in the program. In certain instances it may be appropriate to in-
clude the entire state, or at least expand the coverage beyond the minimum
requirement; this decision might be based on issues regarding equity, devices
to improve air quality on a larger scale, etc.
Supporting Programs
In order to ensure the success of an I/M program, several supporting
elements must be incorporated. Although from the technical standpoint these
supporting elements are very different from the inspection and maintenance
processes, they should be considered integral to the overall I/M program and,
as such, the manpower and costs associated with establishing and operating
these should be reflected in the overall program cost and resource analysis.
Specific support elements are introduced below.
Public Information Program—
An ongoing information program serves to familiarize the public and the
repair facility owners with their respective roles in the I/M program. An
information program is required to explain both the objectives of the program
in terms of air quality, and the direct benefits to the public such as fuel
conservation. The public should be assured that most vehicles will pass the
tests and that most of those that fail will require only minor maintenance.
Another function is to provide vehicle owners with information regarding sta-
tion locations, inspection times, and consumer protection measures.
Consumer Protection—
Provisions must be made to insure that vehicle owners are protected from
abuses that could appear in the system (e.g., overcharging by repair shops
and unnecessary repairs) just as care must be taken to avoid hardships in
terms of extremely costly repairs or the denial of vehicle registration without
due cause. One facet of the consumer protection program is the exemption of
certain classes of vehicles; for example, new cars and antique vehicles. In
addition, some areas have considered a ceiling on the cost of repairs required
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for compliance. The ceiling could be either a flat rate or a percentage of
the market value of the vehicle. This would eliminate the potential for cer-
tain vehicle owners experiencing undue hardships.
Finally, some kind of mechanism should be established to handle consumer
complaints concerning overcharging and unnecessary repairs by garages as well
as complaints about the program in general. This consumer affairs office
could also be responsible for the licensing of repair facilities. If too many
complaints about any one repair facility are received, the consumer affairs
office could investigate and revoke the license of the garage if the claims
were justified.
Mechanic Training—
A mechanic training program increases the efficiency of the repair in-
dustry performance and is prerequisite to the effective testing and proper
maintenance of vehicles. Familiarity with the emission test procedure and
equipment promotes objective and competent testing as well as insuring that
emission testing is uniform and consistent among stations. Mechanics need to
understand the functioning and maintenance of emission control devices in
addition to knowing which engine parameters affect emissions and how to tune
to minimize emissions.
Mechanic training helps alleviate the problems of ineffective repairs and
excessive repair. The latter is caused by overadjustment by inadequately trained
mechanics in an effort to avoid missing the problem. For instance, California
has developed a mechanics' handbook which describes a repair sequence, or
step-by-step procedure, for each type of emissions failure. Mechanics are
instructed to proceed only as far as the step that corrects the malfunction.
This California program was developed to meet a legislative requirement that
mechanics repair vehicles according to specifications established by the Bureau
of Automotive Repair. The specifications are an attempt to eliminate the guess-
work involved in repairs and also serve as a basis for the evaluation of repair
work.
Repair Facility Certification—
The certification of repair shops for emission work serves two purposes.
First, it gives vehicle owners some guarantee of the credibility and compe-
tence of the repair facility. Second, to retain its certification, a repair
facility would be required to perform quality work. Certain criteria could be
established upon which to base decisions concerning certification. Minimum
criteria should include the employment of a certified mechanic and ownership
(or leasing) of approved emission analyzer instrumentation. Additional re-
quirements could be established with regard to the availability of tools and
service manuals required to perform effective repairs.
Integrated Inspection Programs—
The nature and intent of emission inspections is very similar to other
vehicle inspection programs such as those for safety and noise. In this
connection, it is logical to assume that emissions, safety, and noise could
be integrated into one inspection program. In fact, an integrated program
where all three parameters - safety, noise, and emissions - are inspected at
the same time would undoubtedly be much more cost effective and more readily
accepted by the public than separate programs would be.
8
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DETAILED EXAMINATION OF I/M PROGRAM ELEMENTS
While the previous discussion served primarily to acquaint the reader
with the basic elements of an I/M program, a more detailed examination of
these elements is in order. This detailed analysis will provide some insight
regarding the rationale for selecting specific parameters for the proposed
I/M program being considered here. Specifically, the following topics will
be discussed:
• Test Mode
• Program Administration
• Vehicle Exemption and Waivers
• Inspection Frequency
• Mechanic's Training Program
• Phasing Considerations
SELECTION OF TEST MODE
The function of emission testing is to identify those motor vehicles
that exceed established exhaust emission standards for hydrocarbons (HC) and
carbon monoxide (CO). One decision that must be made in defining an I/M pro-
gram is the test mode that will be utilized. The following presents a dis-
cussion of four types of test modes that are commonly used for emissions
inspection programs; these particular test modes include: (1) idle mode,
(2) high idle mode, (3) loaded (key) mode, and (4) modified key mode.
Test Mode Descriptions
Idle Mode—
The idle-mode test involves sampling exhaust gases while the vehicle is
idling; no attempt is made to determine the actual idle speed while the
sample is being taken. Of the four test types being considered here, the idle
test is the simplest test available and involves the least amount of instrumen-
tation. The test is performed essentially with only an emissions analyzer. The
inspector inserts the analyzer probe into the exhaust pipe of an idling vehicle,
takes the reading, and compares the measured emissions levels with established
standards for the particular vehicle type being tested.
There has been some discussion presented concerning the reliability of
the basic idle mode test when engine preconditioning is not performed prior
to analyzing the exhaust sample. For this reason, EPA has specified (in the
Preconditioning is simply allowing the engine to run at a speed of approxi-
mately 2,500 rpm for 60 to 90 seconds immediately before the exhaust is
sampled. This purges the exhaust system and also reduces some of the heat
buildup that occurs under the hood during long idle periods (these could be
encountered while waiting for an inspection), which could affect the air-to-
fuel ratio and hence, the CO and HC exhaust levels.
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draft Appendix N, at least) that: "At a minimum, the idle test should consist
of the following procedure carried out on a fully warmed-up engine: a measure-
ment of the exhaust emission concentrations for a period of time of at least
15 seconds, shortly after the engine was run at 2,000 to 2,500 rpm with no
load for approximately 60 seconds."
High-Idle Mode—
The high-idle mode test is very similar to the basic idle mode with
respect to equipment required and the fact that exhaust pollutants are mea-
sured with the engine idling rather than under a load. The difference, how-
ever, is that rather than testing the vehicle at its normal idle speed,
the engine is adjusted to a speed of between 2,250 and 2,500 rpm. Since the
engine speed is specified for this test mode, a tachometer must be attached
to the engine prior to testing. After attaching the tachometer, the inspector
inserts the probe into the exhaust pipe and then increases the engine speed
to from 2,250 to 2,500 rpm. The engine speed is held constant until the
analyzer stabilizes. At that point, the engine is returned to normal idle
speed and sampling continues until the analyzer again stabilizes. CO and HC
readings are recorded when the analyzer stabilizes both during the high-idle
and normal-idle phase of the test, and are compared with established standards
to determine whether or not the vehicle fails.
Loaded Mode—
Loaded mode testing involves analyzing exhaust pollutants while the ve-
hicle is being operated under load (through the use of a chassis dynamometer).
A chassis dynamometer consists of a pair of parallel rollers that support the
drive wheels of the vehicle. Inertial weights and a power absorption system
are attached to the rollers to resist changes in speed, simulating the various
loadings (i.e., rolling resistance, wind resistance, and vehicle weight) that
the engine would have to respond to under normal driving situations.
Loaded-mode tests allow for a variety of test cycles, one of which is
the Clayton Key mode test. In this test, emissions are measured at three
specific steady-state conditions; typically, these are 50 mph, 30 mph and at
idle.
Modified Loaded Mode—
The modified loaded mode test is identical to the basic loaded mode test
described above, except that the 30 mph phase is eliminated. The primary
reason for eliminating this phase is that the total test time can be reduced
with very little sacrifice in either test reliability or diagnostic information
produced.
Factors Influencing Choice of Test Mode
The following are the main factors that are generally considered in se-
lecting a particular test mode:
• Effectiveness in identifying vehicles that exceed emission
standards;
10
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• Level of diagnostic information provided by the test;
• Costs associated with the test;
9 Correlation with Federal test procedure;
• Test time requirements; and
• Repeatability by the repair industry.
Effectiveness—
Research concerning the effectiveness of loaded mode versus idle mode
generally indicates that both test modes are about equally effective in iden-
tifying hydrocarbon (HC) and carbon monoxide (CO) violations. Research, how-
ever, on nitrogen oxides (NOX) indicates that because NOX control systems are
not designed to operate at idle conditions and NOX emissions at idle are
negligible, the idle-mode test has generally very marginal ability to ade-
quately test NOX emissions. The following discussions summarize the research
to date on idle/loaded mode testing in relationship to the effectiveness issue.
Earlier research had indicated that the loaded mode test was superior to
the idle mode, both in its ability to identify gross emitters, but more impor-
tantly, in its ability to provide valuable diagnostic information.j' Until
recently, the U.S. EPA had been recommending the loaded test as the preferred
procedure.
Conclusions from the following test results help to indicate why there
has been confusion about the comparative effectiveness of the testing pro-
cedures. The Riverside California Trial Program Summary Report5 includes a
comprehensive evaluation of the program operations from September 1975 to
February 1976 during which 20,000 inspections and reinspections were performed.
Also included in this report is an analysis of emissions reductions and cost
effectiveness of repairs on failed vehicles. The inspection phase of this
program utilized a three-mode dynamometer test to measure CO, HC, and NOX
emissions. In addition, the engine test included ignition system parameter
measurements. The exhaust emission test results and ignition data were sub-
jected to a diagnostic test to determine the probable cause of malfunctions
and recommended repairs for failed vehicles. These results appeared on a com-
puter printout, which was identified as Vehicle Inspection Report (VIP).
A surveillance program6 was conducted in conjunction with the Riverside
Pilot Program to evaluate the Riverside loaded-mode test and compare it to an
alternative idle mode procedure; the conclusions of this study are interesting.
Although "Either an idle or a loaded-mode inspection has the potential to pro-
vide significant and cost/effective reductions in hydrocarbons and carbon
monoxide with a slight improvement in fuel economy... there may be little jus-
tification for the extra cost of a loaded mode inspection program since an idle
inspection can do nearly as good a job in detecting gross emitters." It was
further stated that "Both an idle and a loaded-mode inspection and maintenance
program have the ability to detect catalyst-equipped gross emitters."
11
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Other comparative studies have reached similar conclusions in comparing
the idle and loaded mode. Jerome Panzer of Exxon Research reported7 that
"The data show that nonloaded testing can be as effective as loaded testing
in reducing emissions if the nonloaded diagnostic procedure is used." Two
aspects of this particular study are worth noting here. One is that the idle
test included both idle and high speed (2,500 rpm) in neutral. Secondly, a
diagnostic and repair procedure was formulated using this data and data from
other studies. The repair procedure appears to be as critical as the test
itself because identifying gross emitters is but the first step in the process
of controlling automotive emissions; the subsequent repair of these vehicles
is perhaps of greater importance.
Jerome Panzer's research at Exxon indicates that a nonloaded mode has the
potential for identification of NOX problems when the high speed (2,500 rpm)
is included in the test procedure. In a later report Panzer compared this
test with key mode tests and found a correlation of at least 0.8 which is
comparable to the best correlations between short test cycles and the standard
in emission testing, the Federal Test Procedure (CO and HC testing). The study
concluded that "NOX measurements at 2,500 rpm and Key Mode conditions were
equally effective in identifying cars with high NOX. However, the range of
NOX values in the car population was so great that it appears impossible to
establish test standards which would correctly identify a higher percentage of
malfunctioning cars and avoid rejecting cars not needing repairs."
The General Motors Company performed an analysis of several comparative
studies of idle versus loaded-mode testing. Based on their analysis of
earlier studies (including several referenced here), and based on their own
use of the idle test in GM assembly plants, they recommend "...the idle test
for those states required to implement a mandatory vehicle emission inspection
program..."
In summary, most research gives strong evidence to the ability of the idle
test to perform as well as the loaded-mode test in identifying gross emitters
of CO and HC.
Diagnostic Information—
This issue may have a major impact on the effectiveness of an I/M program.
While it is generally assumed that the loaded-mode test provides considerably
more diagnostic information than idle tests, this assumption is not without
challenge. The California study cited previously10 indicates that the service
industry was unable to make use of the additional diagnostic data provided by
the loaded-mode test. The implication, then, extends beyond the issue of test
mode selection; apparently, the auto repair industry must be considered a
crucial factor in assessing the relative merits of idle versus loaded-mode
testing from the standpoint of diagnostics.
It is noted here that the very short loaded-mode tests do not provide
detailed diagnostic information regarding engine performance. Inferences
can be made, however, concerning which system is most likely to be the cause
of the emission problem based on the readings at various points in the test.
As an example, an excessively high HC level at 50 mph with a normal level at
12
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idle indicates that there may be a problem in the ignition system; normal HC
levels at 50 mph and abnormally high levels during idle, on the other hand,
would indicate that the carburetor is not adjusted properly.
In summary, research and practical experience generally indicate that a
loaded-mode test provides more and presumably higher quality diagnostic data
than does the idle or high-idle test. Without a sound, comprehensive mechanics
training effort, however, it is doubtful that the repair industry can effec-
tively make use of the additional diagnostic data. On the other hand, con-
sideration must be given to the possible requirement for testing NOX emissions
as part of the I/M program, at some point In the future. Again, NOx emissions
can only be measured using loaded mode or high idle mode testing. This pos-
sibility and the differences in diagnostic information must be weighed against
the higher inspection fee associated with either high idle or loaded-mode test-
ing in deciding on the particular test type to be adopted.
Variability of Inspection Cost with Test Mode—
The basic equipment requirements for emissions testing will vary with
mode utilized. In all four test types described previously, the same emission
analyzer is employed. The idle-mode test is the least expensive since no
other testing equipment is required. The high-idle test employes a tachometer
in addition to the analyzer, resulting in a slightly higher equipment cost.
(Less than $l,000/lane). The loaded-mode tests necessitate a chassis dynamo-
meter costing $10,000 to $14,000 per lane, plus additional facility space
making the loaded-mode test the most expensive in terms of equipment and fa-
cilities costs. Since both facilities and equipment costs are amortized, how-
ever, the resultant increase in the fee paid by the motorist is slight,
generally $0.20 to $0.25.
Correlation with Federal Test Procedure—
Most loaded mode tests correlate well with the Federal Test Procedure
(FTP), the standard for emissions testing. The 1975 FTP, which is a nine-mode,
125-second test, is considered the best method for the following reasons:
1. It measures emissions from vehicles over a simulated driving
cycle and, therefore, presumably approximate actual in-use
emissions;
2. Available evidence indicates that it is a reasonably reliable
test;
3. It is the test used in certifying new vehicles to show that
they are designed to meet Federal emissions standards; and
4. It measures emissions in terms of their total mass (in g/mile)
and, hence, is directly related to ambient levels whereas idle
tests only measure the relative concentrations of pollutants in
the exhaust gas.
Because of its complexity, long test time, and the need for more rig-
orously controlled conditions, the FTP has not been considered an appropriate
test for inspection/maintenance programs. Rather, attempts have been made to
13
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establish acceptable correlations between the FTP and shorter tests including
various loaded modes such as the Clayton Key mode, the New Jersey ACID test,
as well as with the idle test. Indications are that these tests all correlate
reasonably well with the FTP
Test Time Requirements—
The test time requirements of an emission test are perhaps the single
most crucial element to be considered in selecting the test mode to be utilized.
The inspection fee charged will be highly dependent on the "throughput time"
of the test facility. The throughput time is the time elapsed during the
slowest part of the inspection, and will determine how many lanes are neces-
sary to handle the vehicle population. A test mode having a 2-minute through-
put will require twice as many lanes as one with a 1-minute throughput. The
test time requirements for the four modes being considered here are discussed
below.
The idle-mode test can be performed in as little as 30 seconds. As men-
tioned previously, there has been some discussion concerning the reliability
of the idle-mode test when preconditioning is not performed. Preconditioning
the engine for 60 to 90 seconds increases the test time to 90 to 120 seconds.
It is not clear at this point if the proposed Appendix N preconditioning re-
quirement necessitates the attachment of tachometer leads to the engine. If
this is indeed required by the proposed Appendix N, the test time requirements
would be increased an additional 15 seconds (for induction tachometers, more
for the "clip on" type), making the total test time 105 to 135 seconds.
The high idle-mode test involves taking readings at 2,500 rpm and at
normal idle. The complete test time for the high idle-mode test is 2.5 to
3.0 minutes.
The Key mode test, where emissions measurements are taken at 50 mph,
30 mph, and at idle, has been automated by at least one manufacturer. This
enables a complete loaded-mode test to be conducted in 2 minutes or less.
The modified loaded mode is identical to the Key mode, with the elim-
ination of the 30 mph phase. Modified loaded-mode testing can, therefore, be
performed in less than 90 seconds. Table 1 summarizes the test times dis-
cussed for each test mode.
The test times shown in Table 1 indicate that there may be little dif-
ference in throughput time between the idle-mode and loaded-mode test, and
the modified loaded-mode may be the fastest to perform. This is dependent on
the type of preconditioning procedure required when Appendix N is finalized.
14
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TABLE 1. ESTIMATED TEST TIME REQUIREMENTS
FOR FOUR I/M TEST MODES
Mode Test time (seconds)
Idle 30 - 90 - 120*
High idle 150 - 180
Loaded (Key) 120
Modified loaded 90
"jf
30 seconds without engine precondi-
tioning, 90 seconds with precondi-
tioning (no tachometer leads attached),
120 seconds with preconditioning and
attachment of tachometer leads.
Repeatability by the Repair Industry—
An important indirect cbst of I/M is the cost of equipment purchased by
private garages in order to duplicate the test performed at the inspection
station. The garage mechanic will want to utilize, whenever possible, testing
procedures that ensure that vehicles repaired at his shop will pass reinspec-
tion. This could present some limits on the overall appropriateness of loaded-
mode test, as most garages would be either unable or unwilling to purchase
chassis dynamometers. A solution to this potential problem has been success-
fully employed in Arizona, whereby the loaded-mode test is used, but the pass/
fail decision is based only on the idle phase results. This enables the in-
spection to provide the mechanic with diagnostic information as well as enabling
him to use easily affordable equipment that can replicate the pass/fail portion
of the test performed at the inspection station.
Conclusions
The advantages and disadvantages associated with idle versus the loaded-
mode testing procedure have been summarized in Table 2. With respect to
overall effectiveness for hydrocarbon and carbon monoxide emissions, most re-
search and field experience indicates that the idle mode can identify gross
emitters equally well in comparison with the loaded mode procedure. The idle
mode is also considered sufficient to identify HC and CO from catalyst equipped
vehicles. Until a better test can be devised, the measurement of NOX requires
the use of the loaded mode or high idle mode test.
In terms of diagnostic information, because the loaded mode simulates
actual driving conditions, it generally provides more in-depth diagnostic in-
formation. However, some studies indicate idle testing can generate enough
data to produce as good repair work and as much emission reduction. One study
indicates that the repair industry cannot effectively make use of the more
complicated diagnostic data which the loaded mode test produces, therefore
the additional diagnostic information provided by the loaded-mode test will
be of little use without the existence of a sound, comprehensive mechanics
training program.
15
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Idle mode equipment costs less than loaded mode equipment. The U.S. EPA
proposed preconditioning requirements, however, may cause the idle test to
take longer than the loaded or modified loaded test resulting in more inspec-
tion facilities, thus greater cost to the motorist.
Since it would be difficult, if not impossible, for the repair industry
to acquire the equipment necessary so that, in the process of repairing
vehicles, they could duplicate the loaded-mode test (dynamometer required),
the loaded-mode test (if employed) should include pass/fail criterion based
only on the idle portion.
An additional issue to be considered is NOX testing. With emphasis
being placed on development of a three-way catalyst system for NOX control,
it is possible that in the future NOX testing may become a requirement for
I/M. Since NOX testing is best accomplished by using either a loaded-mode or
high-idle test, Minnesota would be wise to plan for at least the conversion to
loaded mode or high-idle test if the basic idle mode test is adopted initially.
ORGANIZATIONAL APPROACHES
Introduction
There are three main types of organizational structures for conducting
inspection/maintenance programs:
1. Government: centralized test facilities operated by state,
city, or local government (as in New Jersey, California,
Cincinnati, Ohio, Oregon, and Chicago, Illinois),
2. Contractor: centralized facilities operated by a private
corporation under contract to a government (as in Arizona),
and
3. Private garage: decentralized facilities operated by private
automobile service garages, certified or licensed by a govern-
ment (as in Rhode Island and Nevada).
In addition to these primary types, there can be combinations. For example,
a decentralized private system may also include one or several state-run
facilities as quality control measures and to discourage unethical or ineffec-
tive testing or maintenance.
In Rhode Island, the system is the decentralized private garage approach
but the state has one publicly run "challenge station" which acts essentially
as a referee to retest unsatisfied customers from any private station.
Issues Affecting Choice of Organizational Structure
In choosing one of the possible organizational approaches, several re-
levant issues should be considered: costs, vehicle owner protection, vehicle-
owner convenience, and startup time. These issues will be discussed in the
17
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following sections. The particular significance of each factor of course
may vary from one locality to another and may depend in some circumstances
on political factors external to the project itself.
Costs—
The costs that are considered most relevant here include:
1. capital costs (startup costs) land, buildings, equipment,
2. annual costs (recurring costs) salaries, fringe benefits
including pensions, overhead, and leasing.
A program's organizational structure to a large degree determines both
the particular capital categories in which startup expenditures occur and also
which sector (public or private) bears the direct burden. Both public and
private (government and contractor) centralized approaches entail large ex-
penditures in all three capital costs areas - land, buildings, and equipment.
In centralized public (e.g., state-run) systems these expenditures are
clearly the responsibility of the government running the program. In the
contractor-run program, the private corporation has the responsibility for
these capital expenditures. It should be noted, however, that regardless of
who incurs the direct responsibility, the vehicle owner ultimately bears the
cost through the inspection fee charged. Land and building costs vary in dif-
ferent regions and consequently have a different influence depending on the
price, scarcity of land, and associated building costs. In decentralized pri-
vate systems, the only capital expense is the purchase of equipment. For the
same vehicle population, centralized systems incur annualized capital costs
that are only slightly larger than capital costs for decentralized systems.
In terms of existing programs, in New Jersey and Riverside, California,
both state-owned and operated programs, the capital costs per lane were
$484,000 and $225,000, respectively, whereas in Maricopa and Pima Counties in
Arizona, a centralized contractor approach, the cost per lane was $247,000.
The primary recurring annual cost is labor, which generally ranges from
63 to 90 percent of the total recurring costs. The remaining 10 to 37 percent
of operating costs are for overhead and leasing expenses. Labor costs are
involved in a variety of individual program tasks including inspection, gen-
eral administration, maintenance and repair of inspection equipment, public
relations, and data collection. The largest portion of labor costs is for
inspection. In Arizona and Portland, Oregon (both with centralized approaches)
approximately 75 percent of the total labor is expended for the inspection
function, compared to 10 to 14 percent for administration and public relations.
At this point there is little data on the effects of organizational struc-
tures on labor costs. However, the limited available data suggests that cen-
tralized systems incur lower labor costs than private decentralized systems.
One reason for this difference is the different prevailing wage rate for the
"inspectors" in each system. In the centralized systems, the station inspectors
generally earn $4.75 to $5.00 an hour whereas the private garage, mechanic
inspectors earn an estimated $6.50 to $12.50 an hour. Also, in the private
18
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garage approach, there would be a sizable government administrative staff
needed to oversee and inspect the large number of individual inspection
stations.
Another important cost factor to be considered is the long-term economic
effect of fixed pension obligations. Generally, it would seem that in the
centralized, state-run approach there would be created the larger number of
new, state positions, and in the contractor approach there would be the least
new positions. However, the decentralized private garage system may require
many new positions with pension obligations due to the necessity of the large
staff to administer the program. The private contractor not only requires
the least administration but also would take care of all the fringe benefits
and pensions of the inspectors, which, in the long term, is likely to be less
costly than would the similar State benefits.
Consumer Protection—
Consumer protection is an important issue that is significantly influenced
by the organizational structure. Centralized systems, both public and private,
owing to their higher inspection capacity per lane, involve many fewer inspection
sites. Fewer sites means more effective monitoring of inspections and equip-
ment, thereby reducing test variability that may result from inadequate or
substandard instrumentation. Also the fewer inspectors associated with cen-
tralized systems reduce inspector training costs.
Centralized systems both public and private have two additional important
consumer protection advantages over the private, decentralized approach. One
is an inspection process that is independent from the repair process. Unlike
centralized systems, in the decentralized system, the private garages have
both I/M elements - inspection and maintenance - taking place at one location.
This lack of separation presents a potential conflict of interest as the
"inspector" who determines emission violations and their causes is also the
mechanic who stands to gain from the necessary repairs. This situation may
put the public at the mercy of unscrupulous mechanics unless very thorough
checks are built into the system. At the other extreme from the possibility
of unnecessary repairs being made on failed vehicles is the situation where
the local garage or service station may come under pressure from his regular
local customers to pass failed vehicles in need of tune-ups or other repairs.
These types of problems frequently occur in connection with various states'
safety inspection programs that are operated by private garages.
Consumer Convenience—
The greater number of inspection sites in a decentralized private system
has two kinds of convenience advantages. By increasing the number of inspec-
tion stations within a given area, the greater is the likelihood that a given
motorist will be located near an inspection site whether he is traveling from
work or home. This minimizes his costs since he travels less distance and
less time. Secondly, the greater number of stations potentially means the
motorist would have to wait less time in line waiting for inspection. This,
however, may not be the case unless the inspection times are spread out
sufficiently.
19
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Startup Time—
Each type of organizational structure has associated with it, unique
startup time requirements. Publicly operated centralized systems seem to in-
volve the longest startup time, owing to the need to purchase buildings, land,
and equipment for centralized systems, and the requirement of competitive
bidding process in government projects, the time required between legislation
and actual operation is larger than for the private decentralized approach.
In this case, the private garages already have the land and buildings. What
requires time is setting up the overall administration, and training of
mechanics and inspectors.
Summary
Each organizational structure has various advantages and disadvantages
associated with it. In Table 3, these factors, discussed in more detail in
the previous sections, have been summarized.
In terms of consumer protection both the public and contractor-run cen-
tralized system seem to be superior to the private garage approach. This is
primarily due to the separation of the inspection from repair functions and
secondarily due to the efficient monitoring and quality control of centralized
systems.
The cost factors vary in each organization approach. Both centralized
approaches incur higher capital costs in terms of land and buildings although
with the larger number of instruments needed in private garages this may be
somewhat offset. The recurring costs of the centralized systems - both public
and private - are somewhat lower than the private approach because of lower
labor costs. In the centralized state-run program, there is the additional
burden of long-term pension and other fringe benefits. The private garages
necessitate considerable administration labor costs, also incurring some long-
term pension obligations.
Consumer convenience is potentially greatest in the decentralized program
due to the larger number of stations dispersed throughout the population.
EXEMPTIONS AND WAIVERS
Introduction
The total emission reductions resulting from I/M are dependent on (1) the
number and type of vehicles inspected, (2) the failure rate, and thus (3) the
number of vehicles that undergo maintenance. In this regard, there are various
advantages and disadvantages that must be weighed in determining which vehicles
should be exempt from the inspection process. The major considerations when
judging whether any particular vehicle type should be exempt include: (1) the
potential hardships that may result for certain vehicle owners; (2) feasibility
of testing certain vehicle types, from both the technical and practical stand-
points; and (3) the costs associated with including certain vehicle types in
relation to the incremental reduction in emissions.
20
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TABLE 3. ORGANIZATIONAL STRUCTURE; ADVANTAGES AND DISADVANTAGES
Advantages
Disadvantages
V I t i ( \d V H f>
\ nilnst i y )
eci-iK i til I7«'d
Consumer Protection"
] . (nnpc'Ct ion separate front repair : no
conflict of interest.
2. I mi rprudent ban in Lor judging t Jn?
per t ormance of the serv ice J ndnst ry .
3. Monitoring of instruments' and
inspecters' performance facilitated,
thereby reducing testing variability.
COS f 8 -'
I. Lower (inspect ion) labor coats, thus
generally lower recurring costs.
2, More efficient use of equipment.
Inf ormat j.on :
1. Data collection facilitated.
?, Loaded mode testing possible.
C cni nun ie r Protection information
Same as pub 11 •• n-itralized.
Cost Same as publIL centralized, plus
1. All program costs born by private
sector i xcept those associated with
adminietrative oversight.
2. No risks of increasing long-term fixed
governmental costs.
3. Permits use of corporate tax structure
Lo reduce burden of start-up capital
expend i tares.
Consumer Convenience.
I. Greater number of tacilities increase
probability of minimizing travel and
wai t times
7. Possibility for one-stop inspection/
maintenance.
1. Low^r start-up costs.
2. All program i.osts born by private sector
exi_ept adnumat rot ion and monitoring .
Consumer Convenience •
1. Fewer inspect i on 1.11 i I 11 ! OK , t IIUH
an mere owe prohnbi1i ty of longer
trave 1 uiul wait l lines .
Cost :
1. Start-up reqi> res lat ge pub i it
capital out li:y
All pro^r.iin costs born by publit
seclor.
Risk of inc reaH ing long -term f i xctl
costs to government due to increaa*1
in number of pot.ent.LaI retirement/
pens ion beneficiaries.
Consumer Convenience Same as pub lie
centralized.
Consumer Prolection:
I , Poss i hie (ulverse pithj ir rr.-n t inn
corporal, ion earn i ng profitn f r om
"captive market."
Consumer Protect ion•
1. Inspect!on not weparate from iepairs
presents potential for conflicf of
interest and reduct ion df program
e ffeet iveness
No independent basis for judging
performance of serv i t_e indust ry .
Effective monitoring ul inspectt^rs and
instruments is more difficult.
2.
3.
Coat :
1.
Higher adm rnstrativc costs to rnana^''
arid oversee large number of garage-.,
higher labor costs, hence , h ight r re-
cur r i n g c o b t s .
2 - Les s efficient use oI equipment
3. Inspector train ing invo Ives girater
numbers and is t heref ore more t ,'s) ly
In_£_onTiat ion .
1. Uniform and detailed data collect!on
is more difficult.
2. Loaded mode testing IK improbab i e if
not intpossih !r.
From ttrnt 7.,
',-< nl .it !'t o(
I , Jr. Inspect ion/Maintenance Cost-Effectiveness and Feasibility of Implementation
L t J • >n Agency. Washington, H.C. May 1977.
I1. S. Env
21
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Vehicle Classes Considered
Currently, EPA classifies vehicles into six separate categories as de-
fined below:
• Light-Duty Vehicles (LDV) - Gasoline-powered automobiles of
less than 8,500 Ibs Gross Vehicle Weight (GVW).
9 Light-Duty Truck 1 (LDT1) - Trucks designed for highway use and
weighing less than 6,000 Ibs GVW (i.e., pickup trucks).
» Light-Duty Truck 2 (LPT2) - Trucks designed for highway use and
weighing between 6,000 and 8,500 Ibs GVW.
• Heavy-Duty, Gasoline-Powered Trucks (HDG) - Any gasoline-powered
motor vehicle designed for highway use that has a GVW of more
than 8,500 Ibs.
• Heavy-Duty Diesels (HDD) - Any diesel-powered motor vehicle
designed for highway use and weighing more than 8,500 Ibs GVW.
• Motorcycles (MC) - 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.
Minnesota's proposed I/M legislation calls for the annual inspection of
all motor vehicles weighing less than 9,000 Ibs GVW, registered in the seven-
county metropolitan area. The legislation also proposes two categories of
exemptions:
"Subd. 2 [EXEMPT VEHICLES.] The agency shall by rule
exempt from all or any part of the mandatory periodic inspection:
(a) motor vehicles registered as classic, pioneer, or
collector, pursuant to Minnesota Statutes, Section 168.10*
(b) any class of motor vehicle which presents prohibitive
inspection problems."
Under the Clean Air Act Amendments of 1977, specific requirements for
the implementation of motor vehicle I/M programs are established. With
regard to requirements concerning the types of vehicles to be inspected, only
light-duty vehicles (LDV) must, by mandate, be included in the program.
States are encouraged, of course, to develop more stringent programs (and hence,
more classes of vehicles), whenever possible. Quite clearly, the focus of
I/M is on light-duty vehicles (LDV's and LDT's), as these vehicle categories
have been found to be the major contributions to high CO and HC levels, pri-
marily because vehicles in these categories generally constitute approximately
90 percent of the urban vehicle population. Discretion is left to the states
to include motorcycles and heavy-duty vehicles in the inspectable fleet to
provide additional reductions.
22
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It is important that exemptions for certain vehicle classes and waivers
for specific vehicles be provided under certain circumstances. Issues such
as vehicle age and repair cost for compliance, and matters of practicality
such as vehicles that present difficulties in the actual performance of the
inspection, must be considered since arbitrarily including all vehicles (in
general or even within any particular category) may jeopardize the success
of the entire program.
According to the above discussion, six functional categories of motor
vehicles can be defined. Vehicle categorization is often not so clear-cut
at the state level, however. It is noted that Minnesota utilizes 19 specific
categories of motor vehicles in it registration process, yet the proposed
legislation defines the inspectable vehicle population to include any
"... self propelled motor vehicle weighing less than 9,000 pounds gross
vehicle weight and licensed for use upon the public highways of the State for
transportation of persons or property." For discussion purposes here and
throughout this report, it is assumed that, regardless of the registration
class, the specific vehicles weighing less than 9,000 pounds (GVW) can be iden-
tified in the registration files, which will serve to identify those vehicles
required to participate in the I/M program.
Basis for Exempting Certain Vehicles
As indicated above, the practicality of cost, inconvenience, and poten-
tial hardships weighed against the overall or incremental reduction in emis-
sions must be considered in defining which segments of the vehicle population
to include in the program. At this point, the term "exempt" will be defined
to mean not affected by the I/M program; hence, an exempt vehicle would not
be required to become involved with any facet of the I/M program. Exemptions,
then, apply to classes or categories as a whole.
Typically, exempt categories include:
* heavy-duty vehicles (gasoline and diesel) as defined
previously;
• vehicles that are more than a specified age;
• special purpose vehicles; and
• vehicles not licensed for use on the highway.
Exempting Heavy-Duty Vehicles—
Of these categories, the heavy-duty vehicle exemption is often the most
controversial. The public's viewpoint is that the real polluters are the
trucks, since, occasionally, visible emissions are produced by these types of
vehicles. An examination of a typical mobile source emissions profile,
_
Several exempt classes are also defined including antique vehicles and proto-
type or test vehicles.
23
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however, shows quite vividly the relative importance of various motor vehicle
categories with regard to total emissions produced. Such a profile is provided
in Table 4.
Table 4 shows that about 75 percent and 83 percent of the carbon monoxide
and reactive hydrocarbon emissions from mobile sources result from those ve-
hicles generally included in I/M - that is, the light-duty vehicle fleet.
In spite of the statistics cited above, it certainly could be argued that,
on the surface, it might be effective to include at least the heavy-duty,
gasoline-powered vehicles in the program since they do contribute about 22
percent and 12 percent of the urban CO and HC emissions. Several issues must
be considered, however, prior to reaching a conclusion regarding whether or
not to include heavy-duty, gasoline-powered trucks. A basic issue concerns
the need for information on the present state of routine maintenance practices
in the heavy-duty vehicle sector. It is quite likely that there would be a
tendency for commercial fleet owners to maintain their vehicles more adequately
than do individual vehicle owners, primarily because the higher operating costs
associated with an improperly maintained vehicle are generally more visible and
considered more crucial to commercial fleet operators. The question, then, is
do commercial fleets routinely operate at higher efficiency levels than do
privately-owned vehicles? It is noted that emission reduction credits have
not been published for heavy-duty vehicles undergoing I/M; apparently, the data
base regarding the state of in-use heavy-duty vehicles, and the potential emis-
sion reductions achievable from these has not been adequately developed at this
point. The first argument against including heavy vehicles is that there may
not be sufficient data to show that there is a real need to include these vehi-
cles because current maintenance practice may already be achieving the objec-
tives of the I/M concept.
Secondly, commercial vehicles typically accumulate mileage at very high
rates; it certainly would not be unusual for a long haul unit to average over
100,000 miles annually, or for a delivery truck to travel over 40,000 miles
yearly. With these high rates of such mileage accumulation, one could question
the effectiveness of an annual emissions inspection. Related t.o this is the
issue of where the commercial vehicle travel occurs. Long haul and certain
private carrier operations are likely to involve travel almost exclusively
outside a relatively small area (such as the seven-county area being considered
here), therefore, if I/M requirements were imposed, most of the benefits would
accrue outside the area. On the other hand, it is noted that the State has a
registration category for trucks that operate exclusively in the metropolitan
areas. I/M could be imposed on vehicles registered in this category, although
vehicle owners may simply register their vehicles in another category if they
perceive that there would be an advantage in doing so (i.e., not being required
to undergo emissions inspection and related repair).
Finally, the technical aspects of testing heavy vehicles should be con-
sidered. If loaded-mode testing is to be performed, special, high capacity
dynamometers and, generally, much larger facilities and parking areas must be
utilized. Also, the personnel operating these facilities would require special
training in operating heavy vehicles and performing the tests. If diesel
24
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vehicles are included, special laboratory grade analyzers would be required
to measure the CO and HC readings. Further, it is of interest to note that
neither CO nor HC exhaust levels are considered in the diagnostic criteria
for diesel engine maintenance, therefore, it is likely that the repair in-
dustry would have to receive special training on engine diagnosis based on
CO and/or HC exhaust levels.*
Exemptions by Vehicle Age—
Exemptions of vehicles over a certain age is a commonly used method to
protect owners from undue financial hardships. The older vehicles generally
cost more to bring into compliance and are more likely to need extensive re-
pairs such as ring or valve jobs. Moreover, given the small fraction of the
total vehicle population they represent, such exemptions ential a minimum
sacrifice in overall emissions reduction benefits. To illustrate, a comparative
analysis was performed of the total emissions reductions achievable in the
Milwaukee, Wisconsin area with an I/M program very similar in scope, format,
and size (vehicle population) to the proposed program for the Twin Cities
area, reflecting two different age exemption criteria. First, it was assumed
that all light-duty cars and trucks less than 15 years would be included in
the program, and, second, this exemption was redefined to include light-duty
cars and trucks less than 10 years old. The percent reduction in emissions
of CO and HC, as a function of the overall program stringency factor are tabu-
lated in Table 5.
Considering the defined stringency factor of 30 percent, Table 5 shows
that there would be an incremental difference of 6 percent and 4 percent in
total vehicle emissions of CO and HC, respectively, depending on the specific
vehicle-age exemption criterion established.
Special-Purpose and Off-Highway Vehicles—
Vehicles that would be considered special-purpose are prototype vehicles,
vehicles powered by unique, nonproduction engines or motors (i.e., gas tur-
bine, Sterling engines, electric powered, etc.). Also, certain types of farm,
construction, or industrial equipment that may require licensing and is per-
haps used on public roads occasionally would be included. Off-road vehicles
would be defined similarly.
These vehicles would generally not be included because of the difficulty
that would be encountered in both setting standards and performing the in-
spections. Also, from the standpoint of emissions benefits, there would likely
not be any perceptible reduction in total emissions by including these vehicles.
Other arguments based on practical considerations could be presented as well.
Waivers
Waivers are considered to be different from exemptions in that waivers
apply to individual vehicles or subsets of particular vehicle categories.
At this point, it is uncertain whether this type of engine diagnosis is even
feasible.
26
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TABLE 5. IMPACT OF VARYING VEHICLE-AGE EXEMPTIONS AND STRINGENCY FACTOR
ON EMISSIONS REDUCTIONS ACHIEVABLE FROM LDV's AND LDT's.
Percent reduction in emissions by
„ , . , stringency factor
,n , . Vehicles & 3
Pollutant Age exemption ., , -
considered ,, „
10/£ 20% 30% 40%
CO _> 15 years old All light-duty 37 44 49 52
vehicles only
J> 10 years old All light-duty 35 38 41 43
vehicles only
>_ 15 years old Entire vehicle 26 31 34 36
population
_> 10 years old Entire vehicle 22 26 28 30
population
HC >_ 15 years old All light-duty 25 30 33 36
vehicles only
_> 10 years old All light-duty 22 26 28 31
vehicles only
>_ 15 years old Entire vehicle 20 24 27 29
population
>^ 10 years old Entire vehicle 18 21 23 25
population
Source: Reference 11.
Notes: Includes mechanic training; reflects emissions in 1987 assuming
program start-up in 1982. I/M program applies to LDV's and LDT's
only.
27
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Generally, waivers are granted to release a vehicle owner from the responsi-
bility of complying with the inspection standard; the implication here is
that the vehicle must still be inspected.
Waivers are generally on the basis of costs associated with complying
to the standards. Usually, states set specific limits on the amount of money
that has to be spent on the type of repairs that have to be made before a
waiver is granted to release the vehicle owner from compliance;. Limits of
$50 to $100 are common, or the limit can be based on the value of the par-
ticular vehicle. Also, waivers can be granted to owners of either new vehicles
being registered for the first time, or vehicles that, for some technical
reason, cannot be tested easily. For instance, testing full-time, four-wheel
drive vehicles on a dynamometer may not be practical; a waiver could be granted
or an idle test could be prescribed for these special vehicles.
In the case where emissions inspections are combined with safety and/or
noise inspections, waivers may be granted separately for each type of test.
Because a waiver was granted for emissions compliance would not necessarily
mean that the safety or noise standards would not still have to be met.
FREQUENCY OF INSPECTIONS
U.S. Environmental Protection Agency (EPA) policy states that I/M program
emission inspections may be performed on any regular, periodic basis. No
specific time-interval is stipulated, however there is a requirement that the
program achieve a 25 percent reduction in emissions from those vehicles in-
cluded in the program by 1987. The reduction that will be achieved (or, more
precisely, can be expected at this point) depends primarily on two factors -
the stringency level and the frequency of inspection. As a practical matter,
the inspection frequency is generally defined as annual in order to coincide
with registration renewal cycles and, more importantly, to maximize the effec-
tiveness of the program; the issue of maximizing program effectivenss is dis-
cussed in detail, below.
Factors Relating Inspection Frequency and Program Effectiveness
Generally, the more frequently a motor vehicle is inspected, the more
likely it is that its emissions will approach the minimum level. There is a
point, however, where inspections performed more or less frequently are much
less cost effective, therefore, a primary consideration in establishing the
inspection frequency requirement for an I/M program is to approach this point
where cost effectiveness is maximized. In this connection, the topic of de-
terioration becomes relevant.
Deterioration—
In theory, emission rates for carbon monoxide (CO) and hydrocarbon (HC)
are at the lowest level possible when various engine systems and components,
such as the carburation and ignition systems, are operating at maximum effi-
ciency. The most likely condition for these systems to be at maximim effi-
ciency is right after the engine has been tuned (new ignition components,
timing reset, and carburator adjustments made, etc.). With use, these systems
28
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begin to loose their efficiency resulting in overall degradation of engine
efficiency.
Several studies have been or are currently underway to define the exact
nature of deterioration. Preliminary analyses indicate that deterioration
rates increase quite rapidly shortly after the engine is tuned, but the rate
slows substantially with time. Other studies have indicated that the rate of
deterioration is slow at first, but then increases with time. While the gen-
eral conclusions regarding the deterioration rate versus time function appear
to be somewhat contradictory, the general conclusion that over a series of
annual tune-ups, the emission rates of both CO and HC rates just prior to
the tune-up and approximately 9 months after the tune-up, are about equal;
in other words, a tune-up will provide improvements for only about 9 months.
A theoretical emission deterioration curve is shown in Figure 1 below.
300-1
o 200'
UJ
t-
KEY'
A TUNEUP PERFORMED
100
O
50
BASELINE EMISSIONS RATE
12
24
36
TIME, month*
Figure 1. Theoretical emissions deterioration curve.
Note in the curve that the emission rates for the newly tuned conditions
are shown to be increasing year to year. This reflects the impact of normal
engine wear and loss of effectiveness of various engine components. To bring
the rate for a newly tuned engine down to the baseline rate, significant re-
pairs, such as a major overhaul, would likely be required.
29
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Public Convenience and Cost Impacts—
The deterioration characteristics indicate that there could be some jus-
tification for requiring semi-annual inspections. Overriding the benefits
that would be gained - additional emission reductions - would be the likely
rejection of the program by the public. Although at this point the relative
nonacceptance of a semi-annual versus annual program can only be considered
in a subjective manner, it is quite likely that more and stronger opposition
to a semi-annual program would occur. On the other hand, a biennial pro-
gram would likely be more readily accepted; however, the effectiveness
of such a program would undoubtedly be challenged by individucils truly con-
cerned with either improving air quality and/or protecting the public from
being required to participate in an ineffective (and therefore nonessential)
program.
Costs associated with a semi-annual program would likely be between 80 and
90 percent more than an annual program, and a biennially scheduled program cost
would be approximately 60 percent (on an annual basis) of the annual program
cost. Maintenance and indirect costs (such as travel to and from inspection
facilities and waiting for inspections) are directly related to the frequency
of required inspections. Overall, then, the choice of a specific inspection
frequence parameter will have a strong influence on the total program cost; a
general conclusion is that, on a relative basis, the highest benefit-cost
ratio would result from an annual program.
Other Considerations—
Two additional factors merit discussion here. First, the issue of co-
ordinating I/M schedules with other vehicle inspection programs is relevant.
If, for instance, a safety inspection program is going to be integrated into
the I/M program, then it is obvious that the inspection frequency for both
inspections ought to be the same.
The second consideration deals with the enforcement mechanism that will
be used. If, for instance, registration renewals are required annually and
the I/M enforcement mechanism requires proof of recently passing an emissions
test, then certainly inspection frequency ought to be coordinated with the
registration renewal cycle.
Experiences of Other States
Table 6 shows that an annual inspection frequency is utilized by most
I/M programs. Several exceptions are noted, however. In Nevada, inspections
are currently required only upon change of ownership. A similar requirement
is currently utilized in the California program (startup phase) although annual
inspections will soon be required. This initial phase will provide essential
information on the test procedure, stringency rates, public opinion, etc.
Biennial inspection currently is used only in the Portland, Oregon program.
Biennially scheduled inspections were selected basically to coincide with the
registration renewal cycle. Oregon does require that trucks and government
vehicles be inspected annually.
30
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TABLE 6. I/M INSPECTION FREQUENCY
Location
Inspection frequency
Arizona
Chicago
Nevada
New Jersey
Portland
Rhode Island
California (South Coast
Air Basin)
Annual
Voluntary, no requirement
Change of ownership
Annual
Biennial for LDV's, annual for trucks
and government vehicles
Annua1
Currently upon change of ownership,
ultimately, annual
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ENFORCEMENT MECHANISMS
Introduction
There are two methods of enforcing a program such as I/M, sticker ticket-
ing and registration enforcement. The sticker ticketing method involves issu-
ing compliance stickers that must be displayed prominently (usually on the
windshield) on vehicles, proving that the vehicle passed an emissions inspec-
tion. In contrast, motor vehicle registration enforcement means that the
motorist must present proof of compliance in order to register his vehicle.
Without proof of having passed the inspection, the motorist is simply denied
the right to register and, hence, to operate his vehicle. The registration
enforcement system generally requires that the frequency of inspection corres-
pond with the frequency of registration; there is no similar requirement for
the sticker ticketing method. The actual enforcement of the sticker ticketing
method is through levying fines on motorists who have not complied. Noncomply-
ing vehicles are identified either by a special police force, state, or local
police, or during routine traffic patrolling by regular law enforcement person-
nel. Those vehicles not displaying the appropriate sticker are given tickets.
The violators are then given, in some instances, the opportunity to have fines
lessened or eliminated by complying within a specified number of days. If the
motorist still does not comply, he can be subject to appropriate civil penalties
accordingly.
In comparing the two enforcement mechanisms, the primary issues to be
examined are the effectiveness and cost. These are discussed separately,
below.
Effectiveness
Because motor vehicle registration is a legal prerequisite to vehicle
operation, a high level of compliance can be expected for the registration
enforcement approach. Other than avoiding the registration process altogether
and operating illegally, the only way to circumvent the procedure would be to
forge or tamper with the forms used to demonstrate proof of compliance. Given
sufficient checks, a well designed form, and a crossreferencable numbering
system, it is unlikely that many motorists could successfully avoid inspection
and still receive registration.
Many states currently having operational I/M programs or pilot programs
have utilized or will be adopting the motor vehicle registration enforcement
procedure. Included are Arizona; New Jersey; Portland, Oregon; and Nevada.
The notable programs using sticker ticketing for emission inspection are
Cincinnati, Ohio; Chicago, Illinois; and Rhode Island. These programs are
discussed below.
The sticker ticketing approach is effective primarily for statewide
programs. Rhode Island, for example, has utilized the sticker ticketing for
a number of years in connection with its safety inspection enforcement. By
maintaining the sticker system, Rhode Island did not have to change its
registration process; registration is not staggered in Rhode Island but
would have to be under a registration enforcement system. One reason for
32
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success of this system in Rhode Island is that since the safety program had
been enforced with stickers, the public was used to the system and enforcement
mechanisms had already been established. The state has used "random pullover"
for many years both as a direct enforcement tool as well as a quality assurance
mechanism. Any vehicle that, despite having a recently issued valid sticker,
has obvious safety or emissions control deficiencies, is required to be
fixed accordingly and reinspected. In addition, the garage that performed
the initial inspection is visited by appropriate state personnel who check on
inspection procedures, recordkeeping, etc. Rhode Island is now purchasing two
vans equipped with emissions analyzers for the purpose of extending the random
pullovers to include emission tests.
In an I/M program limited to urban areas only, however, the sticker
ticketing approach is inherently more difficult to administer and less effec-
tive in terms of compliance levels. In the Cincinnati, Ohio program, for
example, compliance is estimated at only 25 to 30 percent. The most important
reason for such low compliance is the inability of enforcement officials to
distinguish among vehicles registered in the affected area and other areas of
the State. One solution would be to have a specially coded license plate for
the affected vehicles. This, unfortunately, would result in significant addi-
tional costs even before the actual enforcement would take place. For the
registration enforcement procedure, however, the clerk handling the registration
would only have to check the registrant's address to verify whether or not an
emissions inspection is required prior to registration. It is possible that
under these circumstances, motorists may attempt to register their vehicles in
counties without I/M to avoid inspection. From these considerations, it may
be seen that potential problems with enforcement of a program limited to urban
counties are inevitable regardless of enforcement procedure adopted. The prob-
lems associated with identification of affected vehicles under the sticker
ticketing approach, however, makes enforcement considerably more difficult than
when registration enforcement is used.
Program Costs
The motor vehicle registration method of enforcement is generally less
costly than the sticker ticketing approach. Costs for the registration proce-
dure are minimal provided that the motorists bring certificates of compliance
(printed sheet or a stamp affixed to the registration renewal form) to the
registry prior to the annual registration. There will, of course, be some
additional clerical costs, the extent of which will depend on the form the
compliance verification will be in (i.e., stamp on the registration form,
separate sheet of paper, etc.). Sticker ticketing costs, however, may be
very substantial, particularly if additional enforcement personnel are required.
The Cincinnati Air Pollution Control Board employs four special enforce-
ment officers, the "Green Hornets," whose primary responsibility is issuing
tickets to motorists whose vehicles do not have valid inspection stickers.
The costs of salaries, overhead, vehicles, etc. for the "Green Hornets" are
estimated to total $100,000 per year. In addition, the City of Cincinnati
Police Officers also issue tickets as part of their normal patrolling routine.
The city estimates that this activity costs roughly a half million dollars
annually. Other additional costs stem from court costs, administration costs,
costs involved in collection and handling of fines. Some of these costs are
recovered through the fines.
33
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A summary of advantages and disadvantages of both methods of enforcement
is presented in Table 7.
TABLE 7. ADVANTAGES AND DISADVANTAGES OF TWO ENFORCEMENT MECHANISMS
Enforcement
mechanism
Advantages
Disadvantages
Sticker ticketing 1. Frequency of inspection 1. May require additional
Registration
2.
may be independent of
frequency of
registration
High level of compli-
ance for statewide
programs
3. No need to change
registration process.
1. High level of
compliance.
2. Can be easily adapted
for substatewide
program.
3. Additional costs less
severe.
4. No additional law en-
forcement officials
needed.
enforcement personnel
2. Poor level of compliance
for substatewide programs.
3. High enforcement costs.
4. Must devise means for
identification of sub-
jected vehicles in sub-
statewide program.
1. Frequency of inspection
should be the same as
frequency of registration.
2. Registration must be
staggered.
SUPPORTING PROGRAMS REQUIRED
Several supporting programs are considered essential to the successful
implementation of an I/M program. Three specific programs that are particu-
larly important are mechanics' training, public information, consumer protec-
tion and quality assurance. These are discussed in the following paragraphs.
Mechanics Training
Need for Mechanics Training—
Mechanics training is a highly important part of an effective I/M pro-
gram. Mechanics training may occur through a government-sponsored series of
courses, through auto industry programs, as a regular part of vocational train-
ing courses, or informally through repair shop on-the-job training. Most
government-sponsored mechanics training courses include both background con-
tent, or orientation towards the basic need and benefits of I/M and the
mechanic's role in the program, as well as technical content on automobile
emission control systems, correct diagnosis and repair of emission control
34
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tuneup procedures. EPA and the automobile industry have focused attention on
mechanics training for two basic reasons. One is the increasing technical
complexity of automobile emissions control systems. Owing to the growing
complexity and sophistication of the basic ignition and carburetion systems,
and the use of electronic devices and power systems, there is an ever increas-
ing need for constant training and retraining of mechanics. In recognition of
this, automobile manufacturers have themselves instituted in-service training
programs for mechanics.
The second basic reason for mechanics training relates to the employment
situation in the automobile repair industry itself and public attitude towards
it. Owing to skill shortages, relatively high employee turnover rates, and
the growing complexity of the motor vehicles and repair shop procedures, it is
generally felt that there are widespread substandard (and unethical) repair
practices in the repair industry. In the past few years there has been much
publicity on consumer dissatisfaction with the quality of service experienced
throughout the country. In response to this general dissatisfaction, there
have been proposals to place rather stringent regulation of the repair indus-
try through licensing or certification of repair facilities and/or mechanics.
The potential effects of such regulation have been debated widely. Most in-
dustry spokespersons strongly oppose stringent controls because they feel that
they would restrict competition. Therefore, mechanics training appears to be
a sound alternative to licensing or other forms of direct regulation of the
repair industry.
A related development of major concern to the I/M program itself, is the
widespread practice of motor vehicle owners tampering with their emissions
control systems and fuel switching. Misunderstanding on the part of both the
public and the auto repair industry on the technical aspects of emission con-
trols and the relationships between emissions control, fuel economy, and per-
formance have encouraged these practices. U.S. EPA has stated that 35 percent
of 1976 and 1977 model cars have had their emission systems tampered with in
some way, ranging from minor adjustments away from manufacturer specifications
to major sophisticated disconnections or modifications.
Benefits of Mechanic Training—
The benefits of mechanics training may readily be seen from the above
analysis of the needs for it: better understanding of the need for emission
tuneups and repairs, a more positive attitude toward emissions reduction and
the I/M program, higher quality emission repairs and tuneups, fewer consumer
complaints about emission repairs, reductions in illegal tampering and fuel
switching, and a generally better relationship between the auto repair indus-
try and the public. In conjunction with mechanics training a comprehensive
public education program is, of course, necessary to ensure that the public
at large does not encourage or contribute to practices such as tampering.
Tampering reduces the overall effectiveness of mechanics training programs
in particular and the I/M effort in general.
Approaches to Mechanics Training—
A variety of approaches have been instituted for mechanics training in
various states, ranging from very comprehensive government-sponsored programs
to informal industry-sponsored efforts. In this discussion, the emphasis will
35
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be on providing an understanding of the range of methods that could be employed
in Minnesota.
Many states have instituted formal mechanics training programs in conjunc-
tion with the implementation of their I/M programs. In terms of the actual
timing of these courses, it is important to begin training mechanics several
months to a year before the mandatory inspection process begins. However, the
difficulty in implementing early training programs relates to the fact that
attendance is generally voluntary. Consequently, there must be an incentive
to participate. The primary incentives are: first, government requirements for
for the official certification of a repair shop that it employ at least one
mechanic who has completed an approved mechanics training course, and second,
the economic incentive to the repair facilities and mechanics that result from
the certification process. The repair shops that meet the certification re-
quirements can increase their repair business and this serves as a significant
incentive to other shops and mechanics to join the program. Obviously, as the
I/M program becomes operational and repair demand grows, so does the demand for
mechanics training.
The government sponsored programs may be held in a classroom setting at
local vocational schools or community colleges or, at the private facilities
that wish to become certified. Typically, such courses may be held in the
evenings and last for 12 total hours. Subject matter includes basic orienta-
tion to the needs and benefits of I/M and the role of emission tuneup personnel
in the I/M program and familiarization with basic emission control systems
equipment and emission control tuneups.
Another approach, which was found useful in Arizona's program, is on-the-
job training where special two-person instructor teams hold courses at local
repair facilities, training mechanics from nearby shops. This approach em-
phasizes practical experience and overcomes the problem of reaching mechanics
who are unable to take the time to attend classroom courses. It also has the
added advantage of making mechanics feel comfortable in the course setting.
If not already a piece of standard shop equipment, an emissions analyzer may
be brought to the local repair facility to provide "hands-on" experience
during the "on-the-job" training course. Equipment manufacturers, themselves,
offer training when their products are purchased.
In addition to government-sponsored I/M program mechanics training courses,
it is important to consider industry-sponsored efforts and resources. General
Motors Training Centers are located in many metropolitan areas. These centers
regularly hold special emission control repair and tuneup courses for GM equip-
ment at no charge to the mechanics. Some dealers send mechanics regularly to
these centers to update their knowledge and skills. The other major automobile
manufacturers also offer training opportunities. Manufacturers, both domestic
and foreign, may send instructors with mobile vans to dealers or localities
upon request from local car dealers to conduct mechanics training courses.
Another important resource is the statewide vocational education school
system. Regular mechanics training courses of longer duration than'those
described above, are held for students seeking basic automobile mechanic
skills. These courses should receive continuously updated information on the
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new technologies and skills so that students graduating from them are competent
to do emission control repair and tuneup work. As mentioned above, most of the
instructors trained through the Colorado State University program incorporate
emissions-related information into their ongoing mechanics classes. This
assures that new mechanics entering the trade will have a substantial back-
ground, thus enabling the repair industry to handle the increased number of
repairs due to I/M and the more complex technology of today's vehicles.
An important footnote to the mechanics training approaches noted above
is that, no matter what approach(es) are used, there is a constant need to
update both the instructors and the students on a regular basis. As the
automotive technology grows, short courses which incorporate the new aspects
of the motor vehicle industry should be offered as often as possible.
Public Information Programs
Experiences in several states that recently established inspection/
maintenance programs emphasize the importance of an effective public rela-
tions program. A well-designed, comprehensive program that introduces the
public to the basic need for, and benefits of, I/M and clarifies the mis-
understandings that surround I/M is critical during the early stages of
implementation. A well-thought-out program can help eliminate potentially
adverse reactions that other states with inadequate public relations programs
have experienced (e.g., Arizona; Cincinnati, Ohio; and Chicago, Illinois).
A comprehensive public relations program should consist of three basic
phases: (1) early initial public education on the basic need and benefits
of I/M; (2) an intensive public relations effort 6 months prior to the ac-
tual beginning of mandatory inspection; and (3) an ongoing public relations
program. These are discussed below.
Phase I: Initial Public Information Program—
The emphasis of this phase, which should begin in the early planning and
design stages, should be in basic education as to the needs for I/M, the bene-
fits of I/M, and what it means to the public. It is essential that the public
begin to gain a familiarity with the I/M concept and that this concept have
time to grow in the public awareness. By beginning early grass roots acti-
vities, support for the I/M program can be obtained. The elements of this
phase would consist of a slide presentation, mobile emission testing display,
a generalized brochure, and press releases. Presentations can be given to
specialized interest groups such as clean air groups, environmental groups
and conservation clubs, the League of Women Voters, automobile clubs, auto-
mobile service industry groups, and local civic or service clubs. Also,
metropolitan and regional planning agencies can be involved at this point.
A mobile emissions test demonstration van has been found useful to acquaint
the public or special groups with the inspection process. Many states have
prepared brochures explaining I/M and distributed it widely among the general
public. As important decisions are made and implementation begins, periodic
press releases should be made. This initial public information effort may be
accomplished by the state itself or through assistance provided by private
organizations with experience in I/M public relations programs.
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Phase II: Preinspection Public Relations—
About 6 months prior to the opening of test lanes for mandatory testing
with voluntary maintenance, there should be an intensive public relations
effort. During this time every motorist must be informed of the needs and
benefits of I/M and also of his obligations and rights and the basic organi-
zation and procedures in the program. Also, this is the period during which
the training of the inspectors, in either state or contractor lanes would
occur. An important part of the training is dealing effectively and courteously
with the public.
The basic elements of Phase II public relations would be a mailing to
each motorist, inspector training, news relations and media advertising. The
mailing would consist of a pamphlet not only explaining the basic reasons for
having I/M and the benefits such as air quality and fuel economy improvements
but also the times and places of the inspection stations operation, what
consumer rights and obligations are, what the complaint procedures are, and
also important details of the maintenance phase. During this phase, media
advertisements or announcements are important because it is critical that
every affected motorist receives the right information. All the employees
of both the State and the contractor who deal directly with the public, espe-
cially the emission inspectors, station managers, hotline operators, com-
plaints investigators, and calibration officials should receive training in
how to deal with the public and an understanding of the basics of I/M.
Phase III: Ongoing Public Relations—
The emphasis in the ongoing public relations program is largely informa-
tional. States with existing I/M programs such as New Jersey and Arizona
have indicated that as the public becomes used to the program there may be
somewhat less need for an intensive public relations effort. There would still
be a need to inform motorists of any significant changes in program operations
or other modifications of program elements such as waivers, exemptions, repair
cost ceiling, inspection fees, or registration procedures. This would entail
periodic mailing and possibly some media announcements. Also, new employees
who deal with the public would be required to receive the same orientation
that the initial personnel received at the beginning of the program. The
public should also be made aware of the status of the program in terms of
the emissions reductions achieved and other benefits accrued.
Consumer Protection
An effective consumer protection program is highly important for a suc-
cessful I/M program. It is important from the point of view of protecting
the public from unnecessary costs and inconveniences and equally important in
securing general public acceptance and avoiding a significant buildup of ad-
verse publicity. Among such consumer protection and convenience measures are
public relations elements, although the primary aim of these elements is en-
suring protection from inequities in either the inspection or the maintenance
phase of the program.
Consumer protection mechanisms are generally of two types. First, there
are specific active procedures set up to deal with consumer complaints as they
occur. These are the consumer hotlines and complaints investigators. Second,
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there are features built into the system that directly or indirectly protect
consumers from potential inequities or abuses. These include state motor
vehicle repair regulations, repair cost ceilings, waivers or exemptions, re-
pair facility or mechanic licensing or approval, and warranty regulations
(both federal and state).
Consumer Hotlines—
Consumer hotlines would serve two important functions. First, they would
provide valuable information to the public regarding basic operating times and
locations of the inspection lanes, procedures, consumer rights and obligations,
and other related information. Second, and equally important, the hotlines
would be centralized referral points to guide the consumer after an evaluation
of his problem to the correct department. In many cases, all that may be needed
is correct information, but when a significant problem requires the attention of
a particular department, the consumer can then be routed to the right office.
Also, the hotline personnel are trained in dealing with the public and thus,
can make a significant contribution to the overall public relations effort of
the overall I/M program. It is very important that all contacts between the
public and I/M personnel be smooth and harmonious, especially given the some-
what controversial nature of the program.
Complaints Investigation—
Some of the problems reported to the hotlines would require referral to
other departments, depending on the nature of the complaint. As an example,
complaints that require legal actions would be routed to the Attorney General's
office. Of course some problems would presumably involve more than one depart-
ment's involvement. Any problem could potentially involve the Attorney General's
office at some point if illegal proceedings were uncovered that required legal
action or resolution. Hopefully, most problems could be resolved without re-
sorting to legal action.
Repair Cost Limits—
The repair cost limit is a maximum cost that a motorist may be obligated
to spend on repairs for his motor vehicle in order to meet the emission stan-
dards. This cost ceiling helps to prevent the program from becoming an exces-
sive burden, especially on those vehicle owners in lower income brackets. Also,
on certain vehicles the cost of complying may be so great as to make operation
prohibitively expensive. However, it should be clearly stated that the vehicle
owner is in no way compelled to keep the repairs below the specified limit.
For those who can easily afford the extra costs or who desire to achieve full
compliance, there should be strong encouragement to do so.
Repair costs may be cumulative. In some cases a motorist may fail the
retest and return to the repair shop again for repairs. The repair cost limit
applies to the cumulative emission repairs for the entire sequence within a
specified time limit after failing the emission test.
Repair cost limits are generally of two types. First, an absolute dollar
limit and second, a sliding scale related to the value of the vehicle. In the
first approach generally a fixed upper limit of from $50 to $100 is set which
applies to all vehicles regardless of their age, conditions, or resale value.
In the second approach, which in theory would be more equitable, the price
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ceiling relates to the vehicle value as determined by an accepted reference
such as the used car Blue Book of average retail prices.
Waivers and Exemptions—
Granting of waivers or exemptions for specific vehicle types, in addition
to vehicles exceeding the repair cost ceiling, is another consumer protection
mechanism. Exemptions of vehicles over a certain age is a commonly used method
to protect owners from undue financial hardships. The older vehicles generally
cost more to bring into compliance and are more likely to need extensive re-
pairs such as ring or valve jobs. Moreover, given the small fraction of the
total vehicle population that they represent, such exemptions entail a minimum
sacrifice in overall emission reduction benefits. Other vehicle types commonly
given exemptions are electric, experimental, antique, and off-the-road vehicles.
The major considerations when judging whether any particular vehicle type should
be exempt would be the potential hardships on vehicle owners, balanced by ef-
fects on overall emissions reductions. A more detailed discussion of waivers
and exemptions appears earlier in this section.
Licensing, Certification, or Approval of Repair Facilities and Mechanics—
Licensing or certification of repair shops and mechanics are mechanisms
for ensuring that repairs are done adequately and at a reasonable cost to the
consumer. As such, they may be important as consumer protection elements.
The type and degree of regulation of private industries such as repair shops
by state government is a sensitive issue but given the need to ensure protec-
tion of the consumer and the adequacy of repair, some type of interaction or
influence on repair industry practices is crucial. An active mechanic training
program in emission-related tuneup and emission repairs has been shown to have
a very beneficial impact on upgrading mechanic skills and fostering a positive
attitude toward emission control.
Most states and repair industry groups do not look favorably at formal
licensing of repair shops and mechanics; rather, they view it as expensive
interference in private industry. Of course, when the repair facilities are
designated as official inspection stations then some sort of official licens-
ing and closer supervision is very important for both consumer protection and
quality assurance considerations. Generally, there are two reasons for need-
ing some supervision or influence on the private repair facilities: emission
analyzer calibration and accuracy and control of unauthorized repair practices.
Rather than formal licensing of repair facilities, by which is meant that only
licensed facilities could perform emission repairs, a lesser degree of control
in the form of certification or approval would be appropriate. Given the need
for using reasonably accurate and reliable analyzers, many states publish lists
of approved emission analyzers. New Jersey has one such list. A repair facility
may become approved or certified if it utilizes an approved analyzer. In addi-
tion, the state may require that the facility employ emission tuneup mechanics
who have taken approved mechanic training courses. Furthermore, the state could
have each approved analyzer calibrated at regular intervals.
Warrantees—
The ability of in-use vehciles to maintain the emission standards for
which they were designed depends largely on the integrity of the catalytic
converters: it is significant to have a mechanism that ensures, that failed
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equipment will be identified and replaced. This problem was recognized by the
Clean Air Act Amendments warranty provisions in Section 207(b).
The intent of the Federal Clean Air Act 207(b) warranty provisions was to
ensure that the basic emission control equipment be manufactured such that it
would last up to 50,000 miles or 5 years, whichever came first. As such 207(b)
may be seen as an incentive to the manufacturers to design the basic emission
control equipment to last at least up to the end of the warranty period if not
longer. There is still much debate about what should be the best warranty
period and suggestions have been made to have the warranty extended to the
entire useful life of the vehicle or 100,000 miles. The actual working of
section 207(b) is as follows:
"(b) If the Administrator determines that (i) there are available
testing methods and procedures to ascertain whether, when in ac-
tual use throughout its useful life (as determined under section
202(d), each vehicle and engine to which regulations under section
202 apply complies with the emission standards of such regulations,
(ii) such methods and procedures are in accordance with good engineer-
ing practices, and (iii) such methods and procedures are reasonably
capable of being correlated with tests conducted under section 206(a)
(1), then -
(1) he shall establish such methods and procedures by
regulation, and
(2) at such time as he determines that inspection facil-
ities or equipment are available for purposes of carrying out
testing methods and procedures established under paragraph (1),
he shall prescribe regulations which shall require manufacturers
to warrant the emission control device or system of each new motor
vehicle or new motor vehicle engine to which a regulation under
section 202 applies and which is manufactured in a model year
beginning after the Administrator first prescribes warranty regu-
lations under this paragraph. The warranty under such regulations
shall run to the ultimate purchaser and each subsequent purchaser
and shall provide that if -
(A) the vehicle or engine is maintained and
operated in accordance with instructions under
subsection (c)(3),
(B) it fails to conform at any time during
its useful life (as determined under section
202(d)) to the regulations prescribed under sec-
tion 202, and
(C) such nonconformity results in the ulti-
mate purchaser (or any subsequent purchaser) of
such vehicle or engine having to bear any penalty
or other sanction (including the denial of the
right to use such vehicle or engine) under State
or Federal law,
then such manufacturer shall remedy such nonconformity under such
warranty with the cost thereof to be borne by the manufacturer.
No such warranty shall be invalid on the basis of any part used
in the maintenance or repair of a vehicle or engine if such part
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was certified as provided under subsection (a)(2). For purposes
of the warranty under this subsection, for the period after twenty-
four months or twenty-four thousand miles (whichever first occurs)
the term "emission control device or system" means a catalytic
converter, thermal reactor, or other component installed on or
in a vehicle for the sole or primary purpose of reducing vehicle
emissions. Such terms shall not include those vehicle components
which were in general use prior to model year 1968."
The basic meaning of the warranty is that the manufacturer will be re-
sponsible for the costs of replacement of the emission control devices or sys-
tem up to 50,000 miles or 5 years whichever comes first provided that the
vehicle is operated and maintained in accord with written instructions fur-
nished by the manufacturer. In relation to the I/M program, what is particu-
larly important is the definition of the acceptable test procetdures referred
to in the first paragraph of section 207(b). The basic question is what actual
emissions test will be reasonably correlated with the basic standard of emis-
sion testing which is the Federal Test Procedure (FTP) used to determine if
prototype vehicles and vehicles selected from the assembly line meet the ap-
plicable emission test standards under the Federal Motor Vehicle Emission Con-
trol Program (FMVCP). The purpose of this program is to ensure that cars
being designed and manufactured meet the Federal emission standards. 207(b)
requires that there be a reasonable correlation between the short emission
test used in the I/M program with the lengthy FTP. To date five short tests
have been proposed as suitable for use in light-duty vehicle and light-duty
truck emission inspection program. These include the following tests:
• the idle test
• the Federal 3-mode
• the Clayton Key mode
• the Federal Short Cycle
• the New York/New Jersey short cycle.
These tests, then, have been proposed as being suitable for use in an I/M
program to implement the warranty provisions of 207(b). An associated issue
is the determination of appropriate cutpoints, that is, correct emission test
standards. There are three options for developing these standards: states
can determine them, or they can be provided by EPA or the manufacturers could
provide the date on the basis of which standards would be set either by the
states or the EPA. With EPA's adoption of official cutpoints,however, in order
for the 207(b) warranty provisions to be activated by an I/M program test fail-
ure, then the state's I/M cutpoints must be at least as stringent as the pro-
mulgated EPA cutpoints.
Quality Assurance
Maintaining a high degree of precision and? uniformity in emission test
results is vital to the success of an inspection/maintenance program. Accurate
information must be generated to correctly analyze the impact of the program on
lowering emissions and to maintain public interest in the program. If I/M is
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perceived as a haphazard, arbitrary program, enforcement problems will become
intractable.
The repeatability of the actual test results is central to the issue of
quality assurance. The test must be carried out correctly and with a high
degree of uniformity on all vehicles included in the program. A program
utilizing a network of centralized inspection facilities will facilitate
the standardization and repeatability 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 cen-
tral computer system.
The key or loaded-mode test procedure is a sophisticated test that mea-
sures vehicle exhaust emissions under a variety of different "loads" or
conditions that simultate the actual emissions generated by a vehicle under
normal driving conditions. To correctly perform a loaded-mode test, a series
of samples must be taken from a vehicle's exhaust when it is experiencing
loads within certain parameters. The results of this sampling series are
integrated to provide a composite assessment of the vehicle's emissions
characteristics.
Automating a loaded-mode test by interfacing the control of the analyzer
and dynamometer with a computer routine removes a large portion of the cause
of test result variability, human error. This approach to test control limits
human involvement to (1) identifying the vehicle to the computer by means of
entering the vehicle identification number (VIN) into an input/output device
(i.e., a "CRT" or TV screen-type computer terminal), (2) manually inserting
the analyzer probe into the tailpipe (or tailpipes) of the vehicle being
tested, and (3) operating the vehicle on the chassis dynamometer. The
computer routine can monitor the "load" being generated by the dynamometer and
automatically take exhaust samples at the appropriate times. The samples
results can be integrated by the computer and compared with test standards
stored in the computer.
Once such a system has been installed and its software has been found
accurate and reliable, a series of relatively simple checks should be made
to insure its continued correct operation. Analyzers must be calibrated
periodically. This procedure is straightforward. By analyzing a set of
"calibration gases" that have known precisely-blended contents and checking
the analyzers readings of actual gas content, the analyzers accuracy can be
determined. At the very least, an exhaust gas analyzer should be checked
in this fashion whenever it is turned on and adjusted if its readings are
different from what they should be. With an automated system, the analyzer
can be calibrated regularly at frequencies of 1 hour to minimize the possi-
bility of inaccuracies resulting from equipment malfunction.
In the contractor-operated system, periodic inspections should be made
by the state to verify the accuracy of data submitted by the contractor.
Ninety days is the generally accepted interval for such checks on central
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test lane equipment. In addition to scheduled inspections, the, state may per-
form unannounced checks if there have been complaints about test accuracy or
other indications that an analyzer has not been functioning properly.
In order for such state inspections and checks to be useful, there are
certain informational requirements that should be placed on the contractor.
Most importantly, periodic reports on the frequency and results of equipment
calibrations should be mandatory. A log of any adjustments made in the process
of calibrating equipment should also be kept. Experience to date shows that
the operation of automated test systems is relatively trouble free, and that
downtime resulting from equipment malfunction is minimal. In addition to
direct equipment maintenance and calibration records, there are a number of
items that should be recorded to provide data for use in analyzing the effec-
tiveness of the program.
Another quality assurance issue that should be considered is prohibiting
an inspection contractor from engaging in any other type of business that leads
to a conflict of interest. The contractor must not be in a position to profit
from one test result, but not another.
Standards should be set regarding the type of analyzing equipment that may
be used by the contractor. There is a wide range in the quality and capacity
of such equipment on the market today. Use of equipment that is inappropriate
to a centralized network type application could provide a very low level of
test accuracy and uniformity between tests. Equipment performance standards
can be set by two methods. First, a list of approved equipment, by manufacturer
and model type, can be compiled. Alternately, the actual specifications and
tolerances that acceptable equipment must meet may be promulgated.
There are a number of performance parameters that should be specified to
insure that only high quality equipment is used. Most obviously, the accuracy
(in plus or minus percent) of the actual hydrocarbon and carbon monoxide read-
ings must be specified. The consistency of a unit's analysis over time should
also be subject to limits. If this "zero drift" is large over time, either
more frequent recalibrations should be stipulated or the unit should not be
approved for use. The "purge time" of an exhaust gas analyzer is another
important parameter. This refers to the time interval that must pass between
tests to assure that the emission readings are influenced only by the exhaust
of the vehicle being tested. The "purge time" is a measure of the time that a
unit must remain unused before it has been cleansed of all gases introduced by
the previous test sequence. In high speed units of the type suitable for use
in the high volume contractor-operated system, an inert or "neutral" gas such
as nitrogen is run through the analyzer after each test sequence to remove all
traces of material introduced into the analyzers system by previous tests.
PHASING CONSIDERATIONS
Planning considerations, or phasing, serve to enhance the likelihood of
successful program implementation not only in terms of meeting deadlines and
achieving efficiency, but also in terms of gaining public confidence in the
intent and equity of the program. With regard to the overall phase-in of an
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I/M program, there exists a general sequence of events that must be under-
taken in logical order to ensure the program will be implemented by the EPA
deadline of Mandatory Inspection and Maintenance by January 1, 1983. These
issues have been discussed in detail in Section 6, Implementation Scheduling.
Apart from these issues that concern mandatory phasing elements are additional
issues that are connected with program phasing, but are somewhat less crucial
in nature. These deal primarily with expanding or otherwise changing the
format of the program for purposes other than meeting statutory requirements.
Several of these are discussed below.
Mandatory Inspections - Voluntary Maintenance Phase
Current EPA guidance on I/M program implementation endorses the practice
of scheduling at least one full year of mandatory inspections but voluntary
maintenance. This permits motorist to become somewhat familiar with the pro-
gram and provides an opportunity for both a shakedown of the inspection facil-
ities and procedures, and to collect specific emissions data, which can be
used to define cutpoints for the fully-mandatory phase.
Additionally, one year of voluntary maintenance would give the repair
industry additional time to "gear-up" to the anticipated work load created by
the program. In New Jersey, for example, it was felt that the repair indus-
try was not ready for the fully mandatory phase after one full year of volun-
tary maintenance. As a result, the voluntary maintenance phase was extended
an additional 6 months to allow the industry more time to prepare.
A voluntary maintenance phase does not necessarily mean that motorists
will not repair failed vehicles, particularly if an effective public infor-
mation program stressing benefits supplementary to emission reduction (fuel
savings, increased vehicle life, etc.) is implemented concurrently. In the
Arizona program, for example, there was a measurable reduction in tailpipe
emissions during the voluntary maintenance phase.
One criticism of the one year voluntary maintenance phase is that it may
slow the program's momentum somewhat by creating two critical implementation
dates, one for the original implementation of the program and one for the
initiation of mandatory repair. It could also be argued that a year of vol-
untary maintenance is not desireable because it does not fully utilize the
program's potential for reducing emissions, therefore, the public is being
required to pay for a program that is by design not as effective in meeting
its primary objective as it could be.
An alternative to the one year voluntary maintenance phasing strategy
would be to require mandatory repairs from the beginning of the program, but
to employ initial emission standards so lenient as to fail only the most
gross emitters during the first year and then gradually tighten standards.
It should be pointed out that the two strategies are not mutually exclusive.
For example, New Jersey utilized a voluntary maintenance phase followed by
three phases of increasingly stringent cutpoints.
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Progressively Stringent Outpoints
Vehicle emission standards or "outpoints" determine the overall emissions
reduction potential of an I/M program. They distinguish between those vehicles
requiring emissions-related maintenance and those that do not. The principal
objective of an I/M program is to achieve maximum possible reductions of auto-
motive exhaust pollutants. This objective, however, must be balanced against
equity considerations of public convenience and repair industry capacity. Im-
plementing progressively more stringent cutpoints is one means of achieving
this balance.
Experience from various states implementing I/M programs shows that,
despite a very exhaustive research program to establish cutpoints, it is very
difficult to predict accurately the number of vehicles that will fail the
initial emissions test. The number failed is dependent on the overall emis-
sions characteristics of the vehicle population, a factor which is difficult,
if not impossible, to predict. Should a larger fraction of the vehicle popu-
lation than that anticipated fail the initial test, negative public sentiment
could develop that would jeopardize the I/M program's success. Further diffi-
culties could arise if the total of noncomplying vehicles exceeds the ability
of automotive repair industry to perform required maintenance. These problems,
of course, can be alleviated by setting initial standards such that only the
"gross emitters" will fail the emissions test. Both the public and the repair
industry are then afforded the opportunity to become accustomed to the program
and its economic effects before standards are in full force.
It should be noted that the cutpoints chosen should be periodically re-
viewed to assure that the maximum reasonable emissions reductions are being
attained. As the program continues, it is not unreasonable to expect that
the general condition of the inspectable fleet will improve; this will require
revising the standards to be more stringent in order to maintain the same
failure rate. Revising the cutpoints should be based on vehicle emissions
data compiled during the testing.
Expanding Geographic Coverage
Policy guidance from the U.S. EPA, dated 17 July 1978, suggests that the
minimum acceptable geographic coverage for an I/M program is not only the
designated nonattainment area, but also certain areas beyond, including "the
entire urbanized area and adjacent fringe areas of development."
Seven counties comprising the Minneapolis/St. Paul Metropolitan area
have currently been designated as the bounds of the I/M program proposed here.
At some future time, it may be desirable to expand coverage of the program to
include all counties within the State. A prime example of this would be when
the program itself is expanded to include safety inspections as well as emis-
sion and noise testing.
Although an I/M program involving only the seven Metropolitan counties
would satisfy EPA requirements, such a policy may serve as an incentive for
motorists to illegally register their vehicles in counties outside the covered
area.
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If the decision were made to expand coverage to include the entire State's
population, it may be best to perform this expansion all at once rather than
on a county-by-county basis. Greater economies of scale in construction can
be realized with the former approach, keeping the cost to the motorist as low
as possible.
Expanding Coverage to Include Additional Vehicle Types
Given U.S. EPA policy guidelines that require at least a 25 percent reduc-
tion in light-duty vehicle (LDV) exhaust emissions of HC and CO by 1987, it
is obvious that the burden of responsibility for emissions inspection and main-
tenance will fall upon the LDV population. Definition of this population is
flexible, up to a point. Once maximum weight limits are set by policy deci-
sions, the inspectable vehicle population may be defined, and facilities de-
signed to handle this population. So long as inspection facilities are de-
signed to handle a certain motor vehicle population over a period of years, it
is not practical to phase-in additional vehicle types. It is more cost-
effective from the contractor's viewpoint, and probably more equitable from
the state's viewpoint, to initiate a testing program for all the vehicles in
the design population at the outset rather than including additional vehicles
at a later date.
INTEGRATING SAFETY, NOISE, AND EMISSIONS TESTING
Introduction
The concept of mandatory motor vehicle inspection is not new. Many states
in the U.S. currently conduct periodic motor vehicle safety inspections of
some sort, ranging in comprehensiveness from random spot inspections of a
relatively small fraction of the vehicle population for obvious defects (tire
wear, nonfunctioning lights, wipers, or horn, etc.), to regularly scheduled,
detailed inspections of various major systems such as the brakes, suspen-
sion, and steering. Several states go further still with requirements for
inspecting vehicle emission characteristics to ensure that the pollution con-
trol devices are functioning properly and that the engine's overall perfor-
mance (with regard to emissions) is within design specifications.
In addition to safety and emission considerations, interest has recently
evolved in the noise aspects of motor vehicles. This interest has risen to the
point where several states and cities as well as the Federal government have
set noise standards on motor vehicles, and are actively enforcing these
standards.
In that standards have been established, there are obviously requirements
for ensuring compliance with the standards. It would appear at this point that
there would be many similarities among programs concerned with monitoring and
enforcing compliance in these three areas, since each focuses on various
physical attributes of a motor vehicle that are wholly quantifiable and con-
trollable. The primary questions at this point should concern whether or not
there are distinct advantages or, for that matter, disadvantages, to combining
any of these programs, and secondly, whether it is possible from a technical
or administrative standpoint to operate a combined program. The following
47
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paragraphs provide a discussion of various aspects of each program that tend
to make them either compatible or incompatible in the context of program
consolidation.
Current Status of Inspection Programs in Minnesota
Currently, the State of Minnesota has only a random pullover safety in-
spection program instituted. The need for an automotive emission inspection
program, however, has been defined by the Minnesota Pollution Control Agency
as indicated previously, in that the national ambient air quality standards
for photochemical oxidants (Ox) and carbon monoxide (CO) will not be achieved
in all areas by 1982 and, therefore, a request from the State to the U.S. EPA
for a time extension for compliance is almost a certainty. As indicated pre-
viously, a requirement for considering time extensions is that the State have
a definite schedule established for implementing an acceptable motor vehicle
emissions inspection and maintenance program.
Minnesota currently has regulations dealing with vehicle noise, however
these focus on establishing limits on drive-by noise only. It has been in-
dicated that standards will be established for exhaust noise levels, as well.
In this connection there will be a need for exhaust noise testing in the fore-
seeable future.
Given the current status of inspection programs in the State and the time
frame within which the emissions inspection program must be implemented, it
is perhaps a realistic viewpoint that I/M will be developed either separately
or in conjunction with noise testing, but not with safety. This is not to say,
however, that the development of the I/M program should not consider the
possibility that either or both of the other programs would be integrated in
the future. At this point, it is prudent to consider the potential for com-
bining inspection programs and to perhaps base some of the decisions regard-
ing the I/M program development on the possibility that safety and/or noise
inspection programs will be implemented in the future.
Technical Considerations
A first consideration in the overall concept of consolidating inspection
programs is that, in the most basic sense, all three types are very similar
from the technical viewpoint. Each is concerned with testing a component or
series of components to ensure their conformance with established standards.
Further, the level of effort, the type of individual qualified to perform the
inspections, and the basic facilities required to perform the three types of
inspections are similar, for the most part. Considering individual testing
programs, it is clear that the degree to which these similarities exist can
be greatly influenced by specific options selected for each program. In fact,
if the intent is truly to combine these programs, several specific options
become inappropriate at the outset.
To assist in identifying common features and elements of each program,
a listing was developed, which describes the general features of various op-
tions available in selecting a program. This listing, shown in Table 8, is
subjective to some degree, but it does provide a reasonable indication of
48
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the major common elements in safety, emission, and noise inspection programs.
Based on Table 8, several individual program configurations can be considered
inappropriate at the outset; these are the programs where the effectiveness
is highly questionable or the particular configuration is not recognized as
a technically acceptable option, as indicated by letter code T or W, respec-
ively, ir the column indicating Technical Limitations.
Further, several combinations of options within the three programs are
not compatible. These combinations include both periodic inspections and
inspections that cannot be scheduled (i.e., title transfer or random pull-
over). The problem, obviously, is that one of the primary advantages of a com-
bined program is the capability of performing the three types of inspections
during one visit to the inspection site; this advantage would not be gained
unless (1) all three were either periodic, required upon title transfer, or
conducted during random spot checks; or (2) all were periodic as well as
required either (or both) upon title transfer or as part of a random spot
check (or other similar combinations).
An additional issue in this connection concerns the general operation of
test facilities. For optimal efficiency, the tests should be conducted at
the same facility, therefore it is obvious that a combined program should be
operated entirely (1) within private garages, (2) at centralized facilities,
or (3) using mobile inspection units.
The primary obstacles from a technical standpoint to combining any two
or all three programs are those described above. Other issues should also be
considered, which might influence decisions regarding more detailed aspects of
the testing programs. In general, it would be an advantage to develop programs
that are approximately on the same level of comprehensiveness. If, for instance,
the emission program is to be fairly rigorous requiring mechanic training, an
investment in facilities and equipment, etc., it would be reasonable to inte-
grate a safety inspection program that would also include training (presumably
for the same individuals trained in emission testing), and maximum utilization
of the equipment and facilities requires for the emission program. The intent
should be to gain the maximum benefit from each dollar expended on the program
this type of optimization requires analyzing in detail the incremental costs
and benefits for various combined program scenarios.
In summary, then, there are no major technical obstacles to combining any
or all three types of inspection programs, provided that the most obviously
incompatible options for each type are not selected. This implies that the
existing random safety inspection program would, at best, be very difficult
to combine with the I/M program. In that the national trend has been toward
periodic safety inspections, it is perhaps appropriate that the initial I/M
planning at least recognize the possibility that this type of safety program
may be instituted in the future and therefore allowances made for possibly
consolidating the programs.
Administrative Issues
The consolidation of inspection programs is not likely to result in any
major problems from the viewpoint of program administration. In fact, it is
52
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quite likely that the administration of a combined program is much more effi-
cient than that of two or three separate programs. Interagency coordination
and cooperation, however, is essential to program efficiency. Considering
that, as a minimum, agencies representing law enforcement, highway safety,
environmental protection, and motor vehicle registration would play major roles
in a consolidated program, the need for a high degree of cooperation and coor-
dination is obvious. From the experience to date with combined programs, there
is no basis for skepticism regarding the likelihood that the required inter-
agency coordination can readily be established.
Summary
From both a review of the available literature, and conversations with
individuals responsible for the operation and administration of combined
programs, it can be concluded that combined programs are entirely feasible
and, in fact, may be more desirable than separate programs. From the tech-
nical standpoint, the primary consideration in consolidating programs is to
ensure that the basic features of each program are mutually compatible. This
obviously has some implications regarding the existing motor vehicle safety
inspection program in Minnesota. It is doubtful that the safety program in
its present format would be combined with I/M, because of the basic differences
in the programs. The possibility of a periodic safety inspection being imple-
mented in the future and perhaps being combined with the I/M program should
be considered.
It can also be concluded that there are no significant administrative
obstacles to overcome in combining programs. Obviously, coordination among
various state agencies is required, which should not prove to be an imple-
mentation barrier.
REFERENCES
1. U.S. Environmental Protection Agency, Mobile Source Enforcement
Division, Technical Support Branch, Washington, B.C. Motor
Vehicle Tampering Survey (1978). November 1978.
2. Kincannon, B. F., and A. H. Castaline. Information Document on
Automobile Emissions Inspection and Maintenance Programs. GCA
Corporation, GCA/Technology Division, Bedford, Massachusetts.
Prepared for U.S. Environmental Protection Agency, Office of
Transportation and Land-Use Policy. Washington, D.C. Report No.
EPA-400/2-78-001. February 1978.
3. Olson Laboratories, Inc. The Short Cycle Test Project. U.S.
Environmental Protection Agency Contract Office of Mobile Source
Air Pollution Control. July 30, 1973.
4. Clayton Manufacturing Company. The Key Mode Evaluation System,
El Monte, California. 1971.
5. California Vehicle Inspection Program, Riverside Trial Program
Summary Report. May 1976.
53
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6. Rubenstein, G., R. Ingels, R. Weis, and A. Wang. Vehicle Inspec-
tion and Maintenance - The California Program, Society of Automo-
tive Engineers Publication No. 760557, presented at Fuels and
Lubricants Meeting. St. Louis, Missouri. June 1976.
7. Panzer, J. Idle Emissions Testing - Part II, Society of Automotive
Engineers Publication No. 740133, prepared for Automotive Engineering
Congress, Detroit, Michigan. February 25 through March 1, 1974.
8. Panzer, J. Idle Emissions Testing, Some Effects of Engine Malfunc-
tions on Emissions, Exxon Research for presentation at MVECC-IV.
Anaheim, California. November 1975.
9. General Motors Company, General Motors Position on Motor Vehicle
Emission Inspection Procedures. February 28, 1975.
10. Rubenstein, et al., op. cit.
11. Midurski, T. P., et al. Evaluation of Motor Vehicle Emissions
Inspection and Maintenance Programs in Wisconsin - Phase 3. Final
Report. GCA Corporation, GCA/Technology Division, Bedford, Massa-
chusetts. Prepared for U.S. Environmental Protection Agency,
Region V Office, Chicago, 111. Report No. EPA-905/2-78-004.
November 1978.
54
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SECTION 3
PROGRAM OPTION
OPTION DEFINITION
Based on a rather detailed review of several possible inspection and main-
tenance program (l/M) scenarios, the Minnesota Pollution Control Agency (MPCA)
selected a specific configuration that appears to be best suited for implemen-
tation in the State. Essentially, the program selected involves establishing
a network of centralized inspection stations where loaded mode emissions test-
ing and stationary noise inspections will be conducted. The basic loaded
mode, centralized facility concept was selected for several reasons. First,
it was considered that the loaded mode option offers several advantages over
the idle mode, including more comprehensive diagnostic capabilities, and more
flexibility in testing procedures. Also, there will likely be an NOX standard
defined in the near future for motor vehicles and NOX testing may become neces-
sary as part of the I/M program; NOX testing can only be performed with the
loaded or high idle test. Since the high idle test necessitates attaching
tachometer leads to the engine, the throughput time for the loaded mode test
is 20-30 percent less than for the high idle test. With the high idle test,
therefore, additional test lanes would be required and the cost to the motorist
would increase accordingly. The major disadvantage of the loaded mode test is
that It is slightly more expensive than the regular idle test to perform (pro-
vided the throughput rates are the same ), since additional test equipment is
required. The incremental cost difference, $0.20 to $0.25 per test, is not
considered to be significant.
The primary reasons for selecting the centralized facility approach over
private garages concerned program control and anticipated public acceptance of
the program. Specifically, the State would be able to exercise much closer con-
trol over the inspection program with fewer personnel, which should result in a
much higher quality program than would be achievable if the decentralized option
were used. Further, it was considered that the public would be much less skep-
tical of a program where inspections were performed by an impartial entity who
would not benefit from vehicles either failing or passing (primarily since re-
pairs are not performed at the centralized facilities, nor are any individuals
undergoing inspections considered "regular customers" who could bias the
inspector).
A number of additional elements must be defined in order to fully des-
cribe the program. The program is currently being considered for implementa-
tion in the following counties:
*
The throughput rate for idle mode testing will depend on the pre-conditioning
requirements adopted when Appendix N is finalized.
55
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• Anoka County
• Carver County
• Dakota County
• Hennepin County
• Ramsey County
• Scott County
• Washington County
The inspection frequency has been defined as annual with inspections
being staggered throughout the year. Generally, inspections will be scheduled
to the extent that they should be performed within a certain time period prior
to registration. A method that could be used is to forward registration
renewal material to motorists, say, 60 days before the renewal deadline. In
order for the motorist to renew his registration, a certificate of compliance
would be required along with the registration form; this certificate of com-
pliance would be obtained by successfully passing the emissions inspection
(or being granted a waiver) at an inspection station. The 60-day lead time
would assure adequate time to obtain an inspection and a reinspection if
required.
The vehicle population to be tested consists essentially of all light-duty
vehicles (LDV's), light-duty trucks (LDT's) with a gross vehicle weight (GVW)
of 9,000 pounds or less, and motorcycles. Some exemptions will be made,
however, including (tentatively):
• motor vehicles registered as classic, pioneer, or collector,
pursuant to Minnesota Statutes, Section 168.10
• any motor vehicle that presents prohibitive inspection problems.
A stringency level (for emissions tests only) of 30 percent has been
defined for this analysis. It has also been indicated that the program would
operate on a mandatory inspection - voluntary repair basis during the first
year. This will serve primarily to acquaint the public with the program as
well as to gather baseline emissions and noise data from which cutpoints can
be established.
Several supporting programs will also be established in conjunction with
the I/M program. Included are programs for: (1) public information, (2) con-
sumer protection, (3) quality assurance, and (4) mechanics' training. These
programs may be operated by the State or portions of each may be operated by
contractors. These ancillary programs are discussed in detail i.n Section 2.
INSPECTION SCENARIO
In order to illustrate how the I/M program will work and where some of
the ancillary programs tie in, the following description of the test procedure
is offered.
56
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The requirements for an emissions inspection in each instance will be
related to the annual registration procedure; that is, emissions inspections
will be required generally during the period when registration renewals are
due. To initiate the registration renewal process, the Division of Motor
Vehicles will mail out registration renewal forms to motorists within the
seven counties. Mailings will be staggered such that approximately one-
twelfth of the total registrations are processed each month (slightly lower
in winter months) approximately 2 months prior to the renewal deadline.
Sometime during this 2-month period, motorists will take their vehicles to
the centralized inspection facilities for the emissions test.
At the inspection station, the motorist will present his renewal forms,
from which certain information will be collected and entered into a computer
file. This information would include:
1. A serial number which allows the test record to be
retrieved and identified with the computer;
2. Exact date and time of the test;
3. The vehicle identification number (VIN);
4. Vehicle registration number;
5. Vehicle model, year, and make;
6. Owner's name;
7. Engine configuration;
8. Emissions control equipment;
9. Vehicle weight class; and
10. Test number (first, second, third, etc.).
Based on this information, test personnel can determine whether or not
the vehicle is exempt from the emissions inspection. If the vehicle is exempt,
the noise emissions level is measured by placing a sound level meter near the
tailpipe outlet while the engine speed is increased. Upon passing the noise test,
the motorist is issued a certificate of compliance, which he submits along
with other registration renewal forms to the Division of Motor Vehicles.
Should the vehicle fail the noise test, the motorist is advised as to the
likely causes (usually defective, inadequate, or inappropriate exhaust system
components) and given a form stating that he has failed the test. The motorist
is then required to have appropriate repairs made to the exhaust system at the
repair facility of his choice; he then returns for a reinspection. Upon
passing the reinspection, he is issued a certificate of compliance and the
registration renewal process continues as usual.
If the vehicle is not exempt from the emissions inspection, it proceeds
through the test lane where it is subjected to both the emissions and noise
57
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tests. Pass-fail criteria for both tests are automatically adjusted to the
particular characteristics of the vehicle. If the vehicle passes both tests,
the certificate of compliance is issued and the registration process continues.
If the emissions and/or noise tests are failed, the motorist is advised of
the likely problems and is given a form stating which portions of the tests
the vehicle failed. The owner then takes the vehicle (and failure forms) to
a repair station where appropriate repairs or adjustments are made. The
mechanic completes a repair form indicating:
1. repair actions taken;
2. parts replaced;
3. cost of parts and labor; and
4. name and address of repair facility.
It is noted that for emissions-related repairs, the vehicle owner is
obligated to spend only a certain amount of money before he is granted a
waiver; the repair form substantiates that the motorist is eligible for a
waiver. There has not been a limit placed on repairs required for noise com-
pliance, however.
The vehicle owner then returns to the inspection facility with the repair
form, and the vehicle undergoes the test that was previously failed. If it
passes, a certificate of compliance is issued; if the repair ceiling was reached
for emissions-related repair work, a waiver and annotated certificate of com-
pliance are issued. The retest is performed free of charge.
If the vehicle fails the first retest, the vehicle owner is obliged to
go through the repair and reinspection cycle once again; however, if the
accumulated total of repair costs exceeds a specified repair cost limit, he
may be granted a waiver as before. A fee will be charged for second (and sub-
sequent) retests; this fee will be somewhat lower than the initial fee, however.
Should the motorist at any point in the above process have a complaint
concerning either the inspection or the maintenance phase, he may register
the complaint with the appropriate State agency by calling a toll-free "hotline"
telephone number. Depending on the nature of the motorist's complaint, the
hotline operators can take a variety of different actions in response. If the
complaint is due to lack of information, the motorist can be referred to a
public relations official who can provide more information about the program
and its methods. If the complaint concerns actions of the contractor or ques-
tions the accuracy of the contractor's equipment, the operators refer the
complaint to an appropriate official concerned with quality assurance. The
Quality Assurance coordinator would decide upon the appropriate action; he
could visit the test lane in question and check the calibration of its emis-
sions analysis equipment, or have a complaints investigator conduct either an
unannounced spot check or a formal investigation of the test lane in question.
If the motorist's complaint concerns actions on the part of the private auto-
motive repair industry, the operators refer the complaint to the designated
consumer protection official or agency that has the authority to investigate
consumer complaints concerning private garages. Should any complaint uncover
58
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criminal actions, then the operators could refer the complaint to the Attorney
General's Office for criminal proceedings.
A general flow chart showing the registration process described above
is provided in Figure 2.
59
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VEHICLE OWNER
TAKES TCHICLE
1TO CENTRALIZED
INSPECTION
FACILITY
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60
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SECTION 4
NETWORK AND PERSONNEL REQUIREMENTS
INSPECTION NETWORK
Two determinants establish the basic inspection facilities requirement
for any I/M program. These determinants include, first, the expected number
of inspections to be performed annually, and, second, the average throughput
rate for each inspection lane.
Annual Number of Inspections
The number of inspections that will be performed annually is a function
of the affected vehicle population size within the area of concern, and the
number of reinspections that are expected to be required. Further, the total
number of annual inspections will change over time as a result of changes in
the vehicle population.
In deriving the network requirements for the Minnesota program, several
conditions were assumed. First, it was assumed that the program would start
in early 1982, and, as a minimum, extend through 1987. The vehicle population,
then, that was used as the basis for determining the number of facilities was
the projected 1987 population in each of the seven affected counties. Also,
it was assumed that only a small fraction of the total population of affected
vehicles would require more than one reinspection; therefore, the basic com-
putations reflect only the base population plus the expected number of first
failures. These factors are discussed in detail below.
Motor Vehicles Population—
Data regarding the motor vehicle and human populations for each of the
seven counties were obtained from the Department of Public Safety, Division
of Motor Vehicles, and the Twin Cities Metropolitan Council, respectively.
These data included tabulations of the 1970 and 1978 human populations, and
the numbers of vehicles by various categories registered in 1977.
To develop an estimate of the number of vehicles that would be inspected
in 1987, both the population and registration data were used. First, the
average annual growth rate for each county from 1970 to 1978 was established.
Table 9 shows both the populations and the growth rates.
61
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TABLE 9. AVERAGE ANNUAL GROWTH FACTORS, HUMAN POPULATION,
1970-1978
County
Anoka
Carver
Dakota
Hennepin
Ramsey
Scott
Washington
Total
1970 population
154,712
28,331
139,808
960,080
476,255
32,423
83,003
1,874,612
1978 population
197,780
37,250
192,870
939,060
466,840
44 , 540
112,610
1,990,950
Average annual
growth factor
1.0312
1.0348
1.0410
0.9972
0.9975
1.0405
1.0389
These average annual growth factors were then applied to the 1978 county
population to arrive at an estimate of the 1987 populations in each county,
which is tabulated in Table 10 below.
TABLE 10. PROJECTED POPULATION BY
COUNTY FOR 1987
County
Anoka
Carver
Dakota
Hennepin
Ramsey
Scott
Washington
Total
Projected population in 1987
260,800
50,700
276,900
915,700
456,400
63,700
158,800
2,183,300
Motor vehicle registration data were used to derive a tabulation of the
number of vehicles (of the types that would be required to undergo inspection)
registered in each county during 1977. Also, the population data for 1978
were adjusted to reflect 1977 conditions; this permitted the establishment of
the ownership rates (expressed in vehicles per capita) of inspectable vehicles
for each county. These data are shown in Table 11.
62
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TABLE 11. DERIVATION OF VEHICLE OWNERSHIP RATES DURING 1977
BY COUNTY
Number o f
Numoer or _. . . . _ , .
, . , Population in Ownership rates
County inspectable vehicles 1(T7-,t / , • , /
. , . ,«-,-,* 1977 (.vehicles/capita
registered in 19/7
Anoka
Carver
Dakota
Hennepin
Ramsey
Scott
Washington
75,998
17,434
90,745
544,900
252,717
20,849
49,543
191,796
31,165
185,274
941,414
468,010
42,806
108,393
0.40
0.56
0.49
0.58
0.54
0.49
0.46
Total
1,052,186
1,968,858
0.53
i
Source: Department of Public Safety, Division of Motor Vehicles.
Derived from 1978 population and growth factors presented in
Table 9.
The ownership rates, then, were applied to the 1987 population estimates
provided in Table 10 to arrive at a preliminary estimate of the 1987 inspect-
able vehicle population; this is presented in Table 12. It is noted that the
ownership rate has been increasing from year to year, and conversations with
planners at the Metropolitan Council indicate that by 1987, the overall owner-
ship rate for the entire seven county area is likely to be approximately
0.60; this translates to a total of 1,309,800 vehicles compared with the
1,156,900 vehicles indicated for an ownership rate of 0.53. The final total
number of vehicles in each county that will be inspected during 1987 was de-
rived from the total for each county shown in Table 12, plus a portion of
the additional vehicles resulting from the increased ownership rate. The
number of additional vehicles added in each county is calculated as a function
of the ratio of the particular county's vehicle population to the total seven-
county vehicle population presented in Table 12. The resulting distributions
are presented in Table 13.
Number of Reinspections Required—
By definition, the tentative failure rate for the Minnesota program is
30 percent. Also, the inspection frequency has been defined as annual. With
these two parameters defined and the 1987 inspectable vehicle population iden-
tified, the total number of annual inspections can be calculated. This is
simply:
N. = P.
i i
(1 + r)
-------
TABLE 12. PROJECTED 1987 COUNTY VEHICLE POPULATIONS* BASED ON AN
OVERALL OWNERSHIP RATE OF 0.53
County
Anoka
Carver
Dakota
Hennepin
Ramsey
Scott
Washington
Total
-.no-, „ i • Ownership rate
1987 Population / , - , / >
v (vehicles/capita)
260,800
50,700
276,900
915,700
456,400
63,700
158,800
2,183,000
0.40
0.56
0.49
0.58
0.54
0.49
0.46
0.53
Projected 1987
vehicle population
104,320
28,392
135,681
531,106
246,456
31,213
73,048
1,150,216
'inspectable vehicles only.
64
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TABLE 13. PROJECTED 1987 COUNTY VEHICLE POPULATIONS BASED ON
AN OVERALL OWNERSHIP RATE OF 0.60
County
Anoka
Carver
Dakota
Hennepin
Ramsey
Scott
Washington
Total
1987 vehicle population
assuming 0.53 ownership rate
No. vehicles*
104
28
135
531
246
31
73
1,150
,320
,392
,681
,106
,456
,213
,048
,216
Percent of
7-county total
9,
2.
11,
46.
21.
2.
6.
100.
.1
,5
.8
,2
,4
,7
.3
0%
Additional vehicles
reflecting 0.60
ownership rate '
14,
3,
18,
73,
34,
4,
10,
159,
522
990
831
728
150
309
054
584
1987 vehicle population
assuming 0.60 ownership
rate''1
118
32
154
604
280
35
83
1,309
,842
,382
,512
,834
,606
,522
,102
,800
From Table 12.
Computed as: V.
Z"=7 V0.53\
when1 V. = the number of additional vehicles for county i:
P. = the percentage of the total 7-county vehicle population
registered in county i;
VQ.fo = 1,309,800 = the total 7-county vehicle population assuming
an ownership rate of 0.60;
vB'b3 = 1,150,216 = the total 7-county vehicle population assuming
an ownership rate of 0.53.
"Computed as the sum of the 1987 vehicle population assuming ownership rate = 0.53,
plus V..
65
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where N. = the number of inspections to be performed in year i;
P. = the inspectable vehicle population for year i; and
r = the failure rate, defined here as 0.30.
Substituting specific values of P for each county, then, yields the total
number of inspections that will be performed for the year of interest, which,
in this instance, is 1987. Table 14 summarizes these computations.
TABLE 14. TOTAL NUMBER OF ANNUAL INSPECTIONS DURING
1987 BY COUNTY
County
Anoka
Carver
Dakota
Hennepin
Ramsey
Scott
Washington
Total
Number of initial
inspections
118,842
32,382
154,512
604,834
280,606
35,522
83,102
1,309,800
Number of
re inspect ions
35,653
9,715
46,354
181,450
84,182
10,657
24,931
392,942
Total annual
inspections
154,495
42,097
200,866
786,284
364,788
46,179
108,033
1,702,742
Inspection Facility Capacity
The annual capacity of a contractor operated emission inspection lane can
be calculated given the vehicle throughput time, an efficiency factor to
account for random arrival of vehicles, equipment downtime, etc., and the number
of hours that the facility will be operated annually. The throughput time for
loaded mode emissions testing is 2 minutes (see Section 2, Selection of Test
Mode); and based on pther I/M programs, facilities of this type operate at
approximately 67 percent efficiency. If it is assumed that the facilities will
be open 40 hours per week, 52 weeks per year, the annual capacity of each
inspection lane can be calculated as:
Capacity = (l i"sPection\/60 min\/40 hours\/52 weeks W0<67\ = og inspections
\2 minutes /\ hour /\ week /\ year /\ / year
Derivation of the Network Requirements
The procedure for deriving the number of inspection lanes required in each
county is to merely divide the total number of annual inspections required by
the lane capacity; the number of inspections for 1987 is presented in Table 14
66
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and it was stated previously that the annual capacity for each lane is
41,808 vehicles per year. Table 15 below, presents the results of these
computations.
TABLE 15. INSPECTION LANE REQUIREMENTS BY COUNTY
County
An oka
Carver
Dakota
Hennepin
Ramsey
Scott
Washington
Total
Total annual inspections
during 1987
154,495
42,097
200,866
786,284
364,788
46,179
108,033
1,702,742
Number of inspection
lanes required
4
2*
5
19
9
2
3
44
*
From a practical standpoint, one lane could accommodate
this demand, however, two will be used since the desire is
to be somewhat liberal in deriving the network requirements
and associated costs.
Not only must the number of individual lanes be calculated, but also the
number and tentative locations of the inspection stations must be determined
as well. These basic criteria are used in deriving the number and location of
inspection facilities; viz:
• owing to difficulties often experienced in locating and
purchasing larger land parcels, the maximum facility
size is assumed to be six lanes;
• owing to diseconomies associated with small facilities,
the minimum number of lanes for any facility is assumed
to be two; and
• the basic intent is to locate facilities in or near the
population centers to minimize travel distances and
associated inconveniences.
Based generally on the above-mentioned guidelines, the inspection network
presented in Table 16 was developed.
67
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PERSONNEL REQUIREMENTS
The personnel requirements for an I/M can be defined in terms of operating
personnel - those persons directly involved in or supporting the actual in-
spection process - and administrative personnel - those persons involved in the
management of the program as well as those involved in support programs such as
quality assurance, consumer protection, enforcement, etc. The requirements for
both types of personnel are discussed separately in the following paragraphs.
Operating Personnel
The basic operating personnel requirements were derived based on both an
analysis of the tasks involved in conducting the actual inspections (from
time-motion studies by AVCO and Hamilton Test Systems), and from the experi-
ences of I/M programs currently in operation. The general operating personnel
structure to be utilized by the State of Minnesota for the program being
assessed here is summarized as:
• One manager and one assistant manager per facility;
• Three inspectors per test lane; and
• One maintenance/calibration person for every 10 lanes.
Applying these personnel requirements to the inspection network developed
in Table 16, results in the operating personnel requirements shown in Table 17.
Administrative Personnel
The following provides a description of the proposed administrative struc-
ture here. This structure, consisting of both State and contractor personnel,
is based on an analysis of the specific tasks and responsibilities involved in
implementing and operating an I/M program. While most of the personnel described
here would be employed directly by the State or contractor, it is not likely
that all positions would require new personnel; rather, it is quite likely that
existing State personnel could assume some of the responsibilities.
State Personnel—
The basic organizational structure, shown in Figure 3, is organized
under the Minnesota Pollution Control Agency (MPCA), which would hold ultimate
responsibility for the program. Reporting to the MPCA would be the
Administrator who would be responsible for operating the program in accordance
with regulations established by the MPCA staff. MPCA staff would provide in-
put to the administrator regarding policy decisions and would monitor the
effectiveness of the program.
The administrator would be supported by Legal Counsel, as necessary.
The function of Legal Counsel would be to advise the Administrator and MPCA
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.
68
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TABLE 16. INSPECTION NETWORK REQUIREMENTS
County
Anoka
Carver
Dakota
Hennepin
Ramsey
Scott
Washington
Facility configuration
(number of lanes)
4
2
5
4
6
3
6
6
3
2
3
Suggested
location
Coon Rapids
Chaska
West St. Paul
Minne tonka
Minneapolis
Brooklyn Park
Bloomington
St. Paul
Roseville
Shakopee
Stillwater
Total
44 lanes
11 facilities
69
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71
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An Engineer, 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 the MPCA with periodic summaries concerning pro-
gram operation (e.g., percent failures, second failures, emission character-
istics 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 two Investigators, one for quality
assurance, one for consumer protection, and a Hotline Operator.
Contractor Personnel—
The contractor personnel would be headed by an Operations Administrator
who would be responsible for management of the operational aspects of the pro-
gram and for planning of future program operations.
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.
Also subordinate to the Operations Administrator would be a Financial
Coordinator and Legal Counsel having duties similar to their respective State
counterparts.
The Inspector Training Coordinator would be responsible for the formula-
tion and establishment of a comprehensive training program for all inspection
station personnel employed by the contractor.
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.
72
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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 the maintenance/
calibration persons (described previously under operating personnel), and
would hold ultimate responsibility for the repair and overall condition of
all contractor equipment.
Administrative requirements for both State and Contractor personnel are
summarized in Table 18. This table indicates the number of positions and
the appropriate level of activity required during both the startup and opera-
tion phases of the I/M program. It should be noted that this is a suggested
structure, and should be viewed as such.
73
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TABLE 18. ADMINISTRATIVE PERSONNEL REQUIREMENTS
Position
State Personnel
Administrator
Legal Counsel
Clerical support
Mechanics' Training Coordinator
Financial Coordinator
Engineer
Information Systems Analyst
Consumer Protection/Quality
Assurance Supervisor
Data Analyst
Consumer Protection Investigator
Quality Assurance Investigator
Hot-Line Operator
Requirement during
startup phase
1 full-time
1 quarter-time
2 full-time
1 full-time
1 half-time
1 half-time
1 half-time
1 half-time
1 quarter -time
1 as necessary
1 as necessary
-
Requirement during
operational phase
1 full-time
1 as necessary
2 full-time
1 half-time
1 full-time
-
-
1 full-time
1 full-time
1 full-time
1 full-time
1 full-time
Contractor Personnel
Operations Administrator
Assistant Operations Administrator
Legal Counsel
Clerical Support
Financial Coordinator
Inspector Training Coordinator
Personnel Administrator
Data Analyst
Maintenance/Calibration Coordinator
1 full-time
1 full-time
1 as necessary
2 full-time
1 full-time
1 half-time
1 quarter-time
1 half-time
1 full-time
1 full-time
1 as necessary
2 full-time
1 full-time
1 quarter-time
1 full-time
1 full-time
1 full-time
74
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SECTION 5
COST ANALYSIS
METHODOLOGY
In developing the cost analysis presented in this section, program ele-
ments were separated into specific cost categories. A thorough analysis of
the program functions and elements was undertaken to assure that the costs
presented reflect, as closely as possible, the actual costs that will be ex-
perienced when Minnesota implements the proposed program. However, it must
be realized that while conservative assumptions were made whenever possible,
considerable variation in the individual cost elements due to fluctuations in
markets and the economy are inevitable.
All costs reported in this section, except where otherwise indicated,
are in constant 1978 dollars (i.e., effects of inflation are assumed non-
existent). A separate break-even fee reflecting a 7 percent average annual
inflation rate, however, was also derived. Analyses were performed to iden-
tify the individual costs associated for the several individual categories
indicated in Table 19. The methodologies used in deriving these costs are
discussed in the following paragraphs.
Initial Capital Costs
These costs reflect the initial expenditures required for tangible items
such as: purchasing and improving land, constructing the test facilities, and
purchasing and installing test equipment, ancillary equipment, office equipment,
and maintenance equipment. These items are categorized into three primary
elements: building investments, land investments, and equipment costs.
Building Investments—
Building costs are dependent on specific designs and features utilized;
therefore, unit costs (on a dollar per square foot basis) can be expected to
vary somewhat. For the centralized facilities being considered here, a gen-
eral design description was developed based on an analysis of the likely inspec-
tion tasks, equipment requirements, and the experiences of states currently oper-
ating similar facilities. The general building design, which reflects an attempt
to minimize costs, calls for a clear span, metal structure, utilizing metal
sandwich panel walls with normal wall and ceiling finish in administrative
areas, and no wall or ceiling finish in the inspection areas. Items such as
central heating and air-conditioning in the administrative areas and air
exchange and forced hot air heaters in the inspection area are included. No
provisions were made here for more specialized systems such as exhaust fume
75
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TABLE 19. OUTLINE OF PROGRAM COST CATEGORIES AND ELEMENTS
- * — ~ ~ "' • .•--"_ - - ...-_- L- ..
Primary category Principal element
1. Initial Capital Costs 1. Building Investment a.
2. Land Investment a.
b.
3. Equipment costs a.
b.
c .
d.
IT. Orte-Time Start-Up Costs 1. Land acquisition a.
b.
2. Facilities planning a.
b.
c .
3. Program design a.
b.
c .
d.
e.
~ — - — — ^
I terns luc luded
Construction cost
Actual land cost
Pavement and Landscaping
Primary test equi pment
Ancillary equ Lpment
Office equipment /furniture
Ma in t en anc e e qu i pmen t
Site location studies
Title transfer costs
Design sfndy
Bid evaluation
Construction rionitoring
Devlop equipment specifications
Develop subprograms (e.g. , public
information, »urveil lance, quality
control , enforcement , etc . )
Define personnel organ! za tonal
structure
Define data handling nerds
Plan program effectiveness
studies
III. Annuii) operating Costs
4. Develop data handling systems
software
5. Personnel training
6. Personnel salaries and overhead
prior to start-up
7. Initial public Information program
1. Facllity personnel
2. Maintenance
3. Utilltles/services/supplles
IV. A mi 11 Ji 1 Mm In J HI rnt Ivc Costs 1 . Program administrative personnel
2. F.nforcement
3. Consumer protect ion/quality
assurance
4. Public information
5. Training, 1icensing, certification
a. Inspectors
b. Managers
c. Quality control personnel
d. Mechanics traJ-nlnj",
a. Wages, benefits, eLc.
a. Equipment
a. Electric
b. Heat
c. Insuram e
d. Miscellaneous
e. Taxes
a. Wages, overhead
76
-------
collectors; these are included in equipment costs under the general category
of facility furnishings. The above description was submitted to several
metal buildings manufacturers for their assessment of the likely costs. Based
on the general design features and on general size requirements, a range of
costs from $25.00 to $30.00 per square foot was derived. In order to reflect
the most conservative case, the upper limit, $30.00 per square foot, was used
in the cost computations presented here.
The Minnesota Pollution Control Association has indicated that the emis-
sion inspection may eventually be expanded to include safety and noise in-
spections as well. The facilities, therefore, are designed to accommodate
the additional space requirements that would be imposed without additional
construction. An analysis of the specific inspection tasks and equipment to
be used was made to determine actual size and general feature requirements.
Literature searches and interviews with persons involved in similar programs
were conducted. A conceptual floor plan for the basic type of facility re-
quired for emission, safety, and noise testing resulted; this is presented
in Figure 4. Initially, the facilities will be used primarily for emission
inspections; Figure 4, however, includes equipment that would probably be
included when the (expanded) program (i.e., safety and noise testing) is fully
operational. The floor plan shows a single-lane facility; building area re-
quirements for facilities ranging in size from one to six lanes are presented
in Table 20.
The construction cost for each facility is computed as the product of
(1) the building area, and (2) the unit cost, $30/square foot. The total
cost for the network is the sum of costs of the individual facilities shown
in Table 21. The total cost for the construction of all facilities is
$6,120,450, and is presented, by county, in Table 22.
Land Investments—
A number of issues beyond the obvious one of land area are crucial in
deriving an estimate for land costs. The unit cost of land, for example, is
lot-specific to the extent that the per square foot cost may easily vary by a
factor of 3 or more within any block, and by a factor of 10 or more within any
municipality. Available lots may also be limited with respect to size require-
ments, necessitating the purchase of lots exceeding the general requirements,
or even the purchase of unwanted structures. It is obvious, then, that a
precise unit cost for land cannot be provided here. Alternatively, estimates
were developed by various local assessors' offices, based on the general
requirements in terms of zoning, access, lot-size, etc. for each municipality.
These estimates, shown in Table 23, reflect mid-1978 average market values of
available unimproved, commercially zoned land located generally within a
major arterial corridor. Again, it must be noted that these estimates repre-
sent the average of a fairly wide range in actual unit costs.
Lot size requirements are a function of facility configurations. Speci-
fically, a relationship of a 5:1 ratio of lot size to building size was de-
veloped based on queuing and likely zoning requirements. Since building area
requirements have been derived previously in Table 20, land areas may be
easily calculated.
77
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TABLE 21. INSPECTION NETWORK REQUIREMENTS
County
Anoka
Carver
Dakota
Hennepin
Ramsey
Scott
Washington
... . . , . Number of
Municipality . . ,. .
facilities
Coon Rapids
Chaska
West St. Paul
Minnetonka
Minneapolis
Brooklyn Park
Bloomington
St. Paul
Roseville
Shakopee
Stillwater
1
1
1
1
1
1
1
1
1
1
1
Configuration
(lanes)
4
2
5
4
6
3
6
6
3
2
3
Total
11
44
80
-------
TABLE 22. BUILDING COST ESTIMATES
Facility
County ...
configuration
Anoka
Carver
Dakota
Hennepin
Ramsey
Scott
Washington
Total
4-lane
2-lane
5-lane
6-lane
4-lane
3 -lane
6-lane
3 -lane
2-lane
3-lane
_ ,. . , . Number of „, ,
Per facility ,. . ,. . Total cost
,£. J facilities ,,,,
cost, (?) . (?)
required
545,850
290,250
688,050
839,850
545,850
413,550
839,850
413,550
290,250
413,550
1
1
1
2
1
1
1
1
1
1
545,850
290,250
688,050
1,679,700
545,850
413,550
839,850
413,550
290,250
413,550
6,120,450
81
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Land improvements are included in this cost category. The primary improve-
ments involve landscaping and paving. Estimates obtained from various land-
scape architectural firms indicate that the unit costs for black-top paving
and standard finish landscape are approximately $0.80 per square foot and
$0.25 per square foot, respectively. Total land investments for the inspect-
ions network derived previously, including improvements, are presented in
Table 24.
Equipment Costs—
The major equipment items required to operate a loaded-mode emissions
inspection facility were identified based on an analysis of the inspection
task requirements, and conversations with individuals currently involved in
these types of inspection programs. It is assumed that equipment required to
perform the safety aspect of the program will not be purchased until the ex-
pansion to include these inspections occurs. This will ensure that the most
recent state-of-the-art equipment be purchased.
The equipment cost estimates used in this study were based primarily on
interviews with manufacturers' representatives. These interviews focused on
identifying the most appropriate type and model for various major items and
determining the general level of skill required to operate each. The item of
most interest is the emission analyzer itself. There is an extremely wide
range of such equipment on the market today. At one end of the spectrum are
"garage level" analyzers, generally costing about $3,000 or less; at the other
extreme are laboratory grade analyzers, costing in excess of $75,000, that are
much more sophisticated than is necessary for application here. The emission
analyzers that are suited for centralized lanes have the following general
features: (1) to decrease purge-time to a level acceptable for a high volume
application, the analyzer has refrigerated bath and filtration capabilities
not available in a garage analyzer; (2) to eliminate CC>2 and H20 interference,
the centralized lane analyzer has dual detector capabilities; (3) to allow com-
puter tie-in, the analyzer is capable of linearized output; (4) to correct for
high and variable ambient concentrations of HC and CO, "flowing reference cells"
are included.
Specifications of a typical analyzer for centralized facilities use are
presented in Table 25. These specifications are provided for use as a guide-
line in selecting analyzers and are not intended co be used as "minimum"
standards. This information was obtained from Horiba Instruments, Incorporated,
Irvine, California.
Outlined in Table 26 are the equipment requirements and associated costs
for a loaded-mode emission inspection program.
Equipment costs for any facility configuration, then, can be derived
from Table 26. A summary of equipment costs as a function of facility con-
figuration is shown in Table 27.
83
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84
-------
TABLE 25. GENERAL SPECIFICATIONS OF A TYPICAL I/M CENTRALIZED
FACILITY EMISSION ANALYZER
Item
Specifications/Comments
Measuring Method;
Sensitivity:
Repeatability:
Zero Drift:*
Span Drift:*
Response Time (electrical):
t
Ambient Operating Conditions:
Warm-Up Time;
Power Requirements:
Meter Readout Accuracy:
Sample Gas Flow Rate:
Sample Gas Inlet Pressure:
InterferenceFrom Co-existing Gases;
Minimurn/Maximum Measuring Range:?
CO (carbon monoxide)
CHi^ (methane)
C^Hg (propane)
CgHll+ (n-hexane)
NDIR, optical filter, dual source gas-
filled capacitive type detector.
0.5% of full-scale analysis range
±0.5% of full-scale with successive
identical gas samples under the same
physical conditions
less than 1% of full-scale/24 hrs
less than 1% of full-scale/24 hrs
0.5 to 15.5 seconds to 90% of full-
scale in 120 switch selected increments
temperatures between 0 C to 40 C
humidity - less than 95% RH
30 minutes to full accuracy
115 VAC (±10%) 60 Hz ±0.5 Hz
5% of full scale
0.5 to 10 liters per minute
28.5 psig
less than 1% of full scale
Minimum Maximum
50 ppm
100 ppm
100 ppm
100 ppm
100%
100%
100%
5%
* Drift performance specifications are based on ambient temperature variation
of less than 10°C over a 24-hour interval.
Total analyzer response time is dependent on sample gas flow rate, sample
cell length and electrical response time.
I Minimum Recommended Measuring Range is the full-scale concentration which
may be measured with a 500 mm sample cell, response time of 0.5 seconds
full-scale and a noise level of less than 0.5% of full-scale.
85
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86
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TABLE 27. EQUIPMENT COSTS AS A
FUNCTION OF FACILITY
CONFIGURATION
Number of
lanes
1
2
3
4
5
6
Equipment costs ($)
126,500
173,000
219,500
266,000
312,500
359,000
The total network cost for inspection equipment can be computed based on
the number of facilities, by configuration, developed previously. These costs
are presented in Table 28.
In addition to test equipment costs, three additional items must be in-
cluded in the total network equipment costs: calibration vans and equipment,
security systems, investigators' vans, and a central network computer.
One calibration van is required for each maintenance/calibration person.
The personnel requirement for this position was previously derived in
Section 4. It was determined that five maintenance/calibration persons would
be required. Each van is equipped with a spare analyzer enabling a quick re-
placement of an analyzer which is found to be in need of repairs that cannot
be performed at the inspection site. The cost summary is presented below:
1/2 ton light-duty van $ 5,500
Emission analyzer 26,500
Tools, gases, etc. 1,000
Total cost per van $33,000
Tn addition, the quality assurance investigation would have a van iden-
tical to the calibration vans discussed above, costing $33,000. The con-
sumer complaints investigator would have a car, estimated to cost $5,000.
The entire network would be tied into a central computer equivalent in
capability to a Digital PDP-11-35. Cost estimates were obtained from several
manufacturer's representatives, including Digital, Olivetti, Honeywell, and
Sperry Univac, and an average cost of approximately $250,000 was derived.
Each facility should be equipped with security systems to protect against
theft and/or vandalism. A contractor has suggested a cost of $1,100 per
87
-------
facility for purchase and installation of security systems. This translates
to a total cost of $12,100 for the entire network. The total equipment cost
estimate, itemized in Table 28, is $3,391,100.
The capital costs anticipated for the entire program are summarized in
Table 29.
One-Time Startup Costs
Implementation of an I/M program will require the expenditure of monies
for noncapital services on a one-time basis prior to the actual commencement of
inspections. Costs associated with this category are difficult to define at
this point primarily because the elements involve services (planning, design,
development, etc.), that are inherently more variable in cost than, for
instance, equipment or building. Considerations used in developing cost es-
timates for each element are presented within the discussion of the individual
estimates as follows.
Land Acquisition—
Costs for land acquisition include expenditures for identifying and lo-
cating candidate sites, negotiating purchase price, and completing title
transfers. It is estimated that 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 translates to a total cost
of $6,000 per site to cover location and price negotiation. Title transfers
involve physical surveys, title searches, preparation of site plans, etc.
The cost of these elements is estimated to be approximately 10 percent of the
unimproved land value.
For the network being considered here, a total of 11 sites are required,
representing a total unimproved land investment of $2,296,584. The cost for
land acquisition, then, is calculated as follows:
(11 sites)($6,000 per site) + (0.10)($2,296,584) = $295,658
Facilities Planning—
This element reflects the costs associated with engineering and design
of the inspection facilities, bid review, and construction monitoring. The
cost of these services is estimated to be a function of the total building
cost. The total building cost for the alternative being evaluated here is
estimated at $6,120,450. For building costs of this magnitude, facilities
planning costs are estimated to be 10 percent of the total construction cost,
or $612,045.
Program Design—
This element reflects additional planning studies required to establish
specific formats for the operation and administration of the inspection pro-
gram as well as adjunctive programs such as public information, mechanics
training, consumer protection, quality assurance, etc. A certain amount of
88
-------
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TABLE 29. CAPITAL COST SUMMARY
Category
Building Investment
Subtotal
Land Investment
Subtotal
Equipment Investments
Subtotal
Total
Item
Construction
Purchase
Paving
Landscaping
Inspection equipment
Central computer
Calibration vans
Security systems
Investigators' vehicles
Item cost
($)
6,120,450
2,296,584
233,024
131,195
2,926,000
250,000
165,000
12,100
38,000
Category cost
($)
6,120,450
2,660,803
3,391,100
12,172,353
90
-------
variability is inherent here as at this time certain factors such as the ex-
tent of "in-house" effort that will be undertaken by Minnesota is unknown.
In light of this, the estimate derivation focused primarily on the experi-
ences of other states. Based on these experiences and an analysis of the
likely requirements specific to Minnesota, an estimate of $100,000 was derived
for program design.
Data Handling Software Development—
A comprehensive data handling software development package will be re-
quired to provide both basic recordkeeping and program analysis functions.
In developing a cost estimate for this item, experiences of other states,
conversations with representatives of data processing firms, and an analysis
by our own staff were taken into consideration. Based on these discussions,
experiences, and our analysis of the likely requirements specific to Minnesota,
an estimate of $200,000 was developed for this element.
Personnel Training—
An intensive startup program as well as an ongoing effort will be required
to train and certify the entire staff of inspectors, managerial, and maintenance/
calibration personnel. A similar effort will be required to provide a mechanics
training program to adequately prepare the repair industry for the maintenance
phase of the program. This will be discussed separately.
One logical approach to accomplish this task would be to have managers
and assistant managers trained as instructors, allowing for a continuation of
the training program without the requirement of a full-time instructor.
Managers would then be able to train new employees themselves as well as pro-
viding the initial training for the inspectors and calibration/maintenance
personnel.
Cost estimates for training were developed based on information obtained
from the Colorado State University Program. Derivation of the per person cost
of training is shown in Table 30.
The operating personnel requirements were previously found to be:
• 11 facility managers
• 11 assistant managers
• 132 inspectors
• 5 maintenance/calibration persons.
Using these personnel requirements and the training costs from Table 5-12,
the cost of training operating personnel can be computed as follows:
(11 managers)($74) + (11 assistant managers)($74)
+ (132 inspectors)($16) + (5 maintenance/calibration persons)($16) = $3,820.00
91
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Personnel Salaries and Overhead—
The wage rates for operating and administrative personnel were derived
from: "State of Minnesota Compensation Schedules," Minnesota Department of
Personnel, July 5, 1978.
Salaries were matched with position class titles most closely fitting
job descriptions of the positions previously defined. From the: above source,
wage scales (rounded to the nearest $500/year) were found to be:
• Managers, $16,000 per year or $1,333 per month
• Assistant Manager, $14,000 per year or $1,167 per month
• Maintenance/calibration persons, $13,000 per year or
$1,083 per month
• Inspectors, $12,000 per year or $1,000 per month.
Based on U.S. Department of Labor and State data and on experiences of a
contractor currently involved in a similar program in another state, a 25 per-
cent overhead figure was added to the basic salaries.
Based on the experiences of other states' implementation of similar pro-
grams, the following schedule was derived:
• All managerial personnel will start 6 months prior to
facilities opening;
• Inspectors will be phased-in 1 month prior to startup;
• Maintenance/calibration personnel will be phased-in
1 month prior to startup.
With these assumptions, the total startup cost for facility personnel
can be computed:
(11 managers)($l,333/month)(6 months)
+ (11 assistant managers)($1,167/month)(1 month)
+ (5 maintenance/calibration persons)($1,083/month)(1 month)
+ (132 inspectors)($l,000/month)(l month)] 1.25 overhead = $297,788
The administrative personnel costs must also be included in the startup
costs. The administrative personnel requirements for the startup phase are
presented in Section 4. Based on these requirements and salaries from the
Minnesota Department of Personnel, the costs associated with this item were
calculated. This computation is shown in Table 31.
The total personnel cost for the startup phase, then, is the total of
the operational (facility) personnel and the administrative personnel costs,
or:
$297,788 + 253,125 = 550,913
94
-------
TABLE 31. ADMINISTRATIVE SALARIES AND OVERHEAD ASSOCIATED WITH
PROGRAM STARTUP
S«l«ry
Job title
State Personnel
Administrator
Legal Counsel
Clerical Support (2)
Mechanics Training Coordinator
Financial Coordinator
Engineer
Information Systems Analyst
Consumer Protection/Quality
Assurance Supervisor
Data Analyst
Consumer Protection Investigator
Quality Assurance Investigator
Total State Personnel Salaries
Over head @ 25X
Total State cost
Contractor Personnel
Operations Administrator
Assistant Operations Administrator
Legal Counsel
Clerical Support (2)
Financial Coordinator
Inspector Training Coordinator
Data Analyst
Maintenance/Calibration
Coordinator
Total Contractor Personnel
Salaries
Overhead (? 25t
Total Contractor Cost
Total Cost
Annual
(S)
25,000
15,500
9,000
15,000
15,500
15,000
15,500
15,500
14,000
12,500
12,500
25,000
18,750
15,500
9,000
15,500
15,000
14,000
16,000
Monthly
($)
2,083
1,292
750
1,250
1,292
1,250
1,292
1,292
1,167
1,042
1,042
2,083
1,563
1,292
750
1,292
1,250
1,167
1,333
Participation
during startup
(months)
12
3
12 (each)
12
6
6
6
6
3
3
3
12
12
3
12 (each)
12
6
3
6
Total salary
during startup
all positions
($)
25,000
3,875
18,000
15,000
7,750
7,500
7,750
7,750
3,500
3,125
3,125
302,375
25,594
127,969
25,000
18,750
3,875
18,000
15,500
7,500
J.500
8,000
100,125
25,031
125,156
253,125
95
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Public Information Program—
An intensive public information program will be required prior to program
startup to assure public understanding and acceptance of the I/M concept. Ex-
perience thus far indicate that this effort should begin approximately 6 to 12
months prior to the commencement of operation. A preimplementation budget of
$0.12 per vehicle to be inspected the first year has been suggested by a con-
tractor from another state. From Section 4, it was found that approximately
1,179,000 vehicles will be required to pass inspection in 1982,, This translates
to $141,480 for the preimplementation public information program.
Mechanics Training Program—
A comprehensive mechanics training effort, similar to the previously dis-
cussed inspector training program, will be required to assure complete under-
standing of the repair industry regarding their responsibilities in connection
with the maintenance aspects of the proposed I/M program. From the data
presented in Table 30, a cost for training an individual mechanic was esti-
mated to be $22.
The Minnesota Automotive Council estimates that there are approximately
1,900 repair facilities in the seven-county Minneapolis/St. Paul area. For
the purposes of this cost estimate, it is assumed that 75 percent of these
stations will send one mechanic to the training program. This translates to
1,425 mechanics at a cost of $31,350 during the startup phase of the program.
A summary of anticipated startup costs is presented in Table 32.
TABLE 32. SUMMARY OF INITIAL STARTUP COSTS
Item Cost ($)
Land Acquisition 295,658
Facilities Planning 612,045
Program Design 100,000
Data Handling Software Development 200,000
Personnel Training 3,820
Personnel Salaries and Overhead 550,913
Public Information 141,480
Mechanics Training 31,350
Total 1,935,266
Annual Operating Costs
Annual operating costs include all costs associated with the actual oper-
ation of the program. For the purposes of this cost analysis, the costs of
adjunctive programs such as public information, inspector and mechanics training,
etc., are included under "Annual Administrative Costs," which are discussed later.
96
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Facility Personnel—
Annual costs associated with this category are a function of (1) the total
number of individuals and relative levels of job responsibility, and (2) the
per unit cost of wages and overhead.
The operating personnel requirements and wage scale were previously de-
fined. The unit costs of salaries for each classification were derived from
information supplied by the Minnesota Department of Personnel; and overhead
estimates were based on U.S. Department of Labor and State data and from ex-
periences of states operating similar programs. The overhead rate was found
to be 25 percent of the basic hourly wage-rate.
Applying the facility staffing requirements to the appropriate wage and
overhead rates associated with job classification, the annual personnel cost
can be computed. This estimate is shown in Table 33.
TABLE 33. ANNUAL PERSONNEL COSTS FOR FACILITY PERSONNEL
Job title
Manager
Assistant Manager
Maintenance /Calibration
Inspectors
Total salaries
Overhead @ 25 percent
Total number
of positions
11
11
5
132
Annual
salary
($)
16,000
14,000
13,000
12,000
Total annual salary
for all positions
($)
176,000
154,000
65,000
1,584,000
1,979,000
494,750
2,473,750
Maintenance—
Costs associated with equipment maintenance reflect equipment repair and
preventive maintenance expenditures. This item is best reflected as a function
of the total equipment cost. Specifically, this cost is estimated at 20 per-
cent of the original inspection equipment cost. Maintenance costs, then, can
be computed as follows:
($2,926,000)(0.20) = $585,200
Utilities/Services/Supplies—
Included in this element are costs associated with electricity, insurance,
inspection facility supplies, uniforms, calibration van operation, etc.
Utilities—Electric usage requirements were based on the experiences of
other programs, and on discussions with equipment manufacturers' representatives,
97
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For emission testing, in the absence of safety, usage rates were found to be
120 kWh/day for each lane, and 325 kWh/day for each facility. A per
kilowatt-hour cost of electricity of $0.03 was obtained from Northern States
Power. The annual cost, then, is calculated as follows:
(44 lanes)(120 kWh/day-lane)($0.03/kWh)(250 operating days/year)
+ (11 facilities)(325 kWh/day-lane)($0.03/kWh)(250 operating days/year)
= $66,413 annually.
Insurance—The facilities and associated equipment would most likely be
covered by fire, theft, vandalism, and liability insurance. A contractor
operating a similar program in another state has suggested an annual insurance
cost of $1,500 per lane. This translates to $66,000 annually for insuring
44 lanes.
Computer Operation—Based on discussions with a contractor from another
state, and with representatives from several data processing firms, an esti-
mated central computer operating cost of $0.15 per test to be performed was
derived. From Section 4 it was found that the average number of inspections
to be performed annually will be 1,617,000 for 1982-1987. This translates to
an annual cost of $242,550 for computer operation.
Inspection Forms—Inspection forms serve the purpose of reporting test
results, providing diagnostic information (should repairs be necessary), and
serving as the "certificate of compliance" for registration purposes. A cost
of $0.03 per test has been suggested by a contractor from another State.
This computes to a total cost of $48,510 annually for inspection forms.
Calibration Costs—The recurring annual cost of equipment calibration,
in addition to the personnel salaries previously presented, is defined here
as the cost of calibration gases plus the operating cost of the maintenance/
calibration vans. The total annual calibration costs, outlined in Table 34,
were found to total $53,700.
TABLE 34. ANNUAL CALIBRATION COSTS
Item Cost ($)
Calibration gases (20 sets/year @ $200/set) 4,000
Maintenance on equipment 5,300
Vehicle operations cost ($0.12/mile @ 12,000 miles/yr) 1,440
Cost per van 10,740
x vans required 5
Total 53,700
98
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Taxes—The contractor would be required to pay real estate and personal
property taxes on real property. Tax rates were obtained from the Minnesota
Department of Revenue. Annual taxes are calculated in Table 35.
Uniforms—Each facility employee is assumed to be furnished with a set
of uniforms. From discussions with uniform suppliers, an annual cost per
employee of $125.00 was derived. This translates to a total annual cost of
$19,875 for a total of 159 uniformed employees.
The total annual costs for utilities/services/supplies are summarized in
Table 36.
TABLE 36. ANNUAL COSTS FOR UTILITIES,
SERVICES, AND SUPPLIES
Annual cost
Item ($)
Utilities 66,413
Insurance 66,000
Computer Operation 242,550
Inspection Forms 48,510
Calibration Costs 53,700
Taxes 599,219
Uniforms 19,875
Total 1,096,267
Annual Administrative Costs
Costs in this category reflect the overall program administration effort.
These costs include salaries and overhead of personnel involved in areas such
as program administration, consumer protection, quality assurance, public in-
formation, etc. Also, the costs associated with operation of investigators
vehicles are included in this category.
Program Administrative Salaries and Overhead—
Costs in this category are computed from the personnel requirements,
salaries, overhead rate, and level of participation, which were delineated
previously. The annual cost computation is shown in Table 37.
Vehicle Operating Costs—
The quality assurance investigator and the consumer protection inves-
tigator will each require a vehicle and equipment. Assuming an operating
cost of $0.15 per mile and annual travel of 12,000 miles, the yearly operat-
ing cost for the two vans may be calculated;
99
-------
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TABLE 37. ANNUAL ADMINISTRATIVE PERSONNEL COSTS
Position
Scacr Personnel
Admin is trator
Legal Counsel
Clerical Support (2)
Mechanics Training Coordinator
Kinanciol Coordinator
Consumer Protect ion /Qua li cy
Assurance Supervisor
Data Analyst
Consumer Protection Investigator
Quality Assurance Investigator
Hot-Line Operator
Total State Personnel Salaries
Overhead C 25%
Total State Coat
Contractor Personnel
Operations Administrator
Assistant Operations Adeministrator
Legal Counsel
Clerical Support (2)
Financial Coordinator
Inspector Training Coordinator
Personnel Administrator
Data Analyst
Maintenance/Calibration
Coord i nacor
Total Contractor Personnel
Salaries
Overhead P 25%
Total Contractor Coat
Total Coet
Salary
Annual
($)
25,000
15,500
9,000
15,000
15,500
15,500
14,000
12,500
12,500
9,000
25,000
18,750
15,500
9,000
15,500
15,000
15,000
14,000
16,000
Monthly
(?)
2,083
1,292
750
1,250
1,292
1,292
1,167
1,042
1,042
750
2,083
1,563
1,292
750
1,292
1,250
1,250
1,167
1,333
Participation
annually
(months)
12
3
12 (each)
6
12
12
12
12
12
12
12
12
3
12 (each)
12
3
12
12
12
Total salary
lor partial pat ion
.'irmu.-il 1 y
($)
25,000
1,875
18,000
7 , 500
15,500
1 ri, 500
14,000
12,500
12,500
9,000
333,375
33,344
166,719
25,000
18,750
3,875
18,000
15,500
3,750
15,000
14,000
16,000
129,875
32,469
162,344
329,063
101
-------
(2 vehicles)(12,000 miles/vehicle)($0.15 per mile) = $3,600
Public Information—
Although the actual annual expenditure for public information can only be
determined by State officials on a yearly basis, experiences thus far with I/M
indicate that a strong, continuous effort is required. A contractor from
another state has suggested $0.12 per test as a reasonable estimate of the
anticipated expenditure. Between 1982 and 1987, an average of 1,617,000 inspec-
tions will be performed annually. This translates to $194,040 as the annual
cost of public information.
Personnel Training—
This element reflects the ongoing requirement to train new operating
personnel. The replacement rate, percent of work-force "turned-over" annually,
is estimated to be 10 percent annually, based on experiences of other states.
This translates to 16 new employees per year or $256 annually.
Summary
The total cost for the entire program is itemized in Table 38.
FEE COMPUTATION
Annualized Costs
In order to derive a "break-even fee," all costs found in Table 38 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 program
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
Therefore, an investment of $1 will yield annual benefits of:
i for each of n years. Therefore, the amortized costs in
NPV l-
constant dollars, is represented by - The amortization factor for equip
ment, then, is: - : - — or 0.2374.
l-U+0.06) 5
102
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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
i-U+o.oer20
= 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
\NPV
k=l
for each dollar of initial investment. This assumption enables the use of the
above amortization factor, Trr--, 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 expenditrues 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:
°-°6 = 0.2374
l-U+0.06)-5
Annual Operating and Administrative Costs—
These costs are presented as annual figures. To obtain total annual cost
in constant 1978 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 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 38.
104
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Interest Rate and Constant Dollars —
All of the preceding calculations are performed in constant 1978 dollars.
To get figures in actual dollars for years other than 1978, all annual costs,
amortized costs, and fees must be increased by the amount of inflation since
1978.
The interest rate, i, reflects the real return on capital. Actual in-
terest rates include compensation to offset the diminishing buying power of
money as a result of inflation, and thus, are inappropriate here. In this
study, we employ a conservative real rate of return on capital, 0.06. The
exact rate would depend on the source of financing (i.e., debt, equity, or
taxpayers' forgone investment).
Inflation —
The above-mentioned fee is in real (constant) dollars and must be ad-
justed for inflation. These adjustments will cover increased operating costs,
as well as the difference between the market rate of interest and the real
return on capital.
A second fee, fa, is also calculated. This fee is uniform in actual
dollars over time. In calculating this fee, an inflation rate p must be
assumed. * In this report, it is assumed that p = 0.07. For notational con-
venience, let r = market rate of interest and i = real return on capital
(r = i+p). Then, for investments (capital costs and startup costs) an assump-
tion of uniform capital services in actual dollars allows the use of the previous
formulae for TTT with r substituted for i.
Annual operating and administrative costs must be transformed from con
stant to actual dollars. Actual annual cost is equal to the product of
(l) constant annual cost and (2) a transformation factor, T; this transfor-
mation factor is determined from:
k=l
r(
1+p) [1 - (l+i/l+p)"n ]
1 \ l-(l+r)-n /
It shall be noted that the first fee, fc, was independent of p.
Capital investments no longer yield uniform services, but now yield accelerated
depreciation,
105
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Therefore, when n, the number of years, equals 5, and i, the real rate
of return on capital, = 0.06; then T, the transformation factoc, equals 1.210.
Fee Calculation, fa—
The fee, fa, reflecting actual dollars, is calculated in a manner similar
to the original fee, fc. Annualized costs are summed and divided by the annual
number of paid inspections to arrive at fa. The annualized costs are presented
in Tables 39 and 40 for constant 1978 dollars and actual (inflated) dollars,
respectively.
Fee Calculation
Utilizing the methodo'logy described above, two fees were calculated for
the entire program. The first fee, fc, reflects the annual cost in real
(constant 1978) dollars. The second fee, fa, reflects actual (inflated)
dollars. Both fees were calculated assuming one free retest is provided for
failed vehicles. Fees are shown in Table 41.
It should be emphasized here that the fees shown in Table 41 are break-
even fees and therefore do not reflect the profit that the private contractor
would make on each inspection. This profit would likely be negotiated between
the State and contractor and would range in the area of 10 to 15 percent of the
break-even fee.
Derivation of Second Reinspection Fees
Experience thus far with I/M indicates that not all vehicles entering into
the maintenance phase of I/M will pass the resultant reinspection. In fact,
those jurisdictions that currently have I/M programs are experiencing a re-
inspection failure rate of roughly 25 percent. This means that a motorist
whose vehicle fails the initial emissions inspection has one chance in four of
having to make at least one additional trip back to an inspection lane before
his vehicle finally passes the emissions test. This equates to 7.5 percent of
the entire motor vehicle population. In order to keep the costs to these
motorists as low as possible, certain measures have been proposed by the MPCA.
First, one free retest will be allowed for motorists whose vehicles fail the
initial test (has been discussed previously). The second, addressed here, is
the deviation of a separate fee for third (and subsequent) inspections.
Since 7.5 percent of the total motor vehicle population will fail the emis-
sions test a second time, a reasonable figure to account for these vehicles
plus subsequent refailures is assumed here to be 10 percent of the entire motor
vehicle population. Based on the average of projected 1982 to 1987 populations
(Section 4), this equates to approximately 124,400 additional inspections
annually. Rather than assuming additional lanes will be constructed to accom-
modate these vehicles, a more cost-effective approach would be to assume,
rather, that these vehicles will be reinspected within the proposed inspection
network; the additional capacity can be gained by extending the hours of
operation.
106
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TABLE 39. ANNUALIZED COSTS IN CONSTANT (1978) DOLLARS
I.
II.
III.
IV.
Cost category
Capital Costs
1 . Land
2. Buildings
3. Equipment
Startup Costs
Operating Costs
Administrative Costs
Total
Cost
($)
2,660,803
6,120,450
3,391,100
1,935,266
4,155,217
526,959
Amortization
factor
(i=0.06)
0.06
0.087
0.2374
0.2374
1.0
1.0
Annualized
cost
($)
159,648
532,479
805,047
459,432
4,155,217
526,959
6,638,782
TABLE 40. ANNUALIZED
COSTS IN ACTUAL (INFLATED)
DOLLARS
I.
II.
Ill
IV.
Cost category
Capital Costs
1 . Land
2. Buildings
3, Equipment
Startup Costs
Operating Costs
Administrative Costs
Total
Cost
($)
2,660,803
6,120,450
3,391,100
1,935,266
4,155,217
526,959
Amortization
factor
(1=0.06)
0.13
0.142
0.284
0.284
1.210
1.210
Annualized
cost
($)
345,904
869,104
963,072
549,616
5,027,813
637,620
8,393,129
107
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TABLE 41. BREAK-EVEN FEES, CONSTANT (1978) AND ACTUAL
(INFLATED) DOLLARS
, . . , Average number of
Annualized . , . . _
_ paid inspections Fee
Fee type costs r ,, ft.^
yv ,+) annually ($)
^} (1982-1987)
fc (constant dollars) 6,638,782 1,244,000 5.34
fa (actual dollars) 8,393,129 1,244,000 6.75
108
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Since this network will already be in place, and the capital and startup
costs already accounted for (in the first inspection fee), the additional cost
for reinspecting (and re-reinspecting, etc.) these vehicles will appear in
annual operating and annual administrative costs accountable to additional
inspection hours required. Since the additional inspections concerned here are
equal to 10 percent of the total inspections performed, it is reasonable to
expect the additional cost needed to perform these inspections will be roughly
10 percent of the annual operating and administrative costs. By dividing the
total additional cost by the number of affected vehicles, a subsequent rein-
spection breakeven fee may be obtained. These breakeven fees, in constant
(1978) and actual (inflated) dollars are presented in Table 42.
REFERENCES
1. U.S. DOT. National Highway Traffic Safety Administration. Evaluation of
Diagnostic Analysis and Test Equipment for Small Automotive Repair
Establishments. A report to Congress. July 1978.
109
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SECTION 6
IMPLEMENTATION PLANNING
INTRODUCTION
Owing to the nature of inspection and maintenance (l/M) programs, the im-
plementation planning phase is extremely crucial with regard to overall program
success. Implementation planning can be discussed in terms of coordinating
and scheduling various efforts and activities such as securing necessary legis-
lation and funds, selecting the particular operating mode (State-run or Contractor-
operated), arranging for the selection of a contractor(s) to run and/or design
the inspection facilities, etc.; in other words, coordinating all efforts aimed
at getting the program from the conceptual stage to the operational phase. With
regard to program success, a distinction can be made between success in terms of
(l) accomplishing all those tasks that result in the program being operational
by a specified deadline and designed and constructed to operate efficiently,
etc.; and (2) the public's acceptance and recognition of the program as an im-
portant mechanism for achieving a cleaner environment. The types of planning
that will enhance the success of the program in terms of the first definition
concern physical planning (e.g., construction planning) while in terms of suc-
cess from the viewpoint of public acceptance, the critical planning areas con-
sider policy planning (e.g., gradual implementation, gradually increasing strin-
gency factors, planning public information programs; in other words, planning
activity that focuses on "selling" the program to the public). Both types of
planning are considered in the following paragraphs.
In view of the relative importance of issues concerning scheduling and
phase-in, it is appropriate to provide a discussion of these issues; it is not
with the intention of deriving a detailed schedule for the implementation of
the program, rather the purpose here is to provide an indication of some of the
most critical factors in the scheduling and phase-in processes.
In this connection, three general types of issues can be considered.
First, the U.S. Environmental Protection Agency has set policy guidelines that
directly affect the schedule and phase-in requirements of the program. These
concern primarily the dates when the program has to be implemented and operat-
ing fully. Second, there exists a general sequence to the efforts that will be
undertaken in connection with implementing the program that, even though quite
logical and perhaps very obvious, will be mentioned here for completeness.
Third, there are several issues relating to either scheduling or phase-in that
are quite subtle and have a potential impact on the program. These types of
issues have been identified through discussions with individuals who have been
involved in the implementation and/or operation of I/M programs and have the
insights that are obviously gained through such experience.
Ill
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IMMEDIATE ISSUES
The most immediate issues are those that require action of some sort by
EPA, either in connection with the revised State Implementation Plan (SIP) or
as a matter concerning the I/M program specifically. In that the I/M program
is an element in the SIP, there is obviously a strong connection between SIP
requirements and the tasks that must be accomplished immediately as part of the
I/M effort. With regard to scheduling, EPA guidance defines several require-
ments concerning I/M that must be fulfilled prior to submitting the revised
SIP; these can be seen in the following excerpt from an EPA policy memorandum
dated 17 July 1978:
"The I/M Implementation Schedule
The specific items listed below must be included as a part of
the States' I/M implementation schedules with specified dates for
implementation of each item. The stringency planned for the program
and other factors affecting the potential for emission reductions
should also be indicated. Additional items if necessary because of
local factors may be required by U.S. EPA Regional Offices.
1. Initiation (or continuation) of public information
program including publicizing the I/M program in the
media, meeting and speaking with affected interest
groups, etc.
2. Preparation of a draft legislative package and sub-
mittal of legislation package to legislature if
additional legislative authority is needed.
3. Certification of adequate legal authority by
appropriate state official.
4. Initial notification of garages explaining program
and schedule of implementation.
"if
5. Development and issuance of RFPs.
•&
6. Award to contractors) .
?v
7. Initiation of construction of facilities.
"it
8. Completion of construction of facilities.
9. Adoption of procedures and guidelines for testing
and quality control including emission analyzer
requirements (and licensing requirements for private
garages, if applicable).x
*
Indicates that items may apply to some I/M programs and not to others.
112
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10. Notification of and explanation to garages of actions
in Step 9.*
11. Completion of equipment specification, and purchase and
delivery of equipment.
12. Development and adoption of outpoints.
13. Initiation of hiring and training of inspectors or
licensing of garages.*
14. Initiation of introductory program (voluntary main-
tenance with either voluntary or mandatory inspection)
if not previously initiated.
15. Initiation of mechanics training and/or information
program.
16. Initiation of mandatory inspection.
17. Initiation of mandatory repair for failed vehicles.
If certification of adequate legal authority occurs after
January 1979, the States may modify previous commitments to imple-
ment and enforce the elements of the schedule to conform to the
*j\
legal authority. These modifications will be approved by the EPA
Regional Offices and must be consistent with the Administrator's
February 24, 1978, policy memorandum. The documents should be sub-
mitted by January 1, 1979. Any necessary adjustments to the schedule
may be made at this time but must be approved by the EPA Regional
Offices."
The requirement is that an I/M implementation schedule be prepared as part
of the SIP revision, and that the schedule consider the items listed above (if
applicable). The development of this section considers the above list of
schedule elements as well as several additional elements, and these are dis-
cussed below. The discussion of each element should provide some insight as
to how the I/M schedule requirement (defined above) should be addressed. How-
ever, the basic task is:
« formulate tentative plans for the format, scope, design
operation and implementation of the items listed in the
I/M Schedule requirements; this has been accomplished.
whicli is followed by a second task involving:
Indicates that items may apply to some I/M programs and not to others.
113
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• develop an I/M implementation schedule that will address
(at least) the relevant issues defined above for sub-
mittal as part of the revised SIP; this should have been
completed prior to 31 December 1978.
A good starting point in this discussion concerns the legislative require-
ments indicated by items 2 and 3 in the implementation scheduling requirements.
At this point, the general I/M scenario that will be implemented in
Minnesota has been tentatively defined although certain issues are at this
point undecided. This report will serve as an aid in making these decisions.
As a general comment, the implementation requirements are such that a
significant planning effort should be underway even at this point in time to
ensure that the schedule requirements (discussed later) can be met.
That the State recognizes this requirement is obvious in that draft
legislation has been prepared and will be submitted to the legislature early
in 1979. This is of considerable importance, as the EPA deadline for securing
the legal authority to implement and enforce the program is 30 June 1979,
therefore, enabling legislation must be ratified during this session.
In a very similar connection, a program budget must be derived in order
to secure the funds necessary to implement and operate the program. This es-
tablishment of the required funds is also a legislative process and, therefore,
must also occur during the early 1979 State Legislative Session. This obviously
requires the preparation of a budget estimate and substantiating documentation,
probably by the MPCA. The specific task then is:
* Prepare and approve a program budget request including actual
estimates and substantiating data; this should be accomplished
in early to mid-1979.
It is unfortunate that there are no checklists that can be followed or pro-
cedures that can be recommended to guarantee rapid approval of the proposed
legislation and budget by the State Legislature. EPA guidance, however, is
rather specific with regard to the scheduling requirements for securing the
proper authority to implement I/M, as can be seen in the following excerpt
from an EPA policy memorandum dated 17 July 1978:
"Authority to Implement I/M
Normally, adequate legal authority to implement a SIP revision
must exist for a revision to be approved. Where a legislature has
had adequate opportunity to adopt enabling legislation before
January 1, 1979, the Regional Administrator should require certifica-
tion that adequate legal authority exists for I/M implementation by
January 1, 1979. However, for many states there will be insufficient
opportunity to obtain adequate legal authority before their legisla-
tures meet in early 1979. Therefore, a certification of legal author-
ity for the implementation of I/M in these states must be made no
114
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later than June 30, 1979. An extension to July 1, 1980, is possible,
but only when the state can demonstrate that (a) there was insuffi-
cient opportunity to conduct necessary technical analyses and/or (b)
the legislature has had no opportunity to consider any necessary
enabling legislation for inspection/maintenance between enactment of
the 1977 Amendments to the Act and June 30, 1979. Certification of
adequate legal authority, or other evidence that legal authority
has been adopted, must be submitted to the EPA Regional Offices to be
included in the SIP revision already submitted. Failure to submit
evidence of legal authority by the appropriate deadline will consti-
tute a failure to submit an essential element of the SIP, under
Sections 110(a)(2)(l) and 176(a) of the Act."
It is entirely likely (and logical) that during discussion regarding
the I/M legislation the question will arise as to: what will happen if we
do not approve I/M legislation by the 30 June 1979 deadline? The answer to
this is that the State would not be able to submit an essential element of
the SIP, and that Sections 110(a)(2)(l) and 176(a) of the Act would apply.
Of particular interest are the provisions of Section 176(a), which deal with
sanctions that may be placed against states for noncompliance; this Section is
excerpted below:
"Sec. 176. (a) The Administrator shall not approve any projects
or award any grants authorized by this Act and the Secretary of
Transportation shall not approve any projects or award any grants
under title 23, United States Code, other than for safety, mass
transit, or transportation improvement projects related to air
quality improvement or maintenance, in any air quality control
region —
(1) in which any national primary ambient air quality
standard has not been attained.
(2) where transportation control measures are necessary
for the attainment of such standard, and
(3) where the Administrator finds after July 1, 1979,
that the Governor has not submitted an implementation
plan which considers each of the elements required by
section 172 or that reasonable efforts toward sub-
mitting such an implementation plan are not being made
(or, after July 1, 1982, in the case of an implementa-
tion plan revision required under section 172 to be
submitted before July 1, 1982).
(b) In any area in which the State or, as the case may
be, the general purpose local government or governments or any
regional agency designated by such general purpose local govern-
ments for such purpose, is not implementing any requirement of
an approved or promulgated plan under section 110, including any
requirement for a revised implementation plan under this part,
the Administrator shall not make any grants under this Act.
(c) No department, agency, or instrumentality of the Federal
Government shall (l) engage in, (2) support in any way or provide
financial assistance for, (3) license or permit, or (4) approve,
115
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any activity which does not conform to a plan after it has been
approved or promulgated under section 110. No metropolitan
planning organization designated under section 134 of title 23,
United States Code, shall give its approval to any project pro-
gram, or plan which does not conform to a plan approved or pro-
mulgated under section 110. The assurance of conformity to such
a plan shall be an affirmative responsibility of the head of such
department, agency, or instrumentality.
(d) Each department, agency, or instrumentality of the
Federal Government having authority to conduct or support: any pro-
gram with air-quality related transportation consequences shall
give priority in the exercise of such authority, consistent with
statutory requirements for allocation among States or other juris-
dictions, to the implementation of those portions of plans
prepared under this section to achieve and maintain the national
primary ambient air quality standard. This paragraph extends to,
but is not limited to, authority exercised under the Urban Mass
Transportation Act, title 23 of the United States Code, and the
Housing and Urban Development Act."
The implications of not approving I/M legislation are quite severe, as can
be seen from Section 176(a), and therefore should be considered in legislative
discussions on the proposed legislation.
The basic task, then, is:
• approve I/M legislation and corresponding funding; this in
general should be accomplished prior to 30 June 1979.
The second element to be discussed concerns the initiation of a public
information program regarding I/M. In deciding on the particular program
details, several points should be considered. First, there are three basic
stages in the public information effort and the activity and timing of each
should be treated carefully. The first stage occurs during the period prior
to introducing the legislation to the Legislature, and extends through the
time that the legislation is approved. The intent is to inform the public
about the basic concepts of the program primarily to develop support from
those individuals whose representatives will be acting on the legislation in
the State Legislature. The effort may be directed more toward organized groups
who have both a recognized lobbying power and an inherent interest in promoting
air pollution reduction. The second phase occurs approximately 6 months to
a year prior to the startup of the program and extends through the first year
of operation. This entails a very strong, visible effort to inform the public
about the details of the I/M program, particularly concerning the benefits that
the individual motorist is likely to derive from the program. Also, the in-
tent should be to ensure that the requirements for each motorist to obtain an
inspection are defined in detail so that essentially everyone knows what to
expect with regard to how he is notified as to when and where he will be
inspected, eliminate uncertainty regarding repair liability (repair cost
ceiling), where he can take his vehicle for repairs if required, etc. The
final phase is a continued effort after the I/M program is operating smoothly.
116
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The intent would be to inform the public of the program's effectiveness in
reducing pollution. This would require a somewhat lower level of effort than
would the second stage.
The tasks associated with public information programs, then, can be
described as follows:
• develop program strategy including who will operate the pro-
gram (State franchise or private firm), level of activity
associated with each phase, implementation dates (approximate)
of each phase, etc.; this planning effort should be completed
prior to 31 March 1979.
• define details of the first phase of the public information
program and implement and conduct same; this should occur
during the period from approximately 1 April 1979 to
31 August 1979.
• define details of the second phase of the public information
program and implement and conduct same; this should begin
6 to 12 months prior to program startup and extend through
the first year of full operation.
• define details of the third phase of the public information
program and implement and conduct same; this should follow
the completion of the second phase and continue as required.
The next items from the list of I/M Implementation Schedule elements that
will be discussed are items 5 through 8. Items 5 and 6 concern developing
and issuing requests for proposals (RFP's), and subsequent award of a contract(s)
to a private firm(s), while items 7 and 8 concern the actual construction of
facilities.
Assuming first that contractor-operated inspection facilities are selected,
the first task would be to develop a detailed plan of what the program is to
include, and specifically, what the requirements for and responsibilities of
the contractor would be. These would be published as an RFP and distributed
to interested contractors, who would respond with proposals to establish and
operate the inspection facilities. The State would review and evaluate the
proposals and select a particular contractor from those submitting proposals.
The next items deal with the initiation and completion of facilities
construction.
If Minnesota decides to run the program "in-house," an additional task
can be identified; this involves the formal processes that the State must use
in negotiating for a design consultant, soliciting bids from a construction
contractor, and finally selecting a construction contractor. Certain other
steps are also as critical as construction start and completion dates; these
include site selection, land purchase, etc.
117
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The individual tasks associated with the items discussed above can be
defined as follows:
• prepare request for proposal; this would likely take 2 months
to prepare and would not be started until after the legisla-
ture and budget were approved; this task would occur, say,
during April through July 1979;
• assuming that the RFP's were issued by August 1, 1979, and pro-
posals due in late November 1979, the proposals could be eval-
uated and a contractor selected by late January 1980;
• contractor begins site search and purchases required land;
occurs during the period February 1980 through July 1980;
• contractor begins construction of facilities; construction
period August 1980 through March 1981.
Selection, purchase, and delivery of equipment is listed next in the I/M
Implementation Schedule. It could be expected that a fairly substantial lead
time would be required between ordering and delivery of certain equipment
items. The intent, however, would be to stage equipment delivery over the
latter portion of the facilities construction period, so that equipment could
be installed as it arrives. This is the usual procedure used in construction
practice and should not be of extraordinary concern.
Should a state-run option be selected, additional time would be needed as
a competitive bidding procedure would be required. The specific tasks, then,
are:
• Select equipment in accordance with State specifications,
purchase same; this would be done, say, during the period
August 1980 through March 1981.
• Equipment delivery; occurs as required August 1980 through
March 1981.
Item 12 in the Implementation Schedule concerns the development and adop-
tion of cutpoints. Initial cutpoints can be selected based on vehicle emis-
sions data compiled by other states, and these can be refined during the early
stages of inspection once a sufficient cross-section of the vehicle population
has been tested. The initial cutpoints should be defined after some initial
study of existing data. Specific tasks include:
• review data from other programs, define initial cutpoints; this
can take place during the period 6 to 9 months prior to
startup;
• refine cutpoints to account for Minnesota-specific data and
changing vehicle emissions characteristics; this occurs approx-
imately 6 months after initiation of testing and continues
throughout program.
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Items 13 and 15 on the Implementation Schedule deal with hiring and train-
ing inspectors and other personnel, and initiation of training programs for
both inspection personnel and the auto repair industry. A distinction can be
made with regard to operating personnel and administrative personnel phase-in.
Administrative personnel would be phased into the program 12 months prior to
beginning the testing while operating personnel, managers and inspectors,
would be phased in 6 months and 1 month prior to startup, respectively. Train-
ing courses for inspection personnel would begin approximately 6 months prior
to startup to train all new personnel, and the training would continue through-
out the program to train additional personnel approximately 6 months prior to
mandatory maintenance. A task that must be carried out prior to implementing
mechanics training is to define the nature of the training program in terms of
who will do the testing, what will be taught, etc. The specific tasks involved
include:
• hire administrative personnel; this would be accomplished
12 months prior to program startup; *
• hire inspection facility managers and assistant managers;
this would be accomplished 6 months prior to start;
• determine training program details including scope, who
will conduct training, where training is to be held, etc.;
this would be accomplished 1 year prior to startup.
• begin mechanics/inspector training program; this would begin
6 months prior to beginning any testing (inspector training
phase would begin 1 month prior to startup).
The last items on the Implementation Schedule concern phasing in mandatory
inspections and mandatory maintenance. The MPCA has indicated that the general
procedure would be to have voluntary maintenance but mandatory inspections
during the first full year of operation. EPA guidance on deadlines is provided
below:
"D. I/M Implementation Deadlines
Implementation of I/M "as expeditiously as practicable" shall be
defined as implementation of mandatory repair for failed vehicles no
later than two and a half years after passage of needed legislation or
certification of adequate legal authority for new centralized systems
and one and a half years after legislation or certififation for decen-
tralized systems or for centralized systems which are adding emission
inspections to safety inspections. For the normal legislation deadline
of June 30, 1979, new centralized programs must start by December 31,
1981, and all others must start by December 31, 1980. For the case of
the latest possible legislation date, July 1, 1980, this means that a
new centralized program must start by December 31, 1982, while all other
programs must start by December 31, 1981. Where I/M can be implemented
more expeditiously, it must be. Each state implementation schedule must
be looked at individually to determine if it is as expeditious as prac-
ticable. Implementation dates ordered by courts, if earlier than these
dates, take precedence."
119
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New policy guidance from Region V administrator, John McGuire, however,
states:
"Regardless of whether legal authority for I/M is obtained during
the 1979 or the 1980 legislative session, the I/M program must be
implemented in its mandatory phase no later than December 31, 1982,
in the case of a centralized I/M program, in order to insure equity
among the States."
It appears, then, that a full year of mandatory inspection, voluntary
maintenance will be possible for the proposed program.
The tasks that can be identified here regarding phase-in are:
• implement mandatory inspection, voluntary maintenance;
this will occur approximately 1 July 1981 and run
through 30 June 1982.
• implement mandatory inspection, mandatory maintenance;
this would begin 1 July 1982 and extend throughout the
program*.
The issues discussed above, again, must be defined in terms of the
schedule for implementation in the revised SIP. As a. summary of the above
discussion, Table 43 is presented showing each task identified above and its
approximate implementation dat .
Legislation now being considered by the State of Minnesota has called for
opening of inspection stations by November 1, 1981, mandatory inspection by
January 1, 1982, and mandatory repair by January 1, 1983, which would comply
with the Region V implementation requirements mentioned above. The schedule
shown in Table 43 indicates implementation may be possible approximately
6 months prior to the legislative deadline of mandatory inspections (January 1,
1982). One alternative to beginning mandatory inspections on July 1, 1981,
would be the inclusion of a six month voluntary inspection period from July 1,
1981, through January 1, 1982, when mandatory inspections could be initiated.
The actual duration of the program beyond 1987 is open to speculation at this
time. Should the program not be needed as an air quality improvement measure
beyond 1987, the State would have the option of continuing, modifying, or
terminating it.
120
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SECTION 7
COLD CLIMATE CONSIDERATIONS
INTRODUCTION
Numerous statistics do not have to be presented here to substantiate the
statement that winters in Minnesota tend to be quite severe. The question, how-
ever, as to how severe winter weather affects emissions testing; is quite important.
Winter conditions would be expected to affect the emissions testing pro-
gram in three specific areas; viz.:
• individual vehicle emissions
• analyzer performance
• general station operation
Each of these areas is discussed in the following paragraphs.
EFFECTS OF COLD OPERATION ON INDIVIDUAL VEHICLES
The primary impact of cold ambient temperatures on automotive emissions
occurs during the initial stages of operation. Cold-mode operation is the
term that, in the very general sense, is defined as the first several minutes
of operation. The purpose of this discussion is to define the causes and
implications of cold-mode operation as it affects (or potentially may affect)
the proposed I/M program for Minnesota. Additionally, the issue of seasonal
differences in motor fuel composition, and the possible impacts on emissions
is also discussed.
Vf
Cold Mode Characterization
As was indicated above, cold mode operation is defined in general terms
as the first several minutes that a vehicle is operated after having not been
operated for several hours. The primary manifestation of cold-mode operation
is an extraordinarily high emission rate of both carbon monoxide and hydrocarbons.
The excess emissions associated with cold operation occur as a result of
a temporary imbalance in the combustion system parameters. In order for
*
Based on: Midurski, Theodore P., and Alan Castaline. Determination of Per-
centage of Vehicles Operating in the Cold-Start Mode. GCA Corporation, GCA/
Technology Division, Bedford, Massachusetts. Prepared for U.S. Environmental
Protection Agency, Office of Air Quality Planning Standards, Research Triangle
Park, North Carolina. EPA Report No. EPA-450/3-77-023. August 1977.
124
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ignition to occur in a gasoline engine, the fuel introduced into the cylinder
must be vaporized and there must be present an appropriate balance or ratio''
between the quantities of air and vaporized fuel. Gasoline does not vaporize
as well at lower temperatures as it does in the relatively high temperature
ranges that are typical of stabilized engine operation. Therefore, when a
"cold" engine is being started, the rate of gasoline vaporization that occurs
in the combustion area is much less than when the engine is operating at normal
temperature. As a result, an imbalance occurs in the air-to-fuel ratio; this
imbalance can be so severe that ignition will not occur. To compensate for
this temporary imbalance in the air-to-fuel ratio, the fuel delivery system
is equipped with a choke mechanism, which, when activated, restricts the flow
of incoming air to the point where a vacuum occurs in the intake manifold.
The vacuum causes additional fuel to be drawn into the manifold resulting in
extra fuel being delivered to the combustion areas. The increase in the total
amount of fuel delivered to the cylinder compensates for the reduction in the
rate of vaporization, so that the net result is an air-to-vaporized fuel ratio
that is suitable for ignition. Although the ratio of air-to-vaporized fuel
becomes balanced when the choke is functioning, the ratio of air to total
fuel becomes imbalanced owing to an insufficient quantity of combustion air
being present. This imbalance results in incomplete fuel combustion; two
major products of incomplete combustion are carbon monoxide and various un-
burned hydrocarbon compounds.
The choke mechanism on most vehicles is actuated automatically by a heat
sensor incorporated into a temperature-sensitive engine component such as the
intake manifold. The rise-time from ambient to stabilized temperature for
the heat sensitive components generally lags the rise-time in the entering
fuel temperature and combustion chamber temperature by various amounts of time,
thereby assuring adequate choke-on time. Studies have shown the choke-on time
to be a function of ambient temperature. Figure 5 provides an indication of
choke-on time as a function of ambient temperature.1
e
101
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-30 -20 -(0 0 10 2O 30
TEST ^EMPERATUWE, T
Figure 5. Representation of choke-on time as a function of ambient
temperature.
This ratio is commonly referred to as the air-to-fuel ratio,
125
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Production of excess emissions during the cold stages of vehicle opera-
tion occurs also as a result of a phenomenon known as wall quenching. Wall
quenching is a combustion phenomenon that occurs when a flame moves towards
a relatively cool cylinder wall. The cool cylinder wall slows and effectively
stops combustion in the vicinity, thus a layer of unburned and partially
burned fuel remains at the wall surface at the end of the combustion stroke.
The thickness of the layer is a function of several parameters including the
cylinder temperature and pressure, the presence of cylinder deposits, and the
wall temperature itself. Obviously, the cylinder and wall temperatures are
much lower during initial operation than after warm-up. These lower tempera-
tures result in a thicker layer of unburned or partially burned fuel during
each stroke, which contributes to the total excess emissions associated with
cold-mode operation.
Emissions from newer vehicles equipped with catalytic converters are
affected by cold operation because of an additional factor. The converter,
which functions as the primary emission control device, does not: begin to
operate efficiently until it reaches a certain temperature. The time required
to reach the most efficient operating range is generally around 200 to 300
seconds, regardless of the ambient temperature. Therefore, during the several
minutes that it takes for the converter to reach optimum operating temperature,
carbon monoxide and hydrocarbons emission rates are somewhat higher than dur-
ing warmed-up operation.
Temperature obviously has a considerable effect on cold-mode emission
characteristics. The relative impact that ambient temperature has on emission
rates has been analyzed in the laboratory during several studies. Of par-
ticular importance is the fact that these studies conclude that the effects
of varying ambient temperatures are apparent only during the first several
minutes of operation. In one set of tests,2 the effect of ambient temperature
on carbon monoxide and hydrocarbon emission rates for three configurations of
standard 1970 production cars, and three 1970 production cars equipped with
advanced (with respect to the 1970 model year) emission control devices, was
analyzed. The testing involved measuring the emissions produced by each
vehicle as it was operated from a cold condition* through the Urban Dynamometer
Driving Schedule, which is included in the Federal Test Procedure. Tests were
performed at several different ambient temperature conditions for each vehicle.
Cumulative emissions were then identified as a function of elapsed operating
time and temperature; test results are illustrated in Figures 6 through
11.
These figures show quite vividly that the emission rates of both hydro-
carbons and carbon monoxide for the test cars are generally not sensitive
to changes in ambient temperature beyond, say, the first 200 to 300 seconds of
operation, but within the first 200 to 300 seconds, temperature has a marked
effect on emission rates.
v'c
Cold condition implies that the vehicles had not been operated Eor at least
12 hours prior to testing.
HC emissions for Test Cars G, I, and J (Figures 9 through 11) were con-
ducted but are not reported here.
126
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MC
CUM
CIAMS
40
X
30
10
O* A
ISO CID "A" lorfy
If 70 reduction
Commercial Pram. Fu»l
4000 l>. liwtla Wi.
200 400
400 800
TIMf
sec
1000
1200 1400
BOO
700
600
500 CO
CUM.
4<» GRAMS
300
200
100
0
Figure 6. Cumulative HC and CO emissions during
FTP driving cycle - Car A.
50
40
HC
CUM
CIAMS
30
20
10
CAM
400 CIO Engin. "I" looy
1970 Production Cor
Commorciol Pr«m* Fu«l
4300 b. IrwrtioWt.
1400
800
TOO
600
MO CO
CUM.
400 GRAMS
300
200
100
0
Figure 7. Cumulative HC and CO emissions during
FTP driving cycle - Car B.
127
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MC
CUM
CRAMS
SO
30
20
10
CA«C
<55 CIO {-.gin* "«' tody
19/0 Production Cor
Commercial Prem. Futl
SOOOfc. Wr.
70'F CO
200 400
600 800
1IME
SEC
1000 1200 1400
800
700
400
500
400 CO
CUM
300 GRAMS
200
100
0
Figure 8. Cumulative HC and CO emissions during
FTP driving cycle - Car C.
250
200
CO
CUM
GRAMS
150
too
50
CAtG
350 CIO Engine "•' tody
Commwciol UnUoctod Fuel
Cotolytie Converter
All, EC*
Quick VW Monifold
Quick Chok*
4500 fc. Inertia Wt.
_ 20°F
200 400
600 800
TIME
SEC
1000
1200 1400
Figure 9. Cumulative CO emissions during
FTP driving cycle - Car G.
128
-------
250
700
CO
CUM
GKAMS
150
100
50
CM)
250 CIO Engim "A" tody
Pnmlum UnUodwl Fu*l
Colo lyric ConvwHf
AIR
tGR
Production CrtoUft
3500 fc. IntrtioWt.
1400
Figure 10. Cumulative CO emissions during
FTP driving cycle - Car I.
CO
CUM.
GRAMS
500
400
'MO
700
100
v
'" '
F
,7
CAR J
350 CID Engine
"»• Body
Commercial Unleaded Fuel
Catalytic Corw«rt«r
AIR
Production Choke
4300 Ib. Intrlia Wi.
< 00 600 800
TIME
SfC
TstiJ nbn
Figure 11. Cumulative CO emissions during
FTP driving cycle - Car J.
129
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In another series of investigations3on the effects of cold ambient tem-
peratures on light-duty vehicle emissions, nine 1973 vehicles were considered.
These tests involved a standard 23-minute FTP driving schedule during which
exhaust samples were collected for three cycles of operation. The first
cycle included the first 505 seconds of the schedule representing the "cold"
operating phase. The second cycle involved the stabilized phase, which rep-
resent"? the remainder of the 23-minute cycle. The third cycle represents a
"hot start" condition, which involves repeating the first 505 seconds of the
driving schedule after a 10-minute engine-off period. For this series of
tests, an ambient temperature of 60°F was established as a baseline condition.
Comparisons were made of carbon monoxide emissions for each mode at ambient
temperatures ranging from 0°F to 80°F.
The results of the tests are shown in Figure 12. This figure shows the
relative effect of temperature differences (with respect to an ambient tempera-
ture of 60°F) for each of the three test phases and the composite. Figure 12
shows, again, that the relative effect of various ambient temperatures is in-
significant beyond the first few minutes of operation; this is shown by com-
paring temperature effect on Bag 1 emissions (the first 505 seconds of operation)
to the Bag 2 emissions.
The results of a third study1* also indicated the significance of the
first few minutes of cold operation. In this study, 26 production vehicles
of various model years and configurations were tested using the FTP driving
cycle. The testing was conducted at ambient temperatures of 2QQF, 50°F, 75°F
and 110°F. The average emission rates for each phase of the FTP driving cycle
and a composite emission rate were defined for various groupings of vehicles;
these are shown in Figure 13.
Figure 13 provides a good indication of the magnitude of the effect that
cold-mode operation has on emission rates. The effect is best illustrated by
directly comparing the Bag 1 and Bag 2 emission rates. The curves for catalyst
vehicles operating at 20°F indicate that during the first 505 seconds of oper-
ation, the emission rate is about 130 grams per mile while the Bag 2 rate is
about 3 or 4 grams per mile. The importance, then, of accouting for cold-mode
operation in any analysis of carbon monoxide is obvious. As an illustration,
if emissions were computed for a specific location first assuming (1) an
ambient temperature of 20°F, (2) a vehicle mix whose emission characteristics
were similar to those for 1973 - 1974 model year vehicles shown in Figure 13,
and (3) all vehicles operating in the warmed-up (stabilized) mode, the result
might yield the quantity X, which would represent the product of an average
emission rate (in this instance, about 60 grams per mile based on Figure 13
and a travel factor defining the quantity of travel (in vehicle-miles). If a
second analysis were performed using the same assumptions except that all
vehicles were operating in the cold mode (obviously an extreme assumption),
the results would be the quantity 3.8X; this reflects the difference in emission
rates for cold and stabilized operating modes for the representative vehicle
population. If it were assumed that the vehicle population was comprised of all
catalyst vehicles, the difference would be much greater (again, based on
Figure 13).
k
The composite is computed using the sum of 43 percent of Cycle 1 emissions,
100 percent of Cycle 2 emissions, and 57 percent of Cycle 3 emissions.
130
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+ 150
+ 120
u.
O + 90
O +60
oc
u.
+30
O
P n
o -30
£ -60
o
ft:
w -90
-IEO
-1 50
•BAG I
V
BAG 2
REFERENCE CASE
I
20 40 60
INITIAL START-UP TEMPERATURE , (*F)
80
Figure 12. Average vehicle CO percent deviation
versus start-up temperature.
131
-------
?oo
120
80
520
280
160
120
80
40
Cotd Itontitn*
100
140
I?O
100
eo
c.o
10
r.o
9'3-'/4
100
160
140
120
100
80
60
40
20
TEST
o o
AMBIENT. •
Hot trdrnitnl
20 40 60 BO IOO IZO
Figure 13. Temperature dependency of carbon monoxide emissions - varied
categories of vehicles.
132
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Technical Definition of Cold-Mode Operation
It can be concluded from the previous discussion that cold-mode operation
is a time-dependent function. The standard definition of cold-mode operation
is that it represents the first 505 seconds of vehicle operation following a
4-hour (minimum) engine-off period. 5 This definition implies that a discrete
function exists between cold-mode operation and the cold-soak period. Recall,
howeverj that in the previous discussion it was indicated that both ambient
and engine temperatures appear to be critical determinants of cold-mode opera-
tion. The figures presented in that section indicate that ambient temperature
does not have a large effect on the time required to stabilize (ambient tem-
perature does have a very significant effect on the rate of emissions,
however). Apparently, then, the rise-time to stabilized operating temperature
is not affected to a large extent by a differential in ambient temperature of,
say, 50°F (20°F to 70°F). However, the temperature within an engine ranges
from ambient up to about 2000°F in the combustion area (cylinder walls) and
over 200°F for fuel delivery components. Obviously, when an engine is shut
down, these components begin to cool down to the ambient temperature. If the
engine is restarted before the components reach ambient temperature, the amount
of time required to again reach the hot stabilized condition would be reduced.
Limited testing6 by the U.S. Environmental Protection Agency, Office of Mobile
Source Air Pollution Control, has indicated that the time required to reach
the hot stabilized mode is indeed a continuous function of the engine starting
temperature. In these analyses, the starting temperature is considered im-
plicitly to be a function of the soak time. In this connection, equations
were developed describing the required time to reach the stabilized mode as a
function of cold soak period; one of these equations is
t = 3.11 S°'36 (I)1"
where t = time in minutes to reach the stabilized mode and
S = soak time in hours.
The time t defined in equation (1) represents the time to stabilize when the
ambient temperature is about 75°F. Testing was also performed at temperatures
of about 20°F and an equation was derived representing the time required to
stabilize (t^) again as a function of the cold-soak duration; this equation is
t' = 2.61 S°-36 + 1.32 (2)
where t' = time in minutes to reach the stabilized mode at an ambient
temperature of 20°F, and
S = soak time in hours.
Cold soak is defined at the time interval that a vehicle's engine is not
operated.
This equation has been normalized to reflect assumptions in AP-42; for analy-
ses not associated with the emission factors presented in AP-42, a slightly
different equation applies.
133
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The effect of ambient temperature on the cold-mode cycle Length can be
seen by comparing the results of equations (1) and (2) applied to a set of
arbitrary cold-soak durations; this is presented in Table 44, below.
TABLE 44. COMPARISON OF COLD-MODE CYCLE LENGTH IN MINUTES AS A FUNCTION
OF SOAK DURATION FOR AMBIENT TEMPERATURES OF 75°F AND 20°F
. , . Cold soak duration, hours
Ambient
temperature, °F
75
20
2
3
.4
.3
3.6
4.4
4.
5.
3
0
4.9
5.4
5.3
5.8
5.8
6.1
6.1
6.4
6.4
6.8
6.7
7.0
Table 44 clearly shows that the effect of ambient temperature on the cold-
mode cycle length is not nearly as severe as is the cold-soak duration.
Emissions Levels Associated with Cold-Mode Operation
From the previous discussion, it is obvious that the impact of cold-mode
operation on total emissions produced is highly dependent on ambient temperature.
This can be illustrated even more dramatically by plotting both total emissions
and the cold-start portion of the total emissions produced during the FTP urban
driving cycle, as a function of ambient temperature; such a plot is shown in
Figure 14, below. This figure indicates that at temperatures below approximately
0°F, the cold-start mode contributes 70 to almost 85 percent of the total emis-
sions produced.
This becomes even more significant when considering carbon monoxide levels
in areas where large concentrations of cold-mode operation are likely to occur
(in urban core areas during evening rush hours, for example). It has been
suggested that current methods for analyzing cold-mode operation—such as that
used to derive Figure 14—underestimate the cold-mode emissions at 0°F by a
factor of about 2.7 The obvious point of interest concerns whether or not
control strategies developed to reduce CO emissions adequately reflect the
impact that cold-mode operation has on total emissions produced*.
Implications Regarding I/M Effectiveness
The basic question that surfaces at this point concerns the effectiveness
of I/M in reducing cold start emissions. Unfortunately, there are no data that
would provide the basis for a quantitative assessment of the emissions reduc-
tions achievable through an I/M program for the cold-operating mode only. To
date, the composite emissions reductions only have been quantified.
Since photochemical oxidants are associated more with warm seasons, it has
been shown that relatively warm ambient temperatures do not significantly
affect cold-start emissions, the emphasis here is on CO, only.
134
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6
CO
H
00
•a
a)
•H
(1)
"d
•H
X
o
(3
i
o
£>
J.J
td
o
1600
1400
1200
1000
800
600
400
200
0
Notes:
1. Represents 1975 model year vehicle
operating in calendar year 1978.
2. Source: Reference 7.
_L
_L
J_
-30 -20 -10
10 20 30 40 50 60 70 80
Temperature, °F
Figure 14. Cold-start emissions and total emissions produced during
FTP driving cycle as a function of ambient temperature.
Intuitively, however, it would be expected that repairs or adjustments
of the types associated with I/M would necessarily have a positive impact on
cold-mode emissions reductions. Further, if additional emphasis were placed
on inspecting and/or repairing or adjusting components that are particularly
critical with respect to cold-mode emissions generation, such as the choke,
spark plugs, PVC value, etc., one would expect that additional benefits (i.e.,
reductions in cold-mode emissions) would accrue from an I/M program.
Again, it is stressed here that the uncertainty of how I/M affects cold-
start emissions is almost entirely related to conditions where ambient tem-
peratures are generally below about the 30 to 40°F range. This means that
the uncertainty is relevant primarily to the effectiveness of I/M as a CO
control measure.
135
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Implications Regarding Emissions Testing
A further question concerns how cold operations can be expected to affect
emissions testing. First, the previous discussion indicated that the primary
effect of ambient temperature occurs during the warm-up period, which is
generally less than 8 minutes in duration. Beyond this initial period, tem-
perature apparently has very little impact on the acutal emissions rates for
CO and HC. The implication here is that during the emissions testing, the only
requirement is to ensure that the vehicle being tested is fully warmed prior
to measuring CO and HC levels. It sould be safe to assume that most vehicles
will be in the stabilized mode by the time they reach the test site and have
been processed at the reception area. If there is a question of x^hether or
not a specific vehicle is in the stabilized mode, the owner can be advised to
wait several minutes with the vehicle running prior to entering the station.
It would not be practical to do this in the inspection lane, although the
cruise portions of a loaded mode test do offer some preconditioning time.
SEASONAL VARIATIONS IN FUEL COMPOSITION
In order to maintain relatively uniform performance from motor fuel
throughout the year, its composition is altered according to the season.
During colder periods, the vaporization rate of motor fuel (as measured by
its Reid Vapor Pressure) must be enhanced to offset the effects of temperature.
As part of the special blending process, the proportions of various hydro-
carbon categories may change from season to season. The result is that there
may be measurable differences in the emission characteristics of a particular
vehicle from season to season primarily because of the difference in fuel that
is used.
While these differences in emissions characteristics may be small, it may
be of value to analyze the results of the actual tests performed during the
first year of program operation to determine whether or not distinct differences
can be detected as a function of season. If in fact significant differences
are identified, the cutpoints used to determine pass-fail may have to be ad-
justed for the particular season, as well.
COLD TEMPERATURE EFFECTS ON ANALYZERS
Another problem concerning winter temperatures has to do with the steep
temperature differential between ambient conditions within the test and the
outside air. Even the more sophisticated emission analyzers, undergoing fre-
quent quality control checks to minimize analyzer, sampling system, and cali-
bration error, while performing vehicle replication tests, can show under
varying ambient conditions total variability many times greater than the equip-
ment test variability8. Frequent opening of inspection facility doors will
result in temperature variations within the inspection lane over time. A
common energy saving measure of lowering the thermostat at night might also
result in problems, especially if the analyzer is only calibrated daily.
Vehicles tested later in the day when the lane has been heated up to more
comfortable temperatures may not be tested accurately.
136
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It is likely that at certain times, especially at the end of the month
if strict inspection schedules are adopted, vehicles may encounter
delays at the inspection facilities and thus be forced to idle for lengthy
periods in the cold. The result of such a waiting period is a significant
increase in tailpipe moisture. Again, if not properly planned for, this
will affect test results. Moisture from the tailpipe can find its way into
the sampling line and cuase "hydrocarbon hangup," which results in serious
inaccuracies in the emissions measurements.
Aside from reducing waiting times by the availability of additional lanes,
one solution to the tailpipe moisture problems is to heat sample lines, thus
minimizing hydrocarbon hangup problems. Also, to alleviate problems with tem-
perature fluctuations, test facilities should be equipped with analyzers that
rare self-contained in well-insulated, heated/air-conditioned cabinets. During
winter and summer months, the analyzers should be recalibrated every few
hours.
COLD CLIMATE IMPACTS ON FACILITY OPERATION
Several potential problems can be anticipated in the operation of an
inspection facility in a cold climate. Snow, for instance, can have an im-
pact on safety, facility capacity, and inspection demand. Snow-laden vehicles
will result in wet, slippery floors in the inspection area. Also, it is
likely that some motorists may arrive at the inspection facility with tire
chains or studded snow tires. A vehicle cannot be run on a dynamometer with
chains; same discussion has occurred regarding the testing of vehicles with
studded tires on a dynamometer. General conclusions are that vehicles with
studded tires ought not to be tested on the dynamometer because there is the
danger of studs becoming loose and also since the dynamometer rollers would be
subjected to severe wear.
Since vehicles registered in Minnesota are currently prohibited from using
studded snow tires, the associated safety and equipment problems will be avoided.
Motorists should be advised, however, that chains must be removed before the
vehicle can be tested. Should the state rescind prohibition of studded tires,
dynamometers with specially treated rolls are capable of withstanding studded
tires, but are, of course, more expensive.
Snow may cause slowdowns in inspection demand, resulting in a much larger
demand than can be easily handled, at a later point in time. This may require
some flexibility in establishing operating hours. For example, additional
operating hours may be required after prolonged periods of unusually cold or
snowy weather.
One obvious safety problem associated with cold weather operation is the
possibility that in a test lane, when doors are closed, the ambient concentra-
tion of carbon monoxide could reach unsafe levels making working conditions
dangerous. To insure against unsafe carbon monoxide levels in the test lanes
fresh air circulatory systems should be utilized, and ambient CO monitors pro-
vided as warning devices.
137
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SUMMARY
As can be seen from the previous discussion, the rather severe winter
weather associated with the State of Minnesota can have a significant impact
on the proposed I/M program, but only if the program is planned, implemented,
and operated without regard to the special requirements imposed by the climate
of the region. Various measures can be incorporated that will mitigate the
impacts for the most part. It is noted that the experience to date with I/M
programs of the type being considered here, has been in states where winters
tend to be much less severe as compared with Minnesota. There is obviously a
possibility that impacts beyond those delineated above will be discovered once
Minnesota and other similar states have gained experience with winter operations.
The conclusion at this point, however, is that there appear to be no obstacles
that cannot overcome rather easily in operating an I/M program in. areas that
are subjected to severe winter weather.
The more important issue of just how effective I/M will be ELS a control
measure, given the rather cold climate in Minnesota must be considered also.
While it is wholly reasonable to expect I/M to be very effective in reducing
HC emissions during the mild seasons, there appears to be some question as to
how it will affect emissions during the colder periods during the year, par-
ticularly with regard to CO emissions. While a definitive answer to the
effectiveness question cannot be provided at this time, it is noted that sub-
stantial interest in this issue exists, and there apparently will be research
conducted in the very near future in this connection.
138
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REFERENCES
1. Robertson, J. E. The Impact of Vehicle Emissions on Air Quality at Low
Ambient Temperatures. SAE Paper No. 741054. October 1974.
2. Miles, Donald L. and Max Homfeld. The Effect of Ambient Temperature on
Exhaust Emissions on Cars With Experimental Emission Controls. SAE
Paper No. 451052. October 1974.
3. Polak, J. C. Cold Ambient Temperature Effects on Emissions From Light-
Duty Motor Vehicles. SAE Paper No. 741051. October 1974.
4. Ashby, H. A., et al. Vehicle Emissions - Summer to Winter. SAE Paper
No. 741053. October 1974.
5. Compilation of Air Pollutant Emission Factors, Second Edition. U.S.
Environmental Protection Agency, Research Triangle Park, N.C. 27711.
Supplement No. 5 to Publication No. AP-42. February 1976.
6. Williams, Marcia. Definition of Vehicle Cold Start Operation. Unpublished
paper. U.S. Environmental Protection Agency, Office of Mobile Sources.
May 1977.
7. A Review of Carbon Monoxide Emissions from Motor Vehicles During Cold
Temperature Operation—the Importance of Cold Start Emissions for Attain-
ment of Ambient Air Quality Standards. Working Draft. Alaska Department
of Environmental Conservation. November 1978.
8, Elston, J. Auto Emission Inspection Test Variability. (Presented at the
70th Annual Meeting of the Air Pollution Control Association.) Toronto,
Canada. June 1977.
139
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TECHNICAL REPORT DATA
(Please read fmUructions on the reverse before completing)
1 REPORT NO
EPA-905/2-79-001
3. RECIPIENT'S ACCESSION-NO.
4 Til LI AND SUBTITLE
Evaluation of Motor Vehicle Emissions Inspection and
Maintenance Programs in Minnesota
5. REPORT DATE
February 1979
6. PERFORMING ORGANIZATION CODE
7 AUTHOR(S)
Theodore P. Midurski, Frederick M. Sellars,
Nancy K. Roy, Donna L. Vlasak
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