905279003/
Do not WEED. This document
should be retained in the E^A
Region 5 Library Collection.
EVALUATION OF MOTOR VEHICLE
EMISSIONS INSPECTION/MAINTENANCE
PROGRAMS FOR MICHIGAN
EXECUTIVE SUMMARY
CONTRACT NO. 68-02-2536
Task Order No. 7
Pacific Environmental Services, INC.
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EVALUATION OF MOTOR VEHICLE EMISSIONS
INSPECTION/MAINTENANCE PROGRAMS FOR MICHIGAN
EXECUTIVE SUMMARY
1.0 OVERVIEW
Pursuant to United States Public Law 95-95, otherwise known as the
Clean Air Act as Amended (1977), all states are required to demonstrate
the attainment by December 1982 of the national ambient air quality stan-
dards for carbon monoxide (CO) and ozone (O ) in every part of the state.
This demonstration is part of a State Implementation Plan (SIP) to be
approved by the United States Environmental Protection Agency (EPA) no
later than July 1, 1979. For most states, this has required the adoption
of special pollution control measures in order to attain the standards and
maintain them beyond 1982. If an area is unable to demonstrate attainment
of standards by the stated date, despite implementation of various controls,
an extension of the attainment deadline to 1987 may be granted to the
state under certain conditions specified in the Act. One of these condi-
tions is that an emissions Inspection/Maintenance(I/M) program for motor
vehicles be initiated in all areas of the state that will fail to meet
the standards by December 31, 1982. It is EPA policy that the latest
permissible start-up date for such a program is December 31, 1981 if
vehicle inspections are to be conducted at decentralized (private) facil-
ities, and December 31, 1982 if the inspections are to be performed at
centralized special testing stations operated either by the state or
by a private contractor.
The purpose of I/M is to identify vehicles with pollutant emissions
in excess of levels considered acceptable. It is required that vehicles
so identified must be repaired or adjusted. I/M may be considered a qual-
ity assurance mechanism in support of the Federal Motor Vehicle Control
Program which since 1970 has set new vehicle emissions standards for
present and future model years and requires emission control equipment on
new vehicles.
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The State of Michigan must consider candidate I/M programs for imple-
mentation in all or parts of the State, because the five-county Detroit
metropolitan area, at least, is expected to be unable to meet applicable
air quality standards prior to the 1982 deadline. Officially, 37 counties
of southern Michigan, as well as Marquette County in the Upper Peninsula,
have been designated ozone nonattainment counties (Fig. 1). EPA has
determined that reduction of emissions of reactive hydrocarbons (HC),
a major portion of which is attributable to the operation of motor vehicles,
is necessary for the reduction of ambient 0 levels, and can be achieved
through I/M. Failure to address the issue of I/M could result in disap-
proval of the Michigan SIP, which in turn would result in the imposition
of restrictions on industrial growth and possible federal funding sanctions
on the State. Because of the significant effort involved in developing
the information needed to meet the Clean Air Act requirements that mandate
legal authority for I/M no later than July 1, 1979, EPA provided funding
for Michigan to secure contractual assistance for the performance of
necessary technical studies of I/M. Pacific Environmental Services, Inc.
(PES) and Systems Control, Inc. (SCI) were selected to evaluate a range of
possible I/M program configurations to assist in the identification of
a short list of alternatives that would be appropriate in Michigan. The
findings of the evaluation are presented in the two volume study that
accompanies this summary.
1.1 STUDY OBJECTIVES
There were five principal objectives of this study.
1. Explore a broad range of program options.
2. Perform a comprehensive evaluation of the costs and
benefits of seven principal or "base" options that
together incorporate all the unique properties of
program configurations suggested by representatives
of the State of Michigan.
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1. ALCONA
2. ALGER
3. ALLEGAN
4. ALPENA
5. ANTRIM
6. ARENAC
7. SARAGA
8. BARKS'
9. sax
10. BEHZIE
11. BERRIEN
12. BRANCH
13. CALHOON
14. CASS
15. CHARLEVOIX
16. CHEBOYGAN
17. CHIPFEWA
18. CLARE
19. CLINTON
20. CRAWFORD
21. DELTA
22. DICKINSON
23. EATON
24. EMMET
25. GENESEE
26. GLADWIN
27. GOGEBIC
28. GO. TRAVERSE
29. GSATIOT
30. HILLSDALS
31. HOOGHTON
32. HURON
33. INGHAM
34. IOHIA
35. IOSCO
36. IRON
37. ISABELLA
38. JACKSON
39. KAUMA2OO
40. KALKASKA
41. KEUT
42'. KEWETNAW
43. LAKE
44. LAFEER
45. L2ELANAD
46. LENAWEE
47. LIVINGSTON
4S. LDCE
49. MACKINAC
50. MACOMBMETRO
51. MANISTEE
52. MARQCTETTE
S3. MASON
54. MECOSTA
55. MENOMINEE
56. MIDLAND
57. MISSAUKEZ
58. MONROE
59. KONTCALM
60. MONTMORENCf
61. MUSKEGON
62. NEWAYGO
63. OAKLAND-METRO
64. OCEANA
65. OGEMAW
66. ONTONAGON
67. OCEOLA
68. OSCODA
69. OTSEGO
70. OTTAWA
71. PRESpOE ISLE
72. ROSCOMMON
73. SAGINAW
74. SANHAC
75. SCHOOLCRAFT
76. SHIAWASSEE
77. ST. CLAIR-METSO
78. ST. JOSEPH
79. TUSCOLA
30. VAN BOREN
81. WASHTENAW
82. WAYNE METRO
83. WEXFORD
Figure 1. MICHIGAN OZONE NONATTAINMENT COUNTIES
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3. Develop estimates of program costs and consumer fees
for a matrix of 24 program configurations expanded from
the base options and differentiated by administrative
mode, inspection mode, and scope.
4. As a result of this comparative analysis and consultation
with concerned representatives of Michigan, eliminate
from the matrix those candidate programs determined to
be either unsatisfactory or inappropriate for the State,
5. Prepare a program plan for further detailed study of a
specific inspection/maintenance program for Michigan.
Volume 1 of the report addresses the first objective, while Volume
2 presents the results of the analyses undertaken for objectives 2, 3, and
4. The recommended:program plan for further study has been submitted
under separate cover.
1.2 BASIC FEATURES OF INSPECTION/MAINTENANCE
Volume 1 of the report introduces the basic elements and issues of
an I/M program.
EPA policy requires that an approvable I/M program must be able to
produce by the end of 1987 a 25 percent net reduction in emissions of
HC and CO from light-duty vehicles (LDV) compared to what these emissions
would be without this program. Additional emission reductions may be
achieved if a state includes testing of other vehicle categories, such as
heavy-duty gasoline trucks. Vehicle categories that a state may consider
for emissions testing in an I/M program include the following:
a. Light-duty vehicles weighing less than 6,001 pounds
b. Medium-duty vehicles (generally trucks) weighing from
6,001 to 8,500 pounds
c. Heavy-duty (.greater than 8,500 pounds), gasoline vehicles (HDG)
d. Heavy-Duty (greater than 8,500 pounds) diesel vehicles (HDD)
e. Motorcycles
The overall potential for emissions reduction is also sensitive to
the geographical scope of program coverage. Six geographic areas of
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Michigan have been identified as meeting appropriate criteria for imple-
mentation of I/M. These areas are listed below in descending order of
size. Again, it should be noted that an I/M program is mandatory only in a
region in which attainment by 1982 of CO and/or O standards cannot be
demonstrated. Nonetheless, it is true that more comprehensive geographic
coverage results in greater total emissions reduction.
Potential geographic coverage:
a. Entire state (83 counties)
b. Ozone nonattainment counties of lower peninsula (37 counties)
c. Ozone nonattainment metropolitan counties
Detroit (Macomb, Monroe, Oakland, Washtenaw, and Wayne) -
also includes CO nonattainment area
Lansing (Clinton, Eaton, and Ingham)
Grand Rapids (Ottawa and Kent)
Flint (Genesee)
Two elements of candidate I/M programs that do not affect the mag-
nitude of emissions reduction, but nevertheless, are the principal character-
istics distinguishing one candidate from another are the administrative
arrangements and method of emissions inspection. These elements are
discussed below.
Several possible administrative approaches have been evaluated for
the State of Michigan. These arrangements describe the operational format
of the inspection phase of I/M, and would be characterized by one of the
following.
State-owned/operated centralized facilities, in which a public
authority of the State of Michigan would manage and operate
publicly-owned test facilities.
Contractor-owned/operated centralized facilities, in which a
private firm or other entity selected through competitive
bidding would be delegated operational responsibility for inspec-
tion. The contractor and not the State would assume financial
responsibility for constructing and operating test centers.
Administrative overview and monitoring would remain the respon-
sibility of a public authority.
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Inspection of a statistical sample of vehicles at state- or
contractor-owned/operated facilities, in which a stratified,
randomly-sampled percentage of the Michigan vehicle population
would be tested to determine if the vehicles are tuned and oper-
ating generally within manufacturers specifications. The objec-
tive of this approach would be to establish whether or not a
full-scale I/M program is needed in Michigan, and if such a
program would accomplish its intended goal of emission reduction.
Privately-owned/operated decentralized facilities, in which the
State of Michigan would certify qualified establishments (inde-
pendent service garages and dealerships) to perform inspections.
The State would oversee and regulate the program to ensure that
I/M requirements and provisions are met.
All I/M programs currently in operation utilize either centralized
facilities operated by public authority or contractor or decentralized
private garages for vehicle inspection. For all administrative approaches
except statistical sampling, repair of vehicles which fail an emissions
inspection would be mandatory. Repairs would be performed by dealerships,
service garages and independent operators comprising the automotive ser-
vice industry.
Three emission inspection procedures have been evaluated for imple-
mentation in an I/M program for Michigan. These are;
the idle-mode test,
* the loaded-mode test, and
an engine parameter/device inspection (EPDI).
Moreover, it has been proposed that an inspection for safety defects and
excessive noise be incorporated into the emissions inspection procedure.
That is, safety and noise tests would be performed at emissions inspection
stations, most likely at positions specially equipped for such testing.
The idle mode test consists of measuring tailpipe exhaust emissions
with the vehicle idling in neutral gear. Hydrocarbon and carbon monoxide
levels are measured at both normal and high-idle speed. The test at the
normal-idle speed is conducted at the vehicle manufacturer's recommended
idle (600 to 1,000 revolutions-per-minute) while the high-idle test is con-
ducted at 2,500 rpm. Emissions are collected by a tailpipe probe. The
general characteristics of idle-mode testing include:
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Simplicity, requiring minimal training for inspectors
Limited diagnosis of some engine maladjustments and malfunctions
High probability that test conditions can be duplicated by pri-
vate garages for repair diagnosis
Brief test time and minimal equipment requirements
Inability to detect some emission control system malfunctions
that would occur when a vehicle is operating under road-load and
higher speeds
Inability to detect elevated emissions of nitrogen oxides (NO ),
a regulated pollutant
Opportunity to perform minor carburetor adjustments during testing.
The results of any approvable short emissions test must correlate sat-
isfactorily with results obtained from the Federal Test Procedure (FTP).
FTP is EPA's baseline inspection cycle of over forty minutes' duration
which requires a twelve-hour engine-off preconditioning period ("cold
soak") for each vehicle tested. To date, EPA has not released a list of
approved short cycle emissions tests. However, it is anticipated that
the idle mode inspection procedure will be approved.
The loaded mode test may also be approved. This inspection proce-
dure requires the use of a chassis dynamometer and, if specified, a gas
analyzer for oxides of nitrogen (NO ) in addition to the standard HC
-X
and CO analyzers. It has been determined from experimentally-derived
data that most high contaminant emissions result from specific engine
maladjustments or malfunctions that come to light under different
engine speed and road-load conditions. Therefore, it is advisable that
several different load conditions be applied to a vehicle during emissions
inspection. One version of a loaded-mode test, called the transient-
mode or Federal short-cycle inspection, analyzes emission samples from
nine operating modes (simulated after vehicle positioning on the dynamo-
meter) ranging from idle through acceleration to high cruise and decel-
eration over a time period of 125 seconds. The disadvantage of the Fed-
eral short-cycle test is that it is very equipment-intensive, requiring
all equipment used in the FTP. By contrast, most loaded-mode testing
-------
conducted in ongoing I/M programs employs a limited selection of typical
test speeds which usually include only high cruise (.44 to 50 mph) , low
cruise (22 to 30 mph) and idle. Exact test speeds and loads would depend
on vehicle weight. Different failure limits are established for the HC
and CO (and NO ) concentrations for each operational mode and vehicle
-X
model year. Better diagnostic information can usually be obtained from
a loaded test because failures at non-idle modes generally point to a
specific and identifiable malfunction referenced in a logic diagram or
"truth chart-" However, unless mechanics are extensively trained in
the proper use of loaded test diagnostic information, the diagnostics
do not result in emissions reduction greater than that which is obtainable
from the idle mode test.
For the engine parameter/device inspection (EPDI), vehicles are
subjected to a sequence of system component checks to determine the
mechanical condition of various emissions-related systems. Components
and/or operating parameters outside the accepted tolerance range are
considered to have failed, and are required to be replaced or adjusted
to manufacturer's specifications. This approach does not specifically
include measurement of emissions levels, although in some cases, emission
measurements would be taken to evaluate the state of vehicle systems such
as oxidation and reduction catalysts. The diagnostic capabilities of the
EPDI are probably the greatest of any of the short emissions tests
discussed here.
The following sequence is generally applicable to any emissions
testing procedure. Upon its arrival at an inspection facility, (1) the
registration/license number of a vehicle and other pertinent information
on vehicle characteristics are recorded. This is followed by (2) visual
inspection of the exhaust system and emission control devices, (3) the
exhaust emission test, (4) recording of test data, (5) notification of
test results to the motorist, and (6) issuance of certificate (compliance,
failure, or waiver). Figure 2 illustrates this sequence. For a drive-
through facility with three positions per inspection lane, steps 1 and
2 above would occur at position one, steps 3 and 4 at position two, and
-------
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steps 5 and 6 at position three. These positions are respectively termed
the receiving station, test station, and certification station. Data
handling operations may be fully automated or manual, with automated
data handling the rule at centralized inspection facilities. Based on
the exhaust emission test data, a pass/fail decision is made and discussed
with the vehicle owner. Passed vehicles are certified, but impending mal-
functions are flagged. Failed vehicles are diagnosed as to the probable
cause of failure, then released to the motorist for required repair.
Certain vehicles may be granted a waiver from further testing but, in
general, failed vehicles must return to an inspection station following
repair for a retest.
The proposed inclusion of safety testing as part of an emissions in-
spection program was prompted in part by the Michigan Trial Substitute
Vehicle Inspection Program, conducted during 1975 and 1976 at random check
lanes in two Michigan counties. The following items were checked as part
of this program.
Vision defects (glass, wipers, washers, mirrors)
Lighting defects
Exhaust defects (noise and smoke)
Control defects (steering, brake and tire condition)
Miscellaneous deficiencies (horn, registration, and seatbelts)
Among the findings of this program, which is no longer in operation, was
that the overall rate of inspection failure was relatively insensitive to
sample size.
Vehicle-in-use standards and periodic motor vehicle inspection pro-
grams presently operating in other states emphasize safety-related compo-
nents. There is a general belief that vehicles in good operating condition
are less likely to be involved in accidents. The safety inspection envi-
sioned for Michigan would involve quick visual checks of the parameters
mentioned above and a brake test using the skid plate method which is
described in Volume 2, Section 3.3.1 of the report.
10
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The State of Michigan has already established procedures and standards
for drive-by and stationary noise levels. However, the procedure is not
compatible with indoor test facilities in which a large hard-surface testing
site and low ambient noise levels cannot be assured. Simple stationary
tests correlatable with federal pass-by procedures would be needed for
integration into an I/M program. If such tests can be developed and
specified, and their space requirements are not extensive, one or more
may be performed at an emissions inspection facitlity.
1.3 EXPLORATION OF SPECIFIC PROGRAM OPTIONS
Volume 2 of the report is devoted to an in-depth examination of the
characteristics of the specific I/M program options that -may be considered
for implementation in Michigan. The various benefits and economic effects
attributable to I/M generally are discussed in a Michigan context. Also
discussed are ancillary issues of program implementation and operation
(including quality assurance of testing, consumer protection for repair,
public information strategies- and mechanic training programs) that must
be addressed in any program regardless of administrative approach or method
of test. Cost categories for the program are identified and explained;
then, total life costs and annual consumer fees are developed for a
comprehensive set of seven basic and seventeen additional program options.
Based on a comparison of costs, the qualitative merits of each option and
extensive consultation with State of Michigan Technical Advisory Com-
mittees for air quality and inspection/maintenance, the total number of
candidate options is reduced to a set of two firm and one conditional
program configurations for further study. These configurations are dis-
cussed in Section 1.5 of this Summary.
The primary purpose and principal benefit of an Inspection/Mainte-
nance program is the reduction of vehicular emissions. However, there are
associated benefits and positive effects of a successful I/M program in
the realm of monetary savings and improved driveability for the indivi-
dual and certain direct and indirect economic effects. Section 2.0 of
Volume 2 introduces and expands upon the benefits of I/M applicable to
Michigan.
11
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Table 1 presents the total emission reductions that would result from
an I/M program covering all light-duty vehicles (less than 8,500 pounds)
in each of the State's five nonattainment metropolitan areas, under the
assumption that 20 percent of vehicles tested would fail the emissions
inspection and undergo repair. It is further assumed that trained mechan-
ics perform these repairs. Values in the table were supplied by the Michi-
gan Department of Transportation and the Southeastern Michigan Council of
Governments, and were generated using EPA's MOBILE 1 computer program
which computes vehicle emission factors under a wide variety of assump-
tions and incorporates the emission reduction credits attributed to an
I/M program by EPA (based upon values presented in Appendix N of Part 51
of Volume 40, Code of Federal Regulations). Other program benefit issues
discussed in Vol. 2, Section 2.0 are the likely increases in fuel economy,
improved vehicle performance and vehicle life attributable to the iden-
tification and correction of out-of-tune and malfunctioning vehicles;
the identification of warranty parts failures; employment generation and
other economic growth effects attributable to the technical and material
requirements of I/M; the "banking" of emission reduction credits through
I/M in order to protect future industrial growth in Michigan; and
miscellaneous difficult-to-quantify effects including reduced health-
related costs and improved visual esthetics attributable to cleaner air.
In general, assignable benefits are insensitive to program administration
and method of test (with those test procedures for which EPA has acknow-
ledged emission reduction benefits) but vary with geographical scope
of coverage and by type and population of the vehicles subject to inspec-
tion.
Table 2 presents the matrix of 24 program options evaluated for
Michigan. The "base options'" incorporating all unique program features
with repsect to administrative approach, method of test, and program
objectives, are identified in the table by asterisks. For each base
option output capabilities for an inspection lane were computed on the
12
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Table 1. INSPECTION/MAINTENANCE PROGRAM RESULTS IN MAJOR URBAN AREAS
IN THE DESIGNATED NONATTAINMENT REGION
CO
1982: No I/M
I/M 1 year
% Decrease
1987: No I/M
I/M 5 years
% Decrease
1982: No I/M
I/M 1 year
% Decrease
1987: No I/M
I/M 5 years
% Decrease
Detroit*
3,885,672
3,512.449
9. ft
2,346,511
1,746,443
25.6
35.2.863
340,469
3^5
204,066
.159,350
21.9
Flint
168,420
146,679
12.9
92,333
58.196
37.0
Ijuising
135,129
117,530
13.0
78,492
49,401
37.0
HC
20,527
19,680
4.1
10,868
7,882
27.5
17,135
16,449
4.0
9,424
6,883
27.0
Grand Rapids
182,651
158,860
13.0
101,874
64,085
37.0
21,087
20,166
4.4
11,648
8,349
28.3
Niles^
9,557
8,305
13.1
5,514
3,433
37.7
1,066
1,017
4.6
622
439
29.4
Figures are kilograms per average-summer-day for 20 percent failure rate not including
mechanics training
Values supplied by Southeastern Michigan Council of Governments. Hydrocarbon totals
for Detroit include only reactive HC.
Note: I/M program presumed to include 20 percent failure rate (stringency factor)
and repairs by trained mechanics.
13
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basis of time required to perform a single inspection (by test mode and
scope) factored by an empirically-derived percentage multiplier of actual
versus ideal efficiency. The output computation procedure for each mode
of test is discussed in Section 3,6.2 of Volume 2. The following annual
lane capacities were developed for a testing program involving light-duty
vehicles (LDV).
Idle mode 23,000 LDV
Loaded mode 19,200 LDV
Engine Parameter/Device Inspection 4,500 LDV
Based on these values and the required staffing complement per inspection
facility, total personnel and lane requirements were developed by county
using projected vehicle registration for 1987. Given capacity and personnel
requirements it became possible to identify specific values by program
option for each of the cost elements shown in Table 3, We shall return to
this table presently.
I/M program requirements that may result in public and private costs
directly attributable to the program are introduced in Section 3.8 of
Volume 2 and discussed in depth in appendices to the report. Individual
states are responsible for obtaining the legal authority to implement
vehicle Inspection/Maintenance programs. Michigan does not currently have
enabling legislation. The legislation will be requested during the fall
of 1979. Legislation may be very general, or may be very specific and
assign all reponsibilities for the program, determine testing procedures,
and even set emission standards. Preparation of this legislation will
require considerable devotion of time and effort by elected officials and
staff of the State of Michigan. Appendix B of Volume 2 presents a detailed
discussion of the issues that should be considered for inclusion in I/M
legislation.
While I/M legislation is debated and after its passage by the
Legislature, the citizens of Michigan must be informed of all aspects
of the impending program which will have an impact on their accustomed
activities. The basic features of a public information effort and a
suggested timeline for implementation of the various stages are presented
in Appendix C.
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Table 3. COST ELEMENTS
ITEM COST ELEMENT
I. INITIAL IMPLEMENTATION AND CAPITAL COSTS (NONRECURRING)
A. Initial Implementation Costs
1. Site Selection
2. Bids Preparation and Evaluation
3. Facilities Design
4. Training Plan Development
5. Personnel Selection
6. Document Preparation
7. Administrative Support
8. System Integration, Checkout, and Certification
9. Test Scheduling System Development
B. Capital Costs (Construction)
1. Land and Site Improvement Costs
a. Land Cost
b. Site Improvement Costs
2. Facility Construction
3. Instrumentation Cost
4. Office Equipment
5. Computer Costs
a. Hardware
b. Software
C. Caoital Costs (Other)
1. Administrative Office Equipment
2. Quality Control Equipment
a. Mobil Unit
b. Referee Station
c. Correlation Car
3. Consumer Complaint
II. ANNUAL OPERATING COSTS
A. Facility Operating Costs
1. Personnel Costs
2. Maintenance and Miscellaneous Item Costs
a. Facility
b. Equipment
B. Support Costs
1. Administrative
2. Data Analysis
3. Training
C. Quality Control Operating Costs
1. Personnel
2. Supply
3. Maintenance
III. ANCILLARY PROGRAMS ANNUAL OPERATING COSTS
A. Mechanic Training
B. Public Information Program
C. Consumer Complaint
D. Vehicle Test Scheduling Costs
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An I/M program will fully succeed with respect to its intended pur-
pose and to the satisfaction of the public only if qualified mechanics
perform the repairs necessary to bring polluting vehicles into compliance
with standards. Michigan is fortunate to have a vehicle mechanic and
repair facility certification and registration system already in place,
which will greatly ease the problem of identifying qualified mechanics to
perform vehicle repairs. However, additional mechanics must be trained
and many mechanics retrained for perform the necessary repairs. Appendix
D presents the elements of a mechanics program, discusses the two-phase
training approach recommended by State of Michigan staff, and provides
an appropriate program timeline. Costs developed for the training effort
are incorporated in the detailed option cost analyses of Volume 2, Section
5.0.
Any vehicle owner subject to inspection/maintenance should expect
that accurate, consistent inspections will be performed on his or her
vehicle, and that there will be protection from improper and unnecessary
repairs in the event of failing the test. Further, the owner should be
assured that the motorist seeking to circumvent the system Cand thus to
neutralize the contribution the honest owner is making to clean air through
proper vehicle maintenance) will be identified and that such cheating will
be minimized. Mechanisms to assure accurate inspections at testing facil-
ities include state-operated referee lanes or challenge garages (for
complaint handling), mobile quality assurance vans equipped .with instru-
ment and gas calibration devices, correlation vehicles for comparative
evaluation of test results from lane to lane, and a regular, internal,
rigorously-observed schedule of instrument calibration and equipment main-
tenance. These mechanisms are all legitimate program costs directly assign-
able to the State and the operatorts) of the inspection facilities. For
quality-assured repairs the present repair facility certification program
in Michigan could be supported by periodic State inspections of garages
and emission analyzers. Mechanics must also be instructed that they should
tune a failed vehicle to manufacturer's specifications. Appendix E
discusses these mechanisms in greater detail, reviews the most common
means by which some motorists would attempt to cheat the system and
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identifies effective methods for their prevention. The costs of appro-
priate quality assurance elements have been included in the total program
cost analysis for each program option,
1.4 PROGRAM COST ELEMENTS AND COSTING METHODOLOGY
Development of total program costs for each of the seven base options
of Table 2 is based on a life cycle cost model which sums annual operating
costs and amortized implementation and capital costs over the life of the
program, and develops annualized program costs. The three principal cost
categories are Initial Implementation Costs which are those expenditures
required to bring a given I/M concept to the point of implementation and
include design, development, documentation, training, and support personnel
costs; Capital Costs which are those expenditures required for obtaining and
improving land for facility sites, constructing the facilities,and procuring
testing and support equipment; and Annual Operating Costs which, are those
expenditures necessary to administer, operate, and maintain inspection
facilities and provide appropriate quality assurance, consumer protection
and public information on an ongoing basis. The specific elements of
each, cost category are listed in Table 3 and explained in Sections 4.2.1
through 4.4.4 of Volume 2. The cost methodology is based on the following
principal assumptions.
Five-year life of program
Amortization period of five years for equipment costs, twenty
years for building costs, and perpetuity (.constant value), for
land
All fringe costs to state and contractor are included
Vehicle population growth rate of 2.8 percent per year
Land cost estimates per square foot vary by density of land
development
Unit costs for facility construction are uniform for all options
All costs are expressed in 1978 dollars
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For the base options costing, costs were developed for a program that
would cover the ozone nonattainment counties (Figure 11, which include the
carbon monoxide nonattainment area of metropolitan Detroit. Only light-
duty vehicles would be covered by inspection. For determining total capa-
city requirements, the vehicle failure rate is conservatively assumed to
be 30 percent. Tests would be conducted at one or two-lane facilities
using the three-position lanes described earlier. Options incorporat-
ing safety and noise testing use five position lanes. "Worst case"
travel distance to a test facility (maximum) is 30 miles. An initial work
schedule of 8 hours/day, 250 days/year (2,000 total hours) is assumed. The
mandatory program would start January 1, 1983 utilizing implementation and
construction funds made available by the end of 1982, and no additional
facilities would be constructed during the life of the program; that is,
vehicle population growth during 1983-87 would be accommodated by additional
hours of operation.
The selected base options, and reasons for their selection, are des-
cribed below. Option numbers reference Table 2.
a) State-operated, idle mode with automated testing and data
processing but without safety and noise inspection (Option 1).
This program is representative of any state-operated program
that would involve all LDV's in the given study area.
b) State-operated, idle mode with automated testing and data
processing and including safety and noise inspection (Option
2). This option develops the cost for incorporating safety and
noise tests as part of the total testing procedure. This cost
remains uniform (by geographic area) across all administrative
or emissions test mode options.
c) Contractor-operated, idle mode with automated testing and data
processing without safety and noise inspection (Option 31.
This program is representative of any contractor-operated
option but with cost requirements at the lowest level for any
contracted system.
d) Private garage (decentralized), idle mode with manual testing
and data processing without safety and noise inspection (Option
5). This was deemed the most feasible and probably lowest
(total) cost representative of the range of private garage options.
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e) State-operated, statistical sampling program with automated
idle mode testing and data processing and no safety and noise
check COption 71. The State of Michigan has had experience
with a program that statistically sampled vehicles for defects
in safety-related.equipment. The findings of this study indi-
cated that the incidence of malfunction was relatively insen-
sitive to the size of the sample. Therefore, statistical sampling
for vehicle emission control malfunction could prove as effec-
tive as the safety testing program in identifying gross emitters.-
The selected option would be the least complicated of the sta~
tistical sample options, presuming the sampling rate to remain
constant, across all possible configurations,
f) State-operated, loaded-mode with automated testing and data
processing and without safety arid noise testing (Option 9) .
This is the baseline representative of possible loaded mode
configurations, selected specifically for cost comparison with
Option 1.
g) State-operated, EPDI inspection without safety and noise check
(Option 17). This option was selected specifically for cost
comparison with Options 1 and 9.
Program cost development procedures are detailed in Appendix F to
Volume 2, and program cost tables are presented in Section 5.0, The computed
annual inspection fee per tested vehicle (1978 dollars) ranged from $5,32
for Option 1 to $21.85 for Option 17. For each option involving either
a contracted or private garage testing program, a share of the fee is
allocated for State costs and the remainder for the contractor or garage
costs. Table 4 provides complete fee information for each of the options.
In order to develop program costs and fees for the entire set of
program options, line-item sensitivity factors to estimate the costs for
variation among key program elements were developed and are presented in
tabular form in Volume 2, Section 6.0. An I/M program in Michigan will
involve one of three inspection modes, any of six geographic areas, one
of five program stringency factors (standards set such that 10, 20, 30,
40, or 50 percent of vehicles fail the inspection), one of three admin-
istrative approaches and any of six vehicle types. The values of Tables
6-2 through 6-5 of Section 6 express the sensitivities to cost (that is,
the variation from the identified baseline of two-lane inspection stations
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for LDV testing throughput the 0, nonattainment area! experienced as one
O
moves along the range of possible combinations of each of the key program
elements. Computations employing these factors generated a. total program
cost and fee breakdown for each of the remaining seventeen options of Table 2,
These values are tabulated in Section 6, Table 6-1.
Table 4
OPTION NO.
1
2
3
5
7
9
17
CONSUMER
STATE
$ .5.32
7.04
1.01
1.15
7.23
6.30
21.85
FEE IN 1978 DOLLARS
CONTRACTOR
OR GARAGE
$ .00
.00
4.80
4.48
.00
.00
.00
TOTAL
. FEE ,
$ 5.32
7.04
5.81
5.63
7,23*
6,30
21,85
* This figure is reduced to $0.34 per owner if costs are equally
allocated over the entire light-duty passenger vehicle population.
1.5 ELIMINATION OF UNSATISFACTORY OR INAPPROPRIATE OPTIONS
An objective of this study was to reduce the total number of candi-
date programs from twenty-four to a short list of three or fewer options
to undergo further analysis in a later phase of the program. Although
considerable information was derived from the alternatives costing analysis
described above and from investigation of the relative advantages and
disadvantages of the various options, it was desired to obtain additional
comments and opinions on this issue from various groups representative
of a larger constituency in the State of Michigan. Therefore, the
decision on what options would comprise the short list was made only
after extensive consultation with the Governor's Air Quality Review
Committee, the Michigan Vehicles Inspection/Maintenance Advisory and
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Technical Committees, the Legislative Advisory Committee, and guidance
of U.S. EPA. It was also responsive to expressions of public opinion
as obtained during the public hearings on the Michigan State Implementation
Plan and through the medium of a public opinion poll conducted under
auspices of the Michigan State Police, Office of Highway and Safety
Planning.
The decision process resulted in the elimination of the following
options. (Documentation of decisions is provided in Vol. 2, Section 7.0).
1. All inspection programs that include a safety and noise test.
Key reasons were:
Mandatory safety and/or noise inspection programs are not
currently operating in Michigan. While benefits may be
realized from implementing these programs, neither will
improve air quality, and both increase total program costs
and costs to the consumer. The Michigan Legislature must
decide if it is wise to go far beyond the intent of the
Clean Air Act to include other programs within a program
designed specifically to improve air quality.
* States with safety programs currently operating question
the effectiveness of safety inspections in reducing vehicle
defect related accidents.
I/M programs that include safety and noise cost 30% more than
programs testing emissions alone.
Experience from other safety and emissions testing programs
indicates that over 50% of the tested vehicles fail the
combined test. Costs for retesting failed vehicles will
increase accordingly.
Average repair costs for vehicles needing repair will be
higher.
Any I/M test mode is capable of identifying most of the
vehicles that would fail a noise inspection, since most
faulty mufflers or illegally modified exhaust systems are
audible. In some cases faulty mufflers must be corrected
prior to an emissions test, since exhaust leaks make it
impossible to obtain accurate test results.
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Program implementation will take longer due to increased
program complexity.
It may be difficult to obtain legal authority for the
combined program since the required legislation is much
more complex and controversial than I/M legislation alone.
2. All options involving a statistical sampling program with par-
ticipation not to exceed 25 percent of registered vehicles.
Key reasons were:
It is not possible for the State of Michigan to demonstrate
that the emission reduction from I/M required by EPA policy
can be achieved by this program. This type of program may
be able to demonstrate where overall emissions are, and
what further reductions are possible through a vehicle I/M
program.
Other control strategies either from stationary sources
or from other transportation control strategies will be
required to offset the shortfall in emission reductions
obtained through this program.
This approach is not acceptable to the federal EPA, since
it does fulfill the Clean Air Act Amendment requirement for
I/M to be "mandatory and periodic".
3. All options involving a State-operated network of inspection
stations.
Key reasons were:
The initial costs to the State to implement the program are
high.
There is uncertainty in obtaining required funds to imple-
ment the program.
Governmental employment will be greatly expanded as compared
to other private sector administrative approaches.
There will be a loss of property tax revenues collected by
local governments because taxes are not levied on State-
owned facilities.
Flexibility to terminate the program is lacking.
Implementation time is likely to be greater due to the
involvement of many state agencies, and because legal,
financial, administrative, and hiring requirements are more
complex in the public sector than in the private sector.
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4. All options involving both initial emissions, testing and repair
at private garages.
Key reasons were:
There is reluctance by the private sector and consumers
to have private garages perform both the ,,anspection and
repair due to a potential and/or perceived conflict of
interest.
A high turnover rate (10%/year) of garage ownership is
experienced in Michigan. This makes it difficult to quan-
tify program costs since the level of participation by
garages is unknown.
Quality assurance costs are higher because instruments at
many stations must be calibrated and checked for accuracy
regularly. It is also necessary to check regularly for
proper testing procedures and valid repairs.
More resources must be devoted to private garage licensing,
quality control and complaint investigation than for the
other administrative approaches.
So far, all of the states with private garage run I/M pro-
grams are states that had pre-existing safety inspection
facilities. I/M was added onto their safety program. This
substantially reduces planning time and capital required to
implement the program. This is not the case in Michigan.
Most vehicles would have to be scheduled, by appointment,
for inspection at a private garage, since most garages would
be unable to achieve a high output rate. This increases
the average workload at private garages and may increase
average waiting times. In other inspection approaches,
only the failed vehicles (20-30%) must schedule garage
appointments. The overall effects of the added workload
and its effect on program costs and consumer costs are not
possible to predict at this time.
5. All options involving loaded-mode inspections (.retaining the
assumption that inspection stations could nevertheless be
built to specifications that would accommodate such testing
in the future.)
Key reasons were:
The loaded mode test provides substantial diagnostic infor-
mation. The benefit of the additional information is depen-
dent on the mechanic's ability to use the diagnostics. So
far there is no indication that mechanics effectively use
this diagnostic information when repairing vehicles.
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A loaded test does not increase the amount of emission
reductions obtained by the program,
The repair industry may find it expensive and impractical
to buy a dynamometer to duplicate loaded test results for
repair purposes. If a repair garage cannot duplicate the
test to see if repairs are correct there is a possibility of
additional retests and additional consumer dissatisfaction,
A loaded test costs 18% more than an idle test,
If heavy duty vehicles are included in a loaded test I/M
program, special double axle dynamometers will be necessary..
This substantially increases program costs.
6. All options involving engine parameter/device inspection (EPDI),
Key reasons were:
The parameter inspection defined in this report is approxi-
mately four times as expensive as an idle test.
Very little information is available pertaining to the test
time (and subsequently output rate at inspection stations)
involved in parameter testing,
* I/M facilities for another test mode may be designed to in-
clude flexibility to change to a parameter/device inspection
test mode. If a cost effective parameter test is developed
this option may be chosen.
EPA has not established a method for calculating emission
reduction credits for this test type. Currently, the burden
of proof of emission reductions from this type of program
is on the individual states.
Therefore, the remaining candidate options will be carried forward
for additional study.
a. Contractor-operated idle mode testing and retesting at
centralized facilities.
b. Contractor-operated idle mode testing with retesting at pri-
vate garages (New Jersey-type program).
c. Alternative parameter inspections (as information becomes
available).
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The comparative advantages of a centralized, contractor-operated
program were found to be greatest for the following reasons,
The direct costs to the State of Michigan are lowest,
Implementation procedures are straightforward.
This approach ranks second only to a state-operated program
with respect to assured quality and consistency of test.
Idle mode inspections were determined to be the most cost-
effective testing procedure.
Inspection facilities will remain on municipal and county tax
rolls.
The program can be more easily terminated at the end of the
period of contract.
The opportunity for conflict of interest between inspection and
repair is minimal.
The report has shown that total program costs are not signifi-
cantly greater than for a similar state-operated system.
The other two options carried forward were not identified for analysis
in this phase of the study.
&.-^,,^,,.3 .,,,
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0 S. Environmental Protection Agenqf
Region 5, library (PL-12JJ
77 West Jackson Boulevard, Uth floor
Chicago, II 60604-3590
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